Transcript of Proceedings
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CONFERENCE ON ENCAPSULATION OF
ASBESTOS-CONTAINING BUILDING
MATERIALS
Volume 1
Arlington, Virginia
June 8, 1981
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CONFERENCE ON ENCAPSULATION OF
ASBESTOS-CONTAINING BUILDING MATERIALS
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Monday, June 8, 1981
Sheraton National,
Washington Blvd. and Columbia
Pike,
Arlington, Virginia
8:30 a.m o'clock
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CONTENTS
2 Speaker: Page;
3 Larry Dorsey 1
4 Edward A. Klein 3
William Mirick 12
6 Ernest Lory 74
7 James Hubbard 111
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2 MR. DORSEY: Good morning. It is just past 8:30.
3 A few more people are coming in, but I think most of us
4 are here .
5 With us today is Ed Klein, the Director of
6 Chemical Control, Office of Toxic Substances, and he would
7 like to welcome you.
8 MR. KLEIN: Rather than listen to the noise of
9 the mike, can you hear me in the back?
10 First, I would like to welcome everybody coming
11 at this bright and early hour all the way out to Virginia.
12 We are here to take a positive attitude of cooperative
13 solutions to programs of asbestos-containing materials
14 in buildings. I guess the one thing that everybody has
15 in common here is that we are all looking for information.
16 We at EPA are here to learn as well as share
17 experiences that we have had, and we have allowed a considerable
18 amount of time for open discussion and we are really very
19 interested in everybody's views.
20 I would like to give you a brief summary of EPA ' s
21 activity. We have been working with encapsulation for
22 two years and we are now entering the second major phase
23 of our work. During this second phase, we will turn the
24 testing encapsulation back to the private sector and we
25 are developing test procedures both from the laboratory
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and the field and we are working with ASTM to develop per-
formance standards for encapsulation.
Other speakers today will discuss EPA's current
and past programs in more detail. Let me give you a quck
overview of today's proceedings.
Larry, who manages EPA's school asbestos program
will begin by talking about the program and EPA's activities
with respect to encapsulation. I hope his remarks will
provide a broad context for later discussions.
Next we will hear from three experts who have
conducted independent research projects on encapsulants.
William Mirick, the principal investigator for Battelle
Lab; Ernest Lory of the United States Navy who has evaluated
encapsulants in ways Battelle did not; and then there is
James Hubbard of the Georgia Institute of Technology who
has conducted evaluations of encapsulants in the field.
Forest Reinhardt will conclude the day by speaking
briefly about future plans with regard to encapsulants,
focusing on a plan to turn encapsulant work back to the
private sector and the work of ASTM, which is writing
performance standards for encapsulants.
The second day we are going to have a panel of
experts who will discuss their experiences with regard
to encapsulation in the field. Questions like what are
proper application techniques, what airborne fiber
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concentrations can be expected during encapsulation and
other important issues will be raised.
3 In the afternoon, another panel will discuss
4 decisions to encapsulate;. How can you tell if a material
5 is substitutable for encapsulation, what does it do to
6 the insulating properties of the encapsulating materials.
7 We hope that we will have a lot of time for questions and
8 discussion:.
9 With that I will turn it back to Larry. Thank
10 you very much.
11 MR. DORSEY: Thank you. In today's presentation
12 I know the way that we are set up it appears rather formal,
13 set up for our presentations. I would like to ask that
14 if you have a question, as it and keep the discussions
15 as< informal as possible. The purpose of this meeting is
16 to discuss the research needs and to also present to you
17 some of our findings from some of the research that we
18 have sponsored in the past.
19 Many of you are the experts out there. You have
20 been in the business. You have worked with the various
21 sealants. We would like to share that information. We
22 would like to share what we have done in the past, what
23 we hope to accomplish in the future and get your suggestions
24 and ideas.
25 So please, I solicit any questions and comments
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1 at any time. So that we all have a common basis, some
2 of you have been involved in our program in the past. Some
3 more than others.
4 I would like to go over a short history as to
5 how we got into the school asbestos business, which will
6 give us a point of reference when we are discussing the
7 need for future research in the sealants.
8 in 1978, the Environmental Defense Fund petitioned
9 EPA under the Toxic Substances Control Act to regulate
10 the school asbestos problem. At that point we didn't have
11 information and background, we didn't know if there was
12 a problem, but we started research and started investigating.
13 What we discovered immediately was that many
14 school systems were attempting to deal with their asbestos
15 problems without good technical information.
16 There was not a guidance document to help people.
17 Some people were over-reacting, attempting to deal with
18 an asbestos problem that we say is not a problem. Others
19 were attempting to ignore the problem.
20 We contacted the experts throughout the country,
21 Mt. Sinai, Sawyer at Yale, various people in the research
22 business, and developed a guidance document and this was
23 the initiation of our school asbestos program.
24 Copies of the documents have been distributed
25 today. We mailed this guidance document to every school
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1 district in the country, set up a program to make them
2 available through an 800 number and it has been the backbone
3 of our program.
4 Concurrent with announcing this technical assistance;
5 program, we initiated the regulatory program. To develop
6 a regulation is quite a lengthy and diffcult process. I
7 know that the posture of the country at this point is anti-
8 regulation, and if you have been involved in a rule making
9 process, I don't think you need very many more people to
10 slow you down.
11 It takes about 18 months to two years to develop
12 a regulation and that is really an ambitious program. That
13 is saying that all the pieces of information will come
14 together. We didn't know the scope of the problem, the
15 range of the problem, some of the technical difficulties
16 that we would encounter.
17 One of our concerns was attempting to identify
18 the schools that require corrective action and attempt
19 to give people reasonable guidance and recommendations
20 on how to correct their problems.
21 We say that you can remove the asbestos, encapsulate
22 it, enclose it or in some cases, you can set up a
23 maintenance program and defer action.
24 Our work on the encapsulating agents at the point
25 when we wrote the guidance document was almost nil. We
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1 knew that various agents were being used. There was research
2 underway to test various sealants. The only contact I
3 had was to visit various sites where sealants had been
4 used and it was a very, very difficult process to provide
5 guidance at that point.
6 I think we have come a long way in that area,
7 but when the guidance document was written, we knew very
8 little about sealants. Along the way in developing the
9 rule, we were working with an algorithm, an exposure system.
10 Sawyer at Yale, one of the most thorough research papers
11 dealing with this problem, in '77, he identified a problem
12 with the Yale School of Art and Architecture. In his paper
13 we went through with various tests, et cetera, and had
14 measured levels, removal and various simulation studies,
15 et cetera.
16 In 1978, the Secretary of HEW notified the various
17 health departments throughout the country that there was
18 a potential problem associated with this asbestos material,
19 but no recommendations or actions or how to deal with the
20 problem.
21 It is not a new problem. In 1973, EPA under
22 the Clean Air Act, banned the future application of the
23 sprayed-on material. At that point, we were not concerned
24 with problems in existing structures or with the material
25 in existing structures, but subsequent to that, more and
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more problems were identified.
This material came into its own in the late fifties
3 It is a technique that was developed in England and after
World War II, it came into wide use in the United States.
5 For some reason;, we also had the baby boom and a number
6 of things coming together and in the late fifties we needed
7 a number of schools built and the cheapest way to build
them was a steel structure with a pitched roof and outside
9 the sprayed-on material.
10 Throughout the United States, we have identified
11 schools with the sprayed-on asbestos material. There are
12 a number of programs underway. We envisioned at one time
13 a broad regulation requiring inspection of every school
14 in the country and that would be connected with an abatement
15 program requiring corrective action.
16 A number of difficulties in developing that regulation,
17 primarily in developing a standard or an exposure system
18 that anyone could use to determine which schools required
19 action where the material had to be removed.
20 We have backed off and are ready for final promul-
21 gation of a regulation requiring identification of all
22 the asbestos materials in the schools, plus a notification
23 system to all the employees that asbestos is present in
24 that school.
25 We are concerned with custodians, maintenance
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1 workers, builders of schools. If we have to disturb the
2 material, there are precautions and techniques that we
3 recommend. So at this point we are not requiring any cor-
4 | rective action in any school in the United States.
5 We are requiring identification and that a manageme it
6 system be established in the school where the asbestos
7 material has been identified. This is primarily to notify
8 the workers in that school that asbestos is there and not
9 to disturb it.
10 We are continuing our research on the various
11 aspects of the program with sealants, also with developing
12 this exposure assessment system and providing technical
13 assistance to school officials and other building owners
14 on how to deal with their problems.
15 The focus of the conference is sealants. Bill
16 Mirick will give our opening presentation. Bill has been
17 working with us for over two and a half years. He started
18 under this air contract testing various sealants. When
19 we initiated our program, he travelled throughout the United
20 States with us, and we have provided him what information
21 we had then on sealants.
22 We are very close to getting a final report from
23 Battelle. When that is available within the next month,
24 it will be distributed to everyone.
25 Forest Reinhardt is actually in charge of
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1 distributing the report and has been the contact in our
2 office.
3 if you would like a copy, leave your address
4 with Forest, and we will send a copy to you.
5 Are there any questions on what I have discussed?
6 It is a lot of information in a very short time,
7 but I wanted to explain why we are in the business and
8 why we are sponsoring this conference. Again, the purpose
9 of the conference is to discuss the research findings of
10 the past, various research programs, not only what we have
11 sponsored, but Navy programs, Georgia Tech, et cetera,
12 and also to discuss future research needs.
13 With that, I would like to introduce Forest
14 Reinhardt, who will be the moderator for the panel discussion
15 tomorrow and also will be moderator today.
16 Most of you, I think had talked to Forest or
17 been introduced to him in the past. He is a person on
18 our staff that is our expert on sealants and has been the
19 one that developed the sealants guidance document and has
20 distributed it.
21 With that, I would like to introduce Forest Reinharcjt.
22 MR. REINHARDT: Good morning. We seem to be
23 running a little ahead of schedule, which I think is rather
24 atypical for conferences like this, but I am not sure it
25 is a bad thing. So I would like,without too much delay,
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1 to turn the conference over to Bill Mirick who has been
2 working at Battelle Laboratories for about 25 years. He
3 holds a degree in chemical engineering from Ohio State
4 University and has been working on encapsulants for EPA
5 as Larry said for about two years now.
6 MR. MIRICK: Thank you, Forest. I hope you can
7 all hear me.
8 I am looking out over the audience here and I
9 think I have talked to about half of you already. Some
10 of you will be getting new information, some of you won't.
11 When I go to these, it looks like I see more and more familia
12 faces.
13 I am going to get into some of the basic studies
14 that we did on the encapsulants and the reason we did them
15 and some of our conclusions and what we found out about
16 them.
17 Basically, when we started looking at materials
18 to encapsulate the friable asbestos, we looked at it as
19 a normal paint chemist would and tried to put some of these
20 on metal panels, tried to discuss the work on abrasion
21 resistance, the flexibility of these coatings, but soon
22 after we got into the program we foudn out that because
23 of the friable matrix, we were working with these types
24 of test were impractical to work with, so we had to develop
25 and work with a test matrix that simulated the asbestos
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material in the field.
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One of the first things we did then was to go
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out into the field and look for a typical and I have
to put that in quotes, because I really haven't found any
real typical asbestos-containing matrix. The one we used
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for a base background data was one containing 35 percent
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chrysotile asbestos and the rest was mineral wool.
0
We tried to develop a test matrix. We found
that the product called cafco bond or cafco blaze shielded
CF, most nearly simulated the properties of this asbestos
containing material.
Now, the material that we worked with was strictly
13 a mineral wool substraight, and that is what we decided
14 on to use as a test substraight. It had basically the
15 same penetration with water, it had about the same degree
of impact resistance.
17 It had a lot of other properties that the asbestos-
containing material had. It had somewhat similar surface
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properties in the mineral wool as the asbestos-containing
20 material did. So this is the product that we used to evaluat
and check the sealants, realizing that there are other
rto
combinations and there is a tremendous amount of other
materials out in the field that the encapsulants would
24 have to work over.
25 It is difficult to go into the field and look
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at a material and say this is an asbestos-containing material
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and it can be encapsulated. Even after you have looked
athte bulk sampling and found that it contained asbestos,
4 you also have to know what other produ ts are there, because
5 each product has a somewhat different surface charge if
6 you want to call it that, and the surfactants and the wetting
7 agents used in these encapsulants may or may not wet these
8 other materials.
9 You want the encapsulant to --- if you are using
10 a bridging, you want it to penetrate a little bit into
11 that asbestos-containing material. You don't want it to
12 laden the furface and fall off later. With the penetrating,
13 if it doesn't penetrate, it is not doing the job it is
14 supposed to do.
15 So we tried to develop a test matrix that would
16 work as much as possible on all of these. We found out
17 that the test matrix did not encompass all types of asbestos
18 or all types of conditions you run into in the field. You
19 have to remember that these matrixes you see out there
20 may not be just what was supplied by the manufacturer,
21 by the applicator may have decided when hi put it on concrete
22 it has good adhesion, but to steel it doesn't have the
23 right adhesion, so I may add something to it to help it
24 cling better.
25 When he does this, he has changed the properties
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of that asbestos-containing material.
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In our study we could only look at one test matrix.
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So this is one of the problems you are going to run into
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today.
Even though these sealants prove to be satisfactory
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on that test matrix, they may or may not be on the material
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you are putting it on in the field. Getting back into
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the testing, we did then, we applied these encapsulants
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to this test matrix we used and this is what we did our
testing on.
We tried to develop testing on this test matrix.
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Remember, we are talking now about the friable matrix,
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the friable material that you can crumble in your hand.
14 We sprayed this on -- the first test was on styrofoam board
to give us backing and we tried to determine a few tests
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that would give us the most logical properties of these
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encapsulants.
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We wanted to find out how much it penetrated
or how well it wet the surface of that material. We developec
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a penetrating test, we pourted the material on the surface
of this. This made a good screening test, because some
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of them, if they wouldn't wet it, it would bunch up on
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the surface and not penetrate into the material. Or when
~4 they dried it didn't have a good thick layer of penetration.
Some of them would just lay on the surface, even though
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1 they are penetrating materials.
2 When you first looked at that material, it was
3 wet all the way through. The water in that emulsion was
4 carrying all the way through. Or in the case of bridging
5 sealants, when you poured some of them on after they dried
6 and cured, you could pinch it in the middle and lift that
7 bridging sealant off.
8 It was not wetting the surface of that mineral
9 wool. Realizing that the penetration test by just pouring
10 it on is sort of false, when we got to the second part
11 of the program we made four by four square foot panels
12 of the mineral wool and mounted them in an upside down
13 position and we applied all our encapsulants by airless
14 spray onto these surfaces.
15 This gives us now the penetration that is the
16 true that you would find in the field when you are spraying
17 overhead. You have two things working for you and several
18 working against you when you are spraying overhead. The
19 two things working for you is the pressure of the spray,
20 and we didn't want to use a high pressure.
21 The other is the capillary action and the surface
22 action of the materials trying to draw the material up
23 in there. The force of gravity was trying to pull the
24 material back down. So penetration is determined then
25 by mainly the air pressure and the capillary of -- and
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l wetting these asbestos fibers up into there.
2 It is difficult, if you have incompatible
3 encapsulants to wet those surfaces, because they are not
4 drawn up by capillary action. This was the penetrating
5 test. These are some of the problems we run into when
6 apply an encapsulant in an overhead position. If you are
7 not wetting that surface because of the surface characteristics
8 of that material, you don't get adhesion that an initial
9 layer of that surface.
10 If you don't get this the material then falls
11 off in sheets. It may not do it in three or four days,
12 but it may do it three or four months later. The penetrating
13 test we decided on is after the material was cured we would
14 then take a core sample, a corkboard or something that
15 you can cut into the material, go all the way through,
16 put it in a glass vial and put water in it, let it soak
17 for four hours, dump the material out of the vial and measure
18 the hard core that you had of that material.
19 That seems like a sort of a rough test, but remember
20 these encapsulants when cured were supposed to be water
21 insoluable so the water doesn't leach out the resin.
22 So that is basically what the penetrating test,
23 was, how it came to be. We have also tried soaking it
24 for 24 hours to see if we could leach anything out of the
25 water and we analyzed the water. In most cases we found
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1 the materials were not leaching out enough resin to give
2 us any problems.
3 Flexibility of coatings. A lot of these coatings
4 are planned if you put them on steel substraight they have
5 excellent flexibility. The main problem we are working
6 with now is how can you determine flexibility on a substraigh
7 that is really not flexible.
8 It can't bend this friable material like steel
9 over a mandrel. It is too thick to bend over a form of
10 some kind.
11 You deform the bottom, you don't deform the top.
12 How can you measure flexibility, how much the coating bends?
13 We found out that it doesn't make too much difference how
14 much you do bend that materal. We are not really concerned
15 with the flexibility of the material itself.
16 We are concerned mainaly with how well it adheres
17 to the surface of that material. If it doesn't adhere,
18 then we have problems.
19 So we went from a flexibility test to an impact
20 testing where we have a tube with a known weight, we drop
21 it a known distance and it impacts on the surface of the
22 material. We determine how much it impacts in under a
23 certain load and examine the surface of the material and
24 see how much it is broken or bent in.
25 This is the way we determine the impact resistance
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l of materials. If you take a broom handle and poke it against
2 a ceiling and see how much you can force the broom handle
3 into the material is not a good way, because there is no
4 way you can control how hard you poke with a broom.
5 It is a good test if you have a calibrated arm
6 and the right sized broom handle, but it is very hard to
7 describe to people. So we tried this impact test, but
8 the trouble with that, we have to cut the sample out, turn
9 it upside down so we can drop the weight on it.
10 We have not been able to develop a good impact
11 tester that you can use against a ceiling that works upward.
12 It will have to be spring loaded.
13 After we tried one with spring loading, we found
14 we had a lot of variations, not so much because of the
15 spring force, but because the resistance was working against
16 the force of the spring and it did not give true readings.
17 We hvae looked at these impact tests and the only way they
18 really work and they are reliable is actually to spray
19 your encapsulant on the best substraight or on a substraight
20 that you are going to be using, cut a section out, turn
21 it upside down and drop the weight on it.
22 It doesn't do any good to do anything else. You
23 can poke at it, prod at it all you want, and you really
24 can't tell the resistance to impact until you do this type
25 of testing.
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It has to be done on a friable matrix. If you
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do it on a metal matrix, it is not true. We have stone
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chip tests, testing on automobiles, but they dno't want
unless you are working with the material on the actual
5 matrix you are using it on.
c
Another requirement of the encapsulants we felt
7 was very necessary, one, when you had them in a fire they
Q
did not release a tremendous amount of smoke. This is
a typical thing of a lot of coatings. We don't want smoke
resistance. But, again, when we tested them, we got a
lot of encapsulants in that had class F fire ratings and
12 low smoke ratings.
1 *}
This was done on asbestos board, it was done
14 on plywood. As soon as we apply it to the test matrix
15 of mineral wool, we have differences. We have some tested
16 class A, most of them would have a flame spread rating
17 of 10 or 30.
18 When put on the friable matrix, they go as high
19 as 50. Trying to explain the reason for this was a little
20 difficult. Fire ratings were different.
21 The smoke ratings were different and the toxic
22 gases released weren't any different. They stayed about
23 the same. So we considered that the material burning was
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about the same, but the amount of toxic gases did increase
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sometimes.
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1 Now, where did this problem come from? Well,
2 we finally concluded that the friable matrix because of
3 the type of material it is, it holds the heat. It doesn't
4 let the heat dissipate through like an asbestos or plywood
5 board would.
6 It holds the heat and you end up heating your
7 coating from both sides of the material. You have got
8 the heat coming from underneath and you have the heat on
9 the surface from your radiant panel test. The biggest
10 problem is that the material in the encapsulants in the
11 asbestos-containing material does not get the oxygen it
12 sees on the surface on an asbestos board or on a plywood
13 panel.
14 Therefore, you are not burning the gases by the
15 radiant heat, you are creating smoke. So we end up with
16 a larger generation of smoke and sometimes a larger flame
17 spread, because when the smoke is released, you have a
18 false flame front going on because you burn the combustibles
19 in the gas stored under the surface.
20 That is some of the problems. There will be
21 a lot of materials have class A on the asbestos board and
22 on the pine or redwood panels, but on the friable test
23 matrix will have a lower fire classification. The toxic
24 products that we just analyzed, we didn't do the way I
25 would really like to do. We just pulled them off the
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1 smoke chamber and ran them through tubes to give us a gas
2 analysis.
3 The ideal way would be to put them in a vacuum
4 flask and analyze the flask for all gases contained there.
5 When you are trying to do 150 tests in a short period of
6 time youjust don't have time to do all those analyses.
7 The encapsulations, when we started looking at them, we
8 talked about the penetrating and the briding type encapsulant
9 Let me define those for you.
10 Basically, a penetrating encapsulant is going
11 to be low in viscosity. We are talking about most of the
12 time around water thin.
13 It is going to be fairly low in solids. In other
14 words, may have no more than 15 up to about 30 percent
15 volids in these, sometimes 35, and it generally is non-
16 pigmented.
17 When you get into the briding encapsulants, those
18 are usually higher in viscosity, higher in solids and usually
19 are pigmented. Now, the briding encapsulants, if you --
20 the reason we call them -- you can thin the bridging down
21 and probably get some penetration, but basically remember
22 the asbestos material is somewhat of a filtering device
23 also, and when you think a bridging encapsulant down enough
24 so you get real good penetration, you also filter out the
25 pigment onto the top surface of that material and the pigment
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usually lies within a quarter of an inch from the top.
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Once you have the pigment up there, you sort
3 of have a barrier for further penetration. So you can,
4 by good application and careful application with a pigmented
material, you can get penetration up to half an inch, but
f*
you are probably applying this in three, four, five or
7 six coats, and in the field, this is not too practical.
Q
Bridging sealants and penetrating sealants --
I have been accused of sort of favoring penetrating sealants
and possibly I am a little biased in their useage.
11 The penetrating sealants basically, if they functio
correctly, will encapsulate each asbestos fiber and you
will have something like a matrix like a vinyl floor tile.
14 Each fiber is encapsulated if the penetrating sealant has
15
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functioned properly.
16 Bridging sealants, because of their nature, bridge
17 over the surface. They really do not penetrate and encap-
18 sulate each individual fiber.
19 There are uses, though, for bridging sealants
20 and there are uses for briding sealants. I have some
21 difficulties when you hare large flat areas of a very friable
material that I don't think should even be encapsulated
23 in the first place where people have applied a briding
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sealant to it.
25 What happens afterwards I don't really know.
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1 I have seen somewhere several months after they have applied
2 an encapsulant that -- where they have applied a bridging
3 on a large flat surface which should not have been encap-
4 sulated, the material is pulled loose and you have the
5 material hanging down plus you have a very raw asbestos
6 substraight up there which has been disturbed and you can
7 release a tremendous amount of fibers.
8 I have seen failures in penetrating sealants
9 also. I will make a statement that I have made before,
10 that I only seen encapsulants being used in 15 to 20 percent
11 of the jobs across the country. There are too many areas
12 where people have tried to use an encapsulant thinking
13 it is a cure-all, that later on they will have problems.
14 Some of the no-no's for using an encapsulant,
15 whether it be bridging or penetrating, is where you have
16 evidence of water damange and that water damage problem
has not been corrected. If you have water damage and you
18 put an encapsulant on and you have more moisture coming
19 through, you have essentially sealed that surface, the
20 lower surface and then you have your asbestos-containing
material and then you have the substraight.
22 Water gets between the substraight and the
23 asbestos-containing material and your encapsulant. The
24 water stays in there now. It has no way of coming through
25 the asbestos-containing material, and you build up a reservoi]
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1 of water or moisture and you start deteriorating the adhesion
2 to the substraight and then you have a calamity if you
3 want to call it that, where the whole asbestos-containing
4 material, your encapsulant and everything falls to the
5 floor.
6
Another area where I don't see the use of encapsular
7 is where you have a friable asbestos material two inches
8 thick or more. It is very, very difficult over large flat
9 surfaces to tie up two inches thick material without some
10 other means of support.
11 On beams and steel structures where you can wrap
12 around and use the bridging sealant as an envelope where
13 you have contoured surfaces for it to wrap around, it will
14 probably work, because you can create a complete envelope.
15 But on a flat surface you can only tie into the
16 corners and the edge of the room unless you find some other
17 means of support. I have seen areas where people have
18 put up a chicken wire mesh over the whole flat area and
19 then spray it with a bridging encapsulant and it probably
20 does an excellent job.
21 Another area where you had great difficulties
22 with the use of encapsulant is where you already have some
23 of the asbestos containing material hanging down in clumps.
24 in other words, the material has already lost its cohesive
25 strength, the strength it has to hold to itself.
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1 Some people say that you can go in and wet it
2 down lightly and push this material back up and then go
3 back over it with your encapsulant. I find when you do
4 this, unless you are using an exceptionally good adhesive
5 that it starts coming down afterwards.
6 One test developed by ASTM is the use of a gallon
7 jar, where you put on a lid, push up the material and hang
8 a weight on it to see what the cohesive weight is. The
9 original material should have held a two pound weight for
10 one minute.
11 If you are going to try an encapsulation job
12 and the material cannot pass this two pound weight test
13 for one minute, I don't think you should encapsulate. You
14 may have lost there may have been water damage and you
15 may have lost some of the strength of the concrete or the
16 gypsum that was used for binders.
17 I am trying to think if there is anything I have
18 really missed on those areas. Some of the testing that
19 we have done has been basically on the test matrix. Now,
20 the test matrix is not all encompassing as I explained
21 earlier.
22 It does not contain fiberglass, blends of mineral
23 wool and fiberglass, blends of asbestos, and there are
24 asbestos materials we are talking about, if we are talking
25 about chrysotile, it has one surface characteristic, whereas
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the amosite and the crocidolite are different.
2
So the materials wetting the chrysotile will
g
not wet the amosite or crocidolite. So it is not a real
4
good guarantee that the encapsulant that you plan to use
is going to do the job.
n
I still remember and highly recommend and strongly
17
recommend, I don't know how you want to put it, that
Q
before you do an encapsulation job, you do a little test
Q
area on the actual substrates!. to see how well that encapsular
you want to use is going to work.
It is very difficult for me to go in and tell
12
you I have a hand brush test. I looked at the materials,
13
penetrating materials, I can brush hand over the surface,
and if it starts knocking clumps loose, I don't feel it
15
has done a good job.
1 fi
I don't have a good abrasion test for that, I
17 am trying to develop one. It is hard to tell you how much
hand pressure. When you spray a penetrating material or
19 some bridging materials, if you can run your hand over
20 the surface at about the same pressure you would use to
21 hold a five pound weight in your hand and you knock clumps
22 of material loose, that encapsulant has not done its job,
23 no matter how well it has penetrated.
Sometimes on bridging sealants, even though there
25 is a thick layer of briding materials, if you can feel
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something moving under there, you are probably finding out
that the briding material has really not wet that surface.
It is just laying on the surface and after a while it is
going to probably come down.
Granted it is not a very professional or scientific
test, but it is one I think you should look at and consider,
that if you can knock stuff off with your hand, your
encapsulant hasn't done a good job. Or one of the other
ways, and I don't like to do it because it gives other people
ideas of how to destroy this material, but if you take a
knife and cut a slot and put your finger in it and pull down
a little bit, if you feel the whole thing starting to pull
down, again, you have not really wet that surface.
We have got 10 of the encapsulants we looked at
out of the 150 that proved to be acceptable on the friable
test matrix out of 150. All of these that have proved to
be acceptable have passed all of those tests and are pretty
well described.
They do wet the briding sealants we have worked
with do wet into and do penetrate into the asbestos materials,
some of them up to a quarter of an inch.
We talk about thicknesses of bridging material,
we are not talking about how much of that briding material
we have put on. We may have put on only 25 mils of the
actual coating.
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The resin has penetrated in and we have a 3/16
of aninch thick non-porous good tough film in there where
the resin has penetrated and tied up in the asbestos matrix.
One I sprayed that I remember, a bridging encapsulant, looked
very good and everything.
We sprayed it on the test matrix, the four by four
foot square. We took the material off, left it in the rack
overnight on our upsidedown rack overnight, came in the next
morning ready to move it out and move another one in and
10 the whole thing was laying on the floor.
11 It did not wet the surface of that asbestos containing
12 on the mineral wool in the material. And you can run into
13 those problems in the field.
14 I think now probably the easiest way to do,
15 if you have any questions, I think the best way, we can
16 probably get more information out by asking and answering
17 questions than any other way that I can explain what we have
18 been doing on our tests.
19 VOICE: Could you further explain that two pound
20 test? In the area that it encompasses? In other words,
21 how large an area?
22 MR. MIRICK: What I do is put it on at least
23 it is a three and a half inche, three and a quarter to
24 three and a half inch gallon can jar lid. I put it up there
25 so it is at least a foot away from any corner or anything
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1 like that.
2 In other words, just a gallon jar lid that we
3 fasten to the sealing.
4 VOICE: You said you used urathane?
5 MR. MIRICK: Two component urathane as an adhesive
6 to hold it up there.
7 VOICE: You have got that cap weighted for two
8 pounds?
9 MR. MIRICK: No, I just have a hook in it at this
10 time, and I let it cure, let the urathane form cure and then
11 I hold the weight -- hange the weight on it afterwards and
12 time it for a minute. With some of the encapsulants, I was
13 available to hang up to 175 pounds of weight on that for
14 a minute without it falling off, but those were some very
15 outstanding encapsulants.
16 Does that explain your question?
17 VOICE: Yes, sir.
18 MR. MIRICK: It is an ASTM test. In the handout
19 you got today it is on the back page. It lists the ASTM
20 number.
21 VOICE: 1036.
22 VOICE: Have you done any tests with penetrants
23 and bridging encapsulants together, in conjunction?
24 MR. MIRICK: I have not. I understand some people
25 have been using these. I have not done any of that actual
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1 work, no. I was evaluating basically the individual sealants,
2 not systems.
3 VOICE: I am questioning the method of arriving
4 at classification where you pull some penetration types and
5 some briding types. You can't go by pigmentation solely
6 because some of these products have less than one percent
7 pigmentation and if they are not pigmented, they can behave
8 MR. MIRICK: I agree with you. You have to look
9 at the way they act. I am saying in general the penetrating
10 sealants are low viscosity, low solids and non-pigmented.
11 I am saying in general. There are a few that we had that
12 we had very low pigmentation in. I am not classifying those
13 as bridging sealants.
14 VOICE: The method of the test, taking the material
15 as is without regard to its let down procedure, its method
16 of application is highly erroneous. You can't consider something
17 by looking at a penetration core by putting a liquid on there
18 if you don't have the wetting action or viscosity.
19 You have some acceptable sealants here that are
20 ten percent solids, 90 percent water. There are other sealant;
21 higher in solids that could give a better money value in
22 terms of application if they were reduced.
23 YOU have to consider the properties of the
24 material you just can't consider it as it is. I take
25 exception to this only by it was classified as being marginal.
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1 I have evaluated the competition, I looked at what these
2 products were and what they were composed of and how they
3 behave and they take exception to the fact that they were
4 not treated equally.
5 You cannot take something at ten percent solids
6 and compare it to something 50 percent solids and say one
7 penetrates and one does not.
8 MR. MIRICK: We applied the encapsulants, we applied
9 them by airless spray. We reduced them to the manufacturer's
1° specifications that were given to us. Then the penetration
11 was studied by the actual situation where they were airless
12 sprayed and applied overhead.
13 That is the penetration reported in those reports.
14 Your viscosity, if you wanted it thinned three to one, that
15 is the way it was thinned. If that is what was reported
16 to us, that is the way it was thinned.
17 If it was not reported to us as being non-thin,
18 that is the way we applied it.
19 VOICE: In the future when you are working now
20 with the ASTM people with their new guidelines, are they
21 going to try to equalize the solids content as being a factor?
22 is this going to be a consideration?
23 MR. MIRICK: That is a very difficult consideration
24 to make to determine any paint or coating or encapsulant --
25 VOICE: In terms of what the resulting film will
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be. In other words, I have seen a two and three application
process of a competitor that will remain unnamed that is
considered acceptable. But the material has no reciliency.
You could actually take your finger and disrupt it because
it is running at eight, nine percent solids. Two applications
at nine percent solids is literally a no deposit film.
You are not going to have a recilient coating that
8 will prevent inadvertant contact and subsequent loosening
9 of the material.
10 Water sensitivity, I have seen films that are conside
11 to be acceptable that I know are water re-wettable. These
12 films are not water insoluable. I would like to know what
13 degree emphasis was placed on determining that degree of
14 insoluability.
15 MR. MIRICK: After we sprayed the material, we
16 took the core sample and put it in a glass vial for four
17 hours and 24 hours. But again, to try to answer your question,
18 if we base thins on percent solids, it is very difficult
19 to say that something - I agree with you to many degrees,
20 that if you have something that is 20 percent solid and you
21 put one coat on you have a lot better than if you have somethir
22 with only ten percent solids.
23 I have no disagreement with this. But if you look
24 at 100 different materials or 150 different materials, and
25 you reduce all those down to the same percent solids, you
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start with one that has 8 percent solid, that is all it has
when it is reduced down the way they recommend to reduce
it down and you start with one at 50 percent solids, you
are going to reduce some of these things down so much that
they are ineffective.
VOICE: I happen to know that my product was not
utilized according to the directions, so when you get flame
test runs, how much residual fuel is left after evaporating
9 of the solids. You will have 50 percent more residual
10 resin left there to burn with 50 percent.
11 If you have something at 10 percent very little
12 smoke will be generated and very little flame, because you
13 have less fuel. These are other considerations.
14 MR. MIRICK: I agree. If we try to put everything
15 down to one solid or bring everything up to one solid, with
16 150 products it is almost impossible to do.
17 VOICE: I think you should have a minimum solid
18 requirement.
19 MR. MIRICK: That I would consider, yes. I would
20 definitely look into that.
21 VOICE: I would like to ask a question on a different
22 subject. Has Battelle done any work on measuring reducing
23 the asbestos from the sealing with encapsulants?
24 MR. MIRICK: We hope to get into the area of doing
25 some abrasion tests and breaking off some fibers, not only
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1 on the surface, but down in the middle of the material and
2 look at them under the electron microscope to see if they
3 are encapsulated in the case of penetrating material, whether
4 they have a resin core or not.
5 We havenot had a chance to go into that complete
6 area. Basically what our work was doing was look at these
7 materials, whether they release toxic products, whether the
8 amount of smoke they generated, the flame spread resistance
9 and whether they were forming a good surface barrier at the
10 time.
11 That is basically all our work was doing.
12 VOICE: There was a remark that you had made as
13 to terms of friability and where you used in your testing
14 procedures approximately 75 percent mineral wol to balance
15 the chrysotile. I got the impression that this, in your
16 estimation, was representative of what was being experienced
17 in the field.
18 MR. MIRICK: I would not say it is representative,
19 it is what we used as our basis to try to form a matrix.
20 It was 35 percent chrysotile.
21 VOICE: And the balance mineral wool?
22 MR. MIRICK: Yes.
23 VOICE: Was this classified as friable?
24 MR. MIRICK: Yes.
25 VOICE: My idea of what friability means is it
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appears to be solid, like volcanic rock but you can crush
it and it turns into a powder. The process of 65 percent
mineral wool and chrysotile asbestos doesn't evidence that.
MR. MIRICK: This was one of the big problems we
had in determining what friable is. Friable is where you
can take your hand and break the material loose. It may
not crush into a powder, but by brushing your hand over it
or by rubbing over the surface, you can knock the material
9 loose.
10 VOICE: I think we have done well over several
thousand x-rays analyses, our concern was the other matrix
12 in the mass. I have yet to find one similar to the other.
13 We found this in gypsum, but rarely all mineral wool.
14 MR. MIRICK: We had to develop some kind of a test
15 matrix. We took one that is also where we did our field
16 studies, so we had our test matrix was similar to the
17 results of our field study as much as possible.
18 VOICE: Another question, where pigmentation --
19 MR. MIRICK: Could you have the speakers identify
20 ourselves?
21 VOICE: I am Ed Drasca with the KRC Research Corpora
22 tion.
23 The object of a bridging coating where pigmentation,
24 more emphasis was being placed on this, as to the normal
25 routines of pigmentation to vehicle, the vehicle being the
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1 actual binding polimers that are involved is generally around
2 22 percent.
3 The balance is pigmentation and extenders, which
4 there is generally a large amount of in our analysis of it.
5 The fact of a reduction of this down so you can maximize
6 penetration, you are reducing the polimer materials down
7 drastically where the cohesive and the adhesive strength
8 of the material has been reduced to a non-functional basis
9 and thereby reducing a bridgeant nature of this material
10 down to this point has its disasterous effects.
11 MR. MIRICK: This is true, and this is one of the
12 reasons why I am trying to bring each encapsulant down to
13 a certain solid only. It would have to be a resin solid,
14 not a total solid, and you can destroy the effectiveness
15 of bridging sealants because of this.
16 VOICE: I also think the criteria for your tests
17 can be objected to strenuously in many ways. It is not your
18 responsibility to determine the solids on a manufacturer
19 submitting you as a product for testing. Your responsibility
20 is to base what they state they feel is necessary to effect
21 these ends and not to reduce the solids down to such a point
22 that the material will be effective or non-effective.
93 MR. MIRICK: Our task was to evaluate commercial
24 products as submitted to us, using their recommendations
25 for the application of it, if they wanted it thinned three
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1 times, we did that.
o
On the test substrate that is why we gave them
3 the basis of a satisfactory or marginal type material. We
were applying it as we received it from them according to
5 their instructions. In several cases we had some of the
6 manufacturers actually come in and apply their material for
7 us while we observed it.
8 If they wanted to do that we had no objection to
9 it. But again, I would like to say, if you think some of
10 these bridging coatings down so much, ten percent reductin
11 sometimes can ruin the cohesive strength or the strength
12 of that bridging encapsulant. It just doesn't have the impact
13 strength, it may not even make a good film sometimes.
14 It may be a semi-porous film sometimes by reducing
15 it down ten percent. We did it to the manufacturer's
16 specifications.
17 Now, if we didn't do it to what they specified,
18 that is our fault in the sense that either somebody didn't
19 communicate with us or we misinterpreted what they sent in.
20 In one case we did this.
21 They sent in a fact sheet where they said to reduce
22 it seven to one, but they meant this is seven to one for
23 a miscoat first and later on in the folder, about three pages
24 later in the folder, they said it should be reduced only
25 three to one.
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1 VOICE: Would this be the general rule, that somebody
2 would be putting a product out on the market place with the
3 objective that the contractor or the user would have this
4 requirement to dilute it with water?
5 I think that would be fraught with a lot of
6 MR. MIRICK: There are some that they do recommend
7 being reduced, yes, sir.
8 VOICE: I don't think that is beyond the technical
9 ability of an applicator to apply material until you tell
10 him to reduce it to get the proper penetration viscosity.
11 I am not talking about reducing pigmented solid, shocking
12 the system, we are talking about simple ratios, like two
13 to one, and I don't think that is difficult at all.
14 VOICE: It isn't difficult, but there is a grey
15 area that could be deceiving because if a contractor bids
16 in he will throw a half a gallon in so he can make a profit
17 on the job.
18 VOICE: We want to give him a dollar value. If
19 we want to supply water we will give him a ready mix viscosity
20 on the job and we will end up with practically no solids.
21 VOICE: I think that would be a more practical
22 way.
23 VOICE: Does the mineral content or processing
24 of the water prior to dilution have any effect on the product?
25 MR. MIRICK: I want to get your name.
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VOICE: Ron Morel. Assistant Superintendant from
Manches ter, Vermont.
MR. MIRICK: I have not seen in too many application^
where you are reducing a paint down where the mineral content
of the water adversely affects the paint. I don't know of
any paint manufacturer that is using distilled water in their
letdown of the paint, so I don't think you really would have
that.
9 They are using regular city water. I don't know
10 if it had a sulfur content it might give a little different
11 smell, but I don't really see any problem in a paint formulation
12 of just using regular water.
13 VOICE: Toincrease the effectiveness of a penetrating
14 seal, wouldn't there be some emphasis on the fact of reducing
15 the lewis micron size or the particle size of the material
16 as well as adjusting the liquid of the acqueous phase by
17 using floro penetrants reducing the dine factor to normally
18 less than what normal surfactants do?
19 MR. MIRICK: Yes. I feel if somebody really wanted
20 to there are a lot of formulations that could be worked out
21 that will do a much better job of wetting asbestos material
22 in a lot of current products out today. I think it can be
23 formulated, I think a good product can be made, and you can
24 keep your solid content up to around 15 to 18 percent and
25 do a much better job of binding it.
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1 VOICE: Much higher in solids?
2 MR. MIRICK: Possibly much higher. Some of these
resins we are talking about, when you apply them with airless
spray because you apply them with high nozzle pressure, you
are getting a lot of sheer and you sometimes break down the
material and get better penetration just because of the sheer
that you got under the resin.
8 it helps it penetrate.
9 VOICE: There is another point. I don't want to
10 dominate the conversation, where you had indicated hangars
11 were present -- there was apparently a sheer factor to the
12 asbestos not completely severing itself because of the poor
13 interface adhesion between the substrate and the asbestso
14 matrix, but the sheer factor that had lessened its cohesiveness
15 and adhesiveness on the surface characteristics, which would
16 indicate that complete removability would be preferable
17 situation.
18 We found that using a high velosity vacuum with
19 a three inch hose to take off these elements from the surface,
20 not completely, but down to a relatively sound surface where
21 the adhesive and cohesive qualities were adequate for
22 encapsulation proved to be an economical --
23 MR. MIRICK: I would have no objection to this.
24 My main objection to this when we spray it on that they don't
25 remove it or they try to put it back up there. You can go
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ahead and remove that poor cohesive surface or the one that
has already deteriorated for whatever reasons, you remove
that and get to the solid matrix, I see no problem with puttin
an encapsulant on it.
5 I would rater hang the weight on it after I did
6 the vacuum cleaning to make sure, but I see no objection
if you can get that friable or loose material off the surface
before you put on encapsulant, I would have no problem with
that.
10 VOICE: Joe Martin.
11 Could you clarify one point for me?
12 In your earlier staement about the ASTM test of
13 pulloff, you are not saying that that is a sufficient test
14 to evaluate the overall performance of an encapsulant in
15 the field; are you?
16 MR. MIRICK: No. That is just one method of
17 determining whether the friable asbestos containing material
18 can be encapsulated. If it fails that test, I don't think
19 you should encapsulate it at all.
20 You have so little cohesive force there that can't
21 even take basically a two pound weight over you are talking
22 about 14 ssquare inches of space, if it can't take that,
23 that doesn't have very much strength.
24 When you put a coating on there, you are not adding
25 an awful lot of weight. A typical probably a bridging
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coating would weight at the most 16 to 18 pounds a gallon
if you got a pretty heavy one, pretty heavy pigments in there,
and you spread that over 30 square feet, you are not adding
an awful lot of weight to that surface, so we are not concernec
a lot about the weight of the material you are putting on
there.
What we are concerned about is that weight and
the water from that penetrating in through there when you
are applying it.
10 The water will penetrate, but the resin may not.
11 Now the water is wet through, now you have a wet, very friable
12 surface matrix.
13 Now that little bit of weight of that encapsulant
14 is enough to pull it loose a little bit.
15 VOICE: If you get a positive result would that
16 indicate that further tests would be required?
17 MR. MIRICK: If you used the cup test or the weight
18 test to see whether you have got cohesive strength, that
19 is nly one test. Yes, if the asbestos matrix past that can
20 support that, I think you should run a trial test or your
21 encapsulant on the surface to see if it wets that surface.
22 If it doesn't, there is no use putting the material on.
23 VOICE: How can that determination be made by non-
24 informed people in the market place, the wetability?
25 MR. MIRICK: The wetability is a very, very
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1 difficult factor. If I could come up with a good test of
2 that I would be a lot happier.
3 I really don't know It is an objective type of
4 testing, because I look at the surface and lift the corner
5 and see if it is wet. If you get a sealant that hasn't wet,
6 after you pull it off and look at it, you won't see any fibers
7 along that surface at all.
8 There is a few in there from mechanical adhesion,
9 where they have been wrapped around, but usually the surface
10 is almost smooth, there are no fibers clinging to the surface,
11 so it is not wetting that surface.
12 When you don't wet a surface and you put a material
13 up there, it is not going to stay. I guarantee you that.
14 VOICE: When you are doing this testing have you
15 come up with any overall common denominators between penetrating
16 sealants or bridging sealants? I am trying to get at, when
17 the federal government, for example, buys coatings or paints,
18 they have specifications which work from the constituent
19 components to the performance as opposed to performance back
20 to how the manufacturer made it.
21 When you are testing allk these products, have
22 you come up with any ccOTiron denominators of viscosity, suspen-
23 sion materials, whatever it might be, so that the manufacturers
24 may have a better guideline as to how to make their coatings
25 fit those parameters that make it work?
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1 MR. MIRICK: No. I have not. Because of the
2 different resins used, it is hard to say they should be of
3 this viscosity, have this percent of solids in them. You
4 have to look at the material, how it attaches itself to the
5 asbestos-containing material, how it wets that substrate,
6 what impact it has, what resistance it has after being on
7 the substrate.
8 I have seen emulsions that literally break after
9 applied. You get coagulation on the surface. I have some
10 put on steel that look beautiful, and they don't cure. I
11 didn't try to find out where this one didn't cure. After
12 ten days it was tacky.
13 VOICE: I think it is incumbent on the manufacturer
14 to make the determinations. If he cannot demonstrate the
15 astuteness to see the physical problems and the chemical
16 problems and the chemistry of it all, then he shouldn't be
17 in this damned business.
18 MR. MIRICK: I think I have to agree with you.
19 Our study was not to determine what a good formulation was.
20 It was not to determine what the best product was. Our basic
21 idea of this was to come up with a series of test methods
22 or at least give the manufacturers some indication of what
23 tests or what procedures the encapsulant should coform to
24 or should meet to be a viable material to use on the friable
25 test matrix.
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1 VOICE: You also indicated I think in your report,
2 recalling, it has been so long since I looked at it where
3 the polimeric substances were the vehicles being used. Was
4 this an identification --
5 MR. MIRICK: Just as an identification; that is
6 correct.
7 VOICE: Was this identification initiated by Battell
8 or was this submitted by the manufacturer as to what the
9 nature of the polimer was?
1° MR. MIRICK: It was submitted by the manufacturer.
VOICE: There is no way that you can make a deter-
12 mination of this?
13 MR. MIRICK: No.
14 VOICE: I would like to make tests on that
15 MR. MIRICK: I would, too. I would like to see
16 if some resins wet the asbestos material better than others.
17 I have a feeling that some would, but I have not done that.
18 Again, I hate to say, but funding is critical too, and you
19 have to do so much with a certain X-number of dollars and
20 you are sort of limited to what you can do in lots of cases.
21 VOICE: Don Swann of D&E Engineering. What will
22 latex paint do when applied to that test patch that you have?
23 MR. MIRICK: Latex paint, quote a lot of these
24 encapsulants you could also classify as latex paints. What
25 we are talking about is a sealing paint or a wall paint
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1 formulated for interior work. If you put these on the friable
2 test matrix, in 99 percent of the cases that I have seen
3 you will not get a continuous film. They are not made for
4 that tye of rough textured substrate.
5 Besides, they have poor impact resistance. They
6 are low in resin content and pigmentation.
7 VOICE: I have probably looked at a couple
8 thousand of schools, and I have gone back to contact numerous
9 amounts of them and I have found out that a lot of them are
10 going ahead and painting their ceilings. It has been an
11 irritation to me because I am required to go through all
12 the procedures and basically keep quiet about the schools
13 that choose to apply latex paints.
14 MR. MIRICK: I don't think that latex paints over
15 any friable matrix is going to do a good job.
16 VOICE: How much will that impede the penetration
17 of the sealings?
18 MR. MIRICK: It will do a tremendous job of impeding
19 them. You now have a surface that may be 80, 90 percent
20 covered. You have only little pin holes or little areas
2i for the other material to get in.
22 VOICE: Is EPA going to issue anything to the school
23 systems that they have contacted with these dockets that
24 they should not, and is it in any violation of any federal
25 law?
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1 MR. MIRICK: I don't know if it is in any violation.
2 VOICE: We were talking about latex paints. I
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have looked at a lot of schools, and they know what they
apply latex paints. This gentleman said, yes, it will impede
them and basically tell them not to apply latex paint on
the basis of this man's recommendations or information that,
yes, it is not going to last?
MR. DORSEY: We have been providing the best
technical information we have on sealants and paint. We
have many questions about latex paints. We recommend if
they do have a problem, if it is a friable material and there
is a problem, that they test whatever material they are going
to use and we have not recommended latex paints.
The only case where they have been used and we
have a comment to that effect is areas where it is not a
major problem. By major problem, highly friable.
It may be a granular surface. Many of the hotels
around the country have this material and you see where they
have painted over many times. You are going to have a problem
in the future, but we will not recommend a specific compound
or a specific encapsulant or sealant to anyone.
We provide these tests. I think Bill also should
state that when he started this program, what had happened,
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he contacted most of the major manufacturers and said that
2 we are checing on materials that might be used to encapsulate
3 asbestos containing maerials.
If you have something, send it in and we are going
to begin tests. This matrix that was developed, it wasn't
done previously.
Bill learned a great deal from this progrma. Basically,
8 these were formulations that were probably on the shelf and
9 were sent in to be tests.
10 GEnerally, we are not recommending latex paints
11 or anything. The tests that have run probably are just a
12 start, preliminary tests. One of the things we hope to derive
13 from this conference is share with you your knowledge. We
14 should be in probably the second or third type of paints
15 and coatings and sealants that are being used now.
16 We are only testing water based compounds, primarily
17 because of the determined toxicity problems with other compunds
18 Maybe latex paint should be tested more. I don't know --
19 VOICE: It is not that I want to use them, it is
20 just I see evidence of numerous school systems doing it.
2i MR. DORSEY: I share your concern. Many school
22 systems are spending a great deal of money buying latex paints
23 and maybe other compounds that haven't been tested and it
24 is costing a lot of money and they have not solved their
25 asbestos problem or maybe they didn't have a problem that
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1 warranted that in the first place.
2 VOICE: I go into a public bid situation. I find
3 I am bidding against a painting contractor who is basically
4 going to get hold of one of these materials and apply it
5 like they would apply latex paint without any of the procedure
6 outlined in your dockets.
7 VOICE: I think the problem is not too much its
8 strength factor, because there are many latex paints that
9 will demonstrate the qualities we are looking for. THe big
10 element that demonstrates the weaknesses, the latex paint
11 being put on a substrate that withdraws the acqueous phase
12 by capillary action.
13 The paint will not coalesce properly to give a
14 balance of properties necessary to effect the given results.
15 If it doesn't coalesce properly, and these were withdrawn
16 very rapidly by highly porous or observant materials, the
17 effectiveness of the paint is thereby reduced to that extent.
18 Since there are so many variables involved over many thousands
19 of x-ray detraction analyses, we have yet to find one similar
20 to another in quality or quantity of materials being used.
21 MR. MIRICK: I have to agree with you on the latex
22 paints. That is one of the problems, they do not coalesce,
23 the moisture is drawn out. It may not make a continuous
24 film because of that.
25 VOICE: I have a comment sort of related to this
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gentleman's comment about the inappropriate types of materials
2 that he has found used in school buildings. I am
3 Norma Scholneck with Essex Chemical Corporation.
4 First of all, I wanted to ask, relevant to the
identification program Mr. Dorsey alluded to at the beginning,
we didn't have an opportunity for questions then, are you
going to be considering providing some sort of guidance in
this identification program? You said no corrective action
9 would be required, only an indication.
10 Will there be some sort of guidance in terms of
11 planning towards a corrective action stage and has EPA conside
12 the possibility of providing guidance in terms of choice
13 of appropriate versus inappropriate materials?
14 I know you have a guidance document out, but you
15 know, when something doesn't appear in the Federal Register
16 or doesn't appear as an official type of document, it doesn't
17 have the stamp that carries with it a certain amount of weight
18 from a legal standpoint.
19 I just wondered if EPA is thinking in that direction
20 because obviously there are many circumstances that we are
21 all aware of where inappropriate methods, cheap materials
22 have been used.
23 Responsible manufacturers, I am sure many of them
24 are represented here, are quite aware of the fact that there
25 are people who will outbid them because they have
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1 irresponsible methods and marketing practices and scare tactic
2 and who will not investigate a test properly.
3 Is EPA going to make recommendations about looking
4 into appropriate versus Inappropriate?
5 MR. DORSEY: If I can remember your questions,
6 the answers are yes. Let me step back.
7 The identification and notification is needed now
8 because we know this asbestos material is being disturbed.
9 We know that people are disturbing it and don't realize they
1° are dealing with asbestos.
H They are creating exposure problems. The abatement
12 rule that was planned, we backed off because we don't have
13 a standard whereby we can tell somebody they have to remove
14 the asbestos or that corrective action is required. We have
15 developed now this algorithm that is going through changes
16 and further testing.
17 We have major programs on the way now in developing
18 the exposure assessment system. There is a program with
19 the Houston schools, a long-term program, EM, a very expensive
20 program. It is purely a research program at this point.
21 We are providing the best information we have, realizing
22 that it is basically research at this point.
23 The identification notification rule is necessary.
24 The guidance documents will be used. The regulations do
25 require that the person using or the person that will be
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surveying the school will be using the guidance documents.
We don't have a problem saying that this is the kind of material
that you survey for.
THis is the type of analysis you ask for. THis
is a list of labs that have successfully performed on our
round robin program. We don't have a problem there. We
can also provide the warnings.
We can take you to that point. The next point
as far as corrective action, it is difficult to go into a
building becaue you encounter difficulty, different situations
to say that may have to be encapsulated. Bill has learned
a great deal.
We have learned a great deal just testing these
various on the shelf products. We have discovered that there
is an indication that maybe the materials will respond to
different -- maybe the encapsulant will respond to different
types of materials.
It might be in response to the composition of the
material as far as the type of asbestos, maybe the types
of asbestos, maybe the filters that were used, et cetera.
So difficult for us at EPA to provide firm guidance other
than our recommendations and what we have assembled from
the experts.
I am sure people in this room have had more experien
with encapsulating agents that I have. I can tell you ;
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1 horror stories. We want to limit the use until people discover
2 how to use them properly.
3 If you use an encapsulating agent that appears
4 to be successful today, how long will that hold up?
5 VOICE: Is this going to be published in the Federal
6 Register and if so, is there going to be advance notice of
proposed rulemaking?
8 MR. DORSEY: The proposal was last September. This
9 would be the final rule.
10 VOICE: And it will be published in the Federal
11 Register?
12 MR. DORSEY: It is planned to be published in the
13 Federal Register. There are copies available. We are going
14 through for agency review now.
15 We have tried to widely distribute this regulation
16 for comments. If you have not seen a copy, you certainly
17 may get a copy now. It basically tracks with the first four
18 or five chapters of the guidance document.
19 VOICE: Was this the September 17th one?
20 MR. DORSEY: Yes. The only difference in the guidan
21 document, we use the term management system and by that we
22 mean that once you have identified asbestos in a building
23 from that forward you have to track what happens to that
24 material.
25 So you set up a file and a management system for
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that material. Does that answer your question?
2 VOICE: Yes. Thank you.
3 MR. MIRICK: Another part of the question, we are
4 also trying to work with the ASTM to determine standard tests
and procedures for evaluating various encapsulating materials.
This does not prove that when the manufacturer put them out,
because there are a lot of -- I have a problem with poor
8 quality paints that are on the market today, even though
9 they perform to ASTM standards, they are still poor quality
10 as far as I am concerned.
11 VOICE: One thing I want to say, both of you
12 gentlemen, you speak to the fact that you are providing guidan
13 and help and assistance through ASTM, you will provide further
14 guidance for people who contact you. What I am saying is
15 that there are a lot of people out there who are making decisions
16 about what they are going to do with their individual school
17 buildings who don't contact you, who don't look to the
18 guidelines.
19 Obviously if they looked to it you have tremendous
20 technical expertise available to offer to them, but what
2i about those who don't ask and make the wrong decision and
22 the consequences of their not asking?
23 MR. MIRICK: I don't know how to answer that.
24 How do you get the information out? When the program started
25 EPA had an asbestos coordinator in each region and they
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also trained engineers and architects to work with these
2 asbestos coordinators, to visit the schools tring to get
3 this information out.
4 I am not saying that they I think they have
5 done a good job in trying to do this, and each one of those
6 asbestos coordinators, by the way, went through a special
7 training program. Each one of the people working with
8 them went through a training program, so they had the knowledg
as up to date as we could get it and we tried to get the
10 information out.
VOICE: DER seemed to be taking on a certain
12 amount of workload. It has been disbanded. At least in
13 Pennsylvania.
14 They have done a lot of the qualitative
15 assessments in the school systems. I know for a fact that
16 in several of the states that the inquiries that came in
the back of thse EPA dockets are packed in boxes in the
lg administrative offices or former administrative offices
19 Of DER-
Q I had a few superintendents ask why they had
21 not been contacted by agencies that they had submitted
22 information to pertaining to their sealing.
23 MR. DORSEY: One of the rasons that we are developing
24 a regulation is because our voluntary program of providing
technical assistance has not worked in every situation.
25
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The impact I think has been tremendous, but we have not
2 hit every school.
3 I have been to many states. I have talked to --
4 Ican't begin to tell you the number of associations that
5 we have been involved with, just educating them to what
we have available to provide assistance if they want to
deal with their problem, but there are people making decisions
8 without the guidance documents, without contact with us
9 or anyone that had been involved.
10 In many states we have experts I think that have
11 provided just tremendous help and guidance in their respective
12 states. There are a number of states and local education
13 agencies withcLn other states that have not worked with
14 us. So I think through the program and contacts we have
15 developed a network of experts around the country that
16 are doing a good job, but we haven't hit every school.
If you know of districts operating without guidance
18 documents or without our help, if you would contact us
or a state person, we have ten regional offices listed
20 in the back of the guidance document, contact that person
21 and they will call the school and provide them with the
22 document.
23 We have an association of retired people where
24 we have individuals trained in the program and they can
25 travel to the districts. It is difficult to provide you
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1 with the best information for conducting an exposure docu-
2 ment.
3 Our difficulties are giving guidance on what
4 action should be taken if any. Fifty percent of the time
5 we say don't take any action. At this point you don't
"V
6 have to do anything.
7 Fifty percent of the time we try to encourage
8 people to remove the asbestos or encapsulate it or bury
9 it. It is difficult, because it is still a research
10 program.
11 VOICE: My name is Bill Russell with Pentagon
12 Plastics.
13 The first basic job was done in 1976. My question
14 is, the EPA has done a lot of testing, and it should have
15 somewhat guidelines themselves as far as materials and
16 it seems to me that a lot more time is being spent, time,
17 money and attention being given to develop new products
18 for asbestos for the encapsulation of it, rather than on
19 some new products, whether it be bridging or penetrating,
20 that have performed properly.
21 The money and the attention that we have spent
22 is looking for products, and very little time and attention
23 is being spent on what has worked and has proved successful.
24 I would like your opinion on that.
25 MR. MIRICK: I have a tendency to agree with
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1 you. There are some products that have been used and have
2 some pretty good track records. My program essentially
3 has been over since last September, and we are working
4 on the final report -- that has now gone through some revision
5 and things.
6 MR. DORSEY: I don't think if we have a research
7 program in the future that the emphasis will be on product
8 by product, and I don't think we have products that can
9 be used in every situation successfully. What we are
10 attempting to do, the emphasis in the next phase, I hope,
11 and that will be another part of our discussion, what we
12 would like to do is develop two sets of protocols. One
13 set is for you if you have a product that you can go out
14 to a standard testing lab, have these series of tests run,
15 basically the tests that Bill has conducted to date on
16 the various products, if they perform satisfactorily submit
17 the data.
18 The second protocol will be an actual test patch
19 on the actual substrate and develop protocols for that.
20 Because what we are finding is that there is an indication
21 that the various materials out there that have to be
22 encapsulated, that the encapsulating agent is responding
23 differently to the products.
24 You don't know until you actually apply it to
25 the substrate that you are attempting to encapsulate.
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1 The emphasis will be on trying to find something that works,
2 providing the best information to school boards and
3 administrators so they can make a decision. It may be
4 a new product.
5 We are not in that business. At EPA we are not
6 in the business or promoting or testing products, per se.
7 This contract with Bill was actually an attempt to develop
8 various tests for these potential encapsulating agents and
9 when the contract went out, Bill called the various
10 manufacturers attempting to identify potential encapsulating
11 agents, but we are not in the business of testing various
12 products or promoting products.
13 We are trying to provide some guidelines and
14 assistance to the school board member or the school
15 district to make a decision on what is the appropriate
16 method.
17 It is trying to develop techniques and information
18 to get to the school board.
19 VOICE: This is why in many cases a lot of latex
20 paint has been used, because there is -nobody, nobody _
21 of -- no committee to say yes or no, and we have had suade
22 shoe salesmen or whatever it may be to go in and try to
23 encapsulate something that has no fiber at all, and there
24 has to be a form of body to help the public to say yes
25 or no or maybe.
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1 MR. DORSET: We are working with ASTM. I think
2 that would be the appropriate group to develop those guide-
3 lines. It might be easier if we found that there were
4 products that were successful in every case.
5 We haven't found that. We are trying to provide
6 information so that schools don't lose their monty working
7 with what we say is a non-problem. But it is difficult.
8 VOICE: Mr. Dorsey, may I ask a question?
9 Unfortunately, this information is not disseminating down
10 to the people that have the problem. Essentially, anything
11 I have in the last ten years, but since Mr. Mirick's
12 Battelle tests came out, the responses generally were,
13 is this approved by EPA or Battelle. They never read
14 the disclaimer.
15 i told many of these people that inquired about
16 this, that EPA doesn't guarantee anything. Correct me
17 if I am wrong in this.
18 MR. DORSEY: No. You are right.
19 VOICE: And I am sure Battelle Labos doesn't
20 guarantee. They are suggesting to people that we have
21 tested under this criteria and it is up to you to confirm
22 whether this is suitable to your situation, but
23 unfortunately, this is not being disseminated down. When
24 i mention to these clients, did you read EPA's disclaimer
25 in this, they say we never saw it.
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1 I think there should be more information put
2 down to the people at this level that there are no guarantees
3 on the part of EPA or Battelle as to the outcome, because
4 this has been already confirmed with Battelle?s materials
5 have been tested that had failed in the market place and
6 it is qualitative judgments that are with the people.
7 MR. DORSEY: I have to agree. We are attempting
8 to disseminate that information. We have the procedures
9 guidance documents plus Bill's reports, but they haven't
10 reached all the people they should. Everyday we write
11 to people and say you are not on an EPA list and we do
12 not have legal authority and we are not in the business
13 of certifying products.
14 It is a difficult situation. Anyone here that
15 knows of a situation where someone is saying this is an
16 EPA approved product, let me know. I will write the letters
17 to correct the situation.
18 People that are attempting to deal with their
19 asbestos problems in the schools need better information.
20 I agree with you there 100 percent. And we are attempting
2i to get that information to them.
22 I wish we had more definitive information to
23 say yes, in this case you can do it, in this case you
24 can't. All we can do now is make the disclaimer and
25 publish the research findings that we have.
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1 VOICE: You talked about how EPA's job is really
2 to disseminate all of this information down to the school
3 people, and it makes me wonder why EPA hasn't essentially
4 done away with the asbestos regional coordinator's position,
5 at least in our area.
6 MR. DORSEY: We have sponsored from the Office
7 of Toxic Substances for the last two and a half years one
8 person in each region to act as a coordinator for the
9 program. That function at this point is being transferred
1° to the enforcement office, because we are anticipating
11 that one regulation will be in place. It can be or could
12 not be.
13 VOICE: You realize how long it takes for us
14 to learn all the information that we have learned through
15 all of this, and all of a sudden we are faced with a new
16 i person, almost a technical community that has to retrain.
IV MR. DORSEY: In region IV, the latest information
18 is that Brown will probably be the enforcement type working
19 with you. In most of the other regions it is the same
20 person.
21 With our program we are training many different
22 people. The asbestos coordinators were the only people
23 trained. We were learning as we were disseminating the
24 information.
25 But I don't think it is the kind of program at
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this point that only one person in the region can work
with this. I want to put multiple people in a region,
as well as the state people.
VOICE: It seemed like it was winding down.
MR. DORSEY: In the EGPA region there will be
an enforcement group that will take over the function of
providing the technical information.
VOICE: Robert Roe, Commonwealth of Virginia.
I am an architect.
Your directives and guidelines seem to point
only to public schools. Are you concerned with anything
else, like nursing homes, hospitals, colleges, other public
places?
MR. DORSEY: When the program was announced,
the school program, we were actually petitioned by the
Environmental Defense Fund to respond to a specific problem
in just schools. In our survey we found more of this material
in school buidings than we did in any other type of building.
The information and guidance document is appropriate for
any building.
If we receive phone calls or someone solicits
help, we provide it. But the focus for the program has
been school buildings in the past.
VOICE: Your asbestos regional coordinator, is
he only connected with public schools?
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1 MR. DORSEY: No. He can provide the document
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to anyone that has an asbestos problem.
3 VOICE: There is one for Virginia?
4 MR. DORSEY: Region III has a coordinator,
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Pauline Levin, in Philadelphia.
VOICE: You say soon there will be not just guidelir
7 and proposed regulations and good ways of removing asbestos,
8 you said there will be a law soon?
9 MR. DORSEY: No. The regulation currently under
10 review at EPA, as it stands now, it requires just
11 identification of the material in the school buildings
12 and then a management system established so that it provides
13 warnings to the workers. It will not require any corrective
14 action.
15 VOICE: Do you know if there are any states that
16 are proposing legislation that will require the removal?
17 MR. DORSEY: Yes. Florida has an act. Hawaii
18 is initiating legislation. Most of the states that have
19 strong programs have not gone through their various legisla-
20 tures for laws. They are conducting a program through,
21 say, a health department, education group, et cetera.
22 VOICE: So states are concerned about the removing
23 and saying that they are initiating laws, but the federal
24 government is not; is that right?
25 MR. DORSEY: At this point, no.
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VOICE: Is that where the initial scare came
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from, the federal government?
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MR. DORSEY: No. This probem is not a new problem.
4
Since about -- let's see, the first paper was "77 that
was identifying the problem at Yale. Then at Mt. Sinai,
c
researchers there did a study of the New Jersey.,:schools and
7 published a report, that they surveyed schools in New Jersey
Q
and projected that ten percent of the schools contained
asbestos.
In a number of these schools the material was
deteriorating and it was a condition where some action
12
should be taken. That was in '78. We were petitioned
13
to regulate the problem and in our investigation we dis-
covered a number of school people were trying to correct
an asbestos problem without good information.
16 But you had states like Massachusetts that had
17
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surveyed their schools and removed the problem. Rhode
18 Island, also.
19 I hope that it hasn't been our posture to scare
20 anyone. In fact, what we have been trying to do in many
21 situations is calm people down so that they don't deal
22 with what we say are non-problems. Just because asbestos
is in a building does not mean you have a problem.
24 We have been working with the various states,
we have a contact in each state to provide whatever
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information they need to help them with their problems
and also conduct various aspects of the research program
3 to support the technical needs.
4 The research with sealants is one aspect.
5 VOICE: I personally feel that is a real problem,
6 and there are others that have used such phrases as what
are you trying to do, insure good health to everyone? Is
8 asbestos really a problem like that? . You can't insure
9 them against everything, every problem that is going to
10 attack them in their lifetime.
11 But I just wish that there would be some guidelines,
12 directives or laws to get rid of the problem, either from
13 the federal government or from the states.
14 MR. DORSEY: We are attempting to do that. You
15 have to identify where your problems are located before
16 you can correct them. The identification, notification
17 rule would do that. At this point, even if we were in
18 a position to write a rule today, there is some question
19 if we could have a standard or if we have the tools necessary
20 to identify all the problems or differentiate between the
21 materials to determine which ones have to be removed, which
22 ones can be encapsulated or enclosed, et cetera.
23 i don't have the answers. Within another year
24 we hope to be closer. There are various people speaking
25 at the conference today that are in the same type of business.
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It is a very difficult problem for us.
2 VOICE: The identification notification, that
3 is only going to be for public schools?
4 | MR. DORSEY: Public and private, yes.
5 VOICE: And that is a small percentage?
6 MR. DORSEY: Yes.
7 VOICE: Not too long ago, four very large municipal
8 buildings in a county closeby, in which we had contact
9 and we were talking with them, it was let to a pennies
10 per pound point contractor. We talked with him and asked
11 him to use our material or some other widely tested and
12 used material, why are you going this route? We know what
13 the guidelines are, we don't care. It is not law and we
14 will do basically what we please.
15 Being a participant in events in those municipal
16 buildings, I am not real thrilled about that.
17 MR. DORSEY: There is an OSHA regulation for
18 work with asbestos that has to be followed. We are
19 concerned about other buildings and we anticipate collecting
20 the data and information to determine you realize it
21 is very difficult on a national level to write regulations
22 that are appropriate throughout the country,and it requires
23 a great deal of information and data and the administrative
24 and legal process is quite lengthy.
25 We are looking at other buildings. We have a
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1
very, very small group of people working with us on the
2
school asbestos program. We are trying to tackle that
3
problem first.
4
As we develop better technical data and informa-
5
tion we will move to other buildings. The data and informa-
6
tion we have in the guidance documents are appropriate
7
for any building and provided to anyone on request, but
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
there is no law at this point.
I can't tell you what will happen in the public
sector as far as the problem for regulation. We don't
have informaticn on the range and scope of the problem or
the type of difficulties we will encounter there. We are
looking to see how many buildings contain the material,
but I don't have that information today. It is not that we
are not concerned.
VOICE: I would concur with this gentleman here
in asking for some teeth. We have just gotten voted down
twice in one of our schools for removal or encapsulation
of asbestos, which has been typified by our state department
of health as a serious problem. Basically when we go to
town meetings, what is said, well, nobody is going to do
anything, so why should we.
That and another comment on scare tactics. There
is at least one company in the United States that is sending
out brochures to school systems saying that you have got
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1 to get it out, the government says you have to get it out,
2 a $25,000 fine initially plus $25,000 a day for every day
3 it is in there, and the school administration is the liable
4 person.
5 MR. DORSEY: And on Friday I received that brochure
6 and I think that that brochure will no longer be distributed.
7 Those kinds of documents, that one particularly, I have
8 a number of problems with, and any information along those
9 lines that you see, if you will alert me to the fact, we
10 will contact the companies and the people involved and
11 try to stop that.
12 The regulatory process is so difficult, the
13 identification notification rule is at EPA now going through
14 for< review. It has basically been supported. I is not
15 a new proposal. For the last two and a half years we have
16 been working with the states.
17 Almost everyone that would be affected by the
18 regulations, the associations, the education groups, the
19 various state reps, local LEA's, have been involved in
20 that rulemaking.
21 It is possible in the future that we will have
22 an abatement rule, but the first step has to be a standard
23 whereby we can measure the problems out there and provide
24 some guidance. At this point it is really a research program
25 The algorithm was developed primarily by Sawyer at Yale.
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1 It has been emperically bested over the last
2 year. Chris Williams is with us, who developed a first
3 test in his state. We are providing better training in
4 the use of an algorithm, but it is still a difficult problem.
5 VOICE: I think you implied that there were conditions
6 where containment of asbestos would not require any action.
7 MR. DORSEY: Not warrant action at this time.
8 VOICE: What repercussions would this have to
9 insurance companies that take a contingent liability to
10 this, that they are somewhat hesitant to somebody referring
11 this as a result of that kind of a comment from EPA?
12 MR. DORSEY: That is a good question. I don't
13 have an answer for you.
14 VOICE: That could be frought with an awful lot
15 of probems on the part of the client.
16 MR. DORSEY: Right. We have a risk assessment
17 document which is available to anyone. We are saying a
18 certain number of materials obviously damaged, deteriorating,
19 highly friable, that something should be done about that
20 material. We are not saying that you have to contain all
21 the material there.
22 But the comments are made that sometime in the
23 future that has to be dealt with. We are not recommending
24 a containment action at this time because the building
25 isin good repair. Insurance purpose, I don't have an
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1 _
answer for you.
2
VOICE: In case somebody gets a related disease,
he is a law suit. Does that statement contain a force
4
of law? He can go into court and all you have to do is
mention that the person's debility was as a result of asbestos
f*
exposure in that area, the defense will say that the EPA
n
stated that it doesn't necessarily have to be reacted at
this particular point.
g
Since tha has no force of law to an extent, and
1 all you have to do is holler asbestos, it is like in a
movie theater hollering fire and everybody vacates the
12 place.
1 MR. DORSEY: Because people are going to overact,
14 and people are going to cause problems in the future doesn't
mean that we should not address the problem of asbestos
16 today.
17
VOICE: I am not saying that. You are follwoing
I Q
that routine accurately.
19 MR. DORSEY: The legal repercussions having been
20
difficult. We are saying that we are primarily concerned
if you are going to correct your asbestos that you follow
22
a guideline and you follow the OSHA regulations very strictly
00
because the workers have to be protected. You don't want
to contaminate the school or the environment.
As far as the identification notification rule,
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1 we want people to know where the material is located in
2 the school and warn their people not to disturb it.
3 VOICE: Where does EPA's jurisdiction stop, on
4 the outside or on the inside of a school? Is there a grey
5 line there?
6 MR:f DORSEY: There are a few lines, but primarily
7 because we have various acts under which we regulate. Under
8 the Clean Air Act, we can regulate any pollutant that would
9 contaminate the ambient environment, in some cases the
10 indoor air.
11 It is a general act that has to be applied to
12 a specific problem. Under the Toxic Substances Control
13 Act, the act under which we regulate, we are primarily
14 concerned with the specific problem, no matter where it
15 is located. So if it is a toxic substance and we identify
16 a problem that is manufacturing, distribution in commerce,
17 disposal, et cetera, we can regulate it.
18 But it could be that we will work in conjunction
19 with another regulation or under another act or maybe it
20 might be multiple regulations under various acts.
21 Could we take a break for about a half an hour?
22 (Recess.)
23 MR. REINHARDT: Before we get started with the
24 next speaker, I have a few announcements.
25 Mr. Lory will talk until 12:30 and we will
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1 reconvene at 2:30. There will be an opportunity this after-
2
noon for you to ask any questions of Mr. Dorsey and
Mr. Mirick that you didn't get a chance to this morning.
4 On the table outside, if you want to be put on a mailing
5 list for any EPA publications that have come out or will
6 come out in the future, please sign up out there.
7 I guess there are now proposed identification
8 and notification rules are out there and you can pick up
9 a copy of that if you like.
10 Also if you haven't yet signed in, the people
11 who are running the conference would appreciate it if you
12 could. I would like to introduce Mr. Ernest Lory, who
13 works at the United States Navy Civil Engineering Laboratory
14 in California.
15 He has been doing research with asbestos for about
16 six years and has, I guess, recently completed the program
17 which undertook to inspect all of the Navy's shore facilities
18 for friable asbestos-containing materials, and he is going
19 to talk about his research on asbestos friable insulating
20 material encapsulating agents.
21 MR. LORY: Good morning. I am glad to be here
22 in Washington again and I would like to bring you through
23 some technical information and other types of information
24 concerning friable insulating material as well as
25 encapsulating agents to bring us all up to about the same
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1 speed. I know some of you gentlemen and ladies are well
2 versed in encapsulating agents and others of you are on
3 the architectural side who understand buildings, but I
4 hope to bring everybody up to approximately the same speed.
5 In the past decade, there has been an increasing
6 awareness of the significance of environmental contamination
7 as a cause of disease, including cancer. The physical
8 characteristics of asbestos fibers and the widespread and
9 varied sources of friable insulation materials (FIM) containing
10 asbestos have caused concern for human exposure to asbestos
H in both occupational and non-occupational settings within
12 buildings containing such materials.
13 Hazard potential from asbestos exposure for the
14 population involved in these buildings is believed to be
15 significant. Because of the widespread use and the ease
16 of fiber dissemination, friable asbestos insulation material
17 and pipe insulation can be considered the most significant
18 sources of asbestos fibers in the indoor environment.
19 Asbestos-insulating material has been applied
20 to ceilings and walls are found in widely differeng building
21 types -- large offices, schools, gymnasiums, swimming pools,
22 industrial facilities, and machine shops.
23 Recognition of potential health hazards from
24 exposure to asbestos fibers have prompted OSHA, EPA, and
25 other federal agencies to enact regulations for maximum
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1 exposure levels to asbestos fibers to protect the public,
tradespeople, and environment.
3 The friable asbestos abatement program four
4 years ago the U.S. Navy undertook a program to survey all
5 of its shore facilities in CONUS in the 50 states. This
6 involved about 22,000 buildings. We first tried to define
7 the problem by surveying the buildings, locating the materials
8 and sampling it.
9 Then we went into an assessment program of the
10 risk evaluation. This is conducted by architects and engineer
11 Then we go into an evaluation of what type of alternative
12 corrective measures can be taken, and from there the Navy
13 is going to have a program to abate the hazard potentials.
14 Often today you will also see the letters SAI. That was
15 a previous nomenclature which we used in the Navy for Spray-
16 applied Insulation. So you will see that off and on today
17 but it means the same thing as FIM.
18 SAI is defined as any insulation that can be
19 crumbled, pulverized, or reduced to powder in the hand.
20 FIM can be collected by scraping or boring a plastic sampler
21 into or across the surface of the material.
22 Ease of sampling constitutes a measure of the
23 friability of the material in question. FIM, potentially
24 containing asbestos, is separated into three general cate-
25 gories: fibrous insulation, granular/cementitious insulation,
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1 and insulating/fireproofing concrete. FIM of nearly identical
2 appearance and composition may contain vermiculite, rockwool,
3 or fibrous glass may contain up to 100 percent asbestos
4 or no asbestos. The thickness of most FIM commonly varies
5 from 0.25 cm about one-eighth of an inch -- to over
5.0 cm about two inches.
7 TYpical fibrous FIM may contain asbestos also
8 called asbestiform -- fibers. Tamped finishes are normally
9 encountered where the FIM is in view. Untamped fibrous
10 FIM is found in areas of limited access -- boiler rooms,
penthouses -- and is normally out of view.
12 Granular/cementitious -- this type of FIM has
13 a coarse sand appearance and has been used for sound absorpticjn
14 as well as for decorative purposes. Granular, cementitious
15 material may be easily removed from the surface by very
16 little mechanical disturbance wiping with the hand.
17 Insulating/fireproofing concrete -- I know that
18 at times there is a distinction that the Navy uses in this
19 third category versus the EPA, which not necessarily uses
20 this third category negotiation, but the insulating/fireproofi ig
21 concrete, this type of FIM has a foamy appearance with
22 a strong possibility of containing vermiculite or mica.
23 Insulating concrete may be soft and spongy to hand pressure
24 or may require use of a mechanical device to penetrate
25 the material surface.
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1
Insulating concrete is traditionally applied
2
to steel members of high rise structures. This type of
3
FIM is normally hidden from view, but may still cause fiber
4
release to respirable air.
5
Components of FIM. At the end of World War II,
6
asbestos fibers were in short supply, so manufacturers
7
looked for combinations of other fibrous materials to obtain
8
the same end result.
9
During this time, mineral wool in combination
10
with asbestos and nonflammable binders was introduced.
11
This is a rock of asbestos fibers showing how they are
12
in appearance.
13
Products, however, still contained between 20
14
percent and 30 percent asbestos, usually of the chrysotile
15
group. Up until the restrictions of the law by EPA.
16
Materials replacing asbestos fibers in spraybel
17
products are mineral wool and vermiculite.
18
Mineral wool is a generic term which includes
19
fibrous glass, rock wools, and slag wool. Rockwool is
20
made from basalt which is melted and then spun; it has
21
a higher temperature resistance but is more expensive to
22
produce than slag wool.
23
Slag wool is spun from disposed iron slag after
24
melting. Rock and slag wools have some of the properties
25
of chrysotile asbestos fibers but generally lack the high
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1 degree of flexibility and strength of chrysotile fibers.
2 Fibrous glass comes from a process of melting and fiberizing
3 sand.
4 Vermiculite is an expanded exfoliate of any number
5 of hydrous silicates and comes in short pellet form.
6 Manufacturers depend more on the binder in the FIM material
7 to hold the insulation together and in place than on the
8 vermiculite ingredient. Due to the natural low fiber content
9 of hydrous silicates, a low asbestos fiber content is found
10 in vermiculite mixes.
11 FIM binding agents were not standardized either;
12 organic -- resins, glue, flour -- and inorganic agents
13 sodium silicate, portland cement, bentonite clay -- were
14 mixed in various combinations to obtain the desired adhesive
15 properties.
16 Bulk Material Analysis. The petrographic microscope
17 a transmitted polarized light microscope (PLM) instrument
18 with dispersion staining, is widely used for identification
19 and characterization of crystalline substances by their
20 optical and crystallographic properties.
21 As shown in the slide on the right hand side,
22 the same fiber rotated 90 degrees changes color. This
23 color change is used to identify asbestos fibers. This
24 technique was used by the Navy to identify the bulk material
25 samples that were sent to CEL.
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1 X-ray techniques are used on small samples of
2 suspect material, and a pattern fingerprinting uniquely
3 characteristic of any crystalline materials present is
4 produced. This method was used for quality control checks
5 on PLM analysis.
6 Bulk material analysis results shown on the follow!
7 slides indicate wide disruption of fiber concentration,
8 type of asbestos fibers, as well as other bulk material
9 identified in the samples.
10 In this slide we see crystotile. These percentages
11 represent about 200 different analyses. To read through
12 the slide a little bit, fibrous, where we hae this crystotile
13 fiber alone was in 22 percent of our samples. The mixture
14 is a mixture of crystotile and amosite in two percent.
15 The five percent of the fibrous looking material contain
16 crystotile and fibrous glass and three percent contained
17 crystotile and cellulose.
18 Granular/cementitious, 22 percent, crystotile
19 as the major fiber material. Amosite and crystotile is
20 found in one percent and two percent of the fibrous glass
21 crystotile and the granular/cementitious.
22 Insulting, fire proofing, 17 percent was just
23 straight crystotile and in the mixture of fibrous glass
24 and crystotile, it is one percent.
25 This data does not show what our cellulose only
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1 products would be, our mineral wool only products would
2 be. This is just strictly the products in which we found
3 asbestos fibers present in the bulk material. This is
4 the amosite and crocidolite FIM. Again, where it says
5 amosite, fibrous, it is the only amosite present in the
6 bulk material, 11 percent. Three percent is the mixture
7 where amosite was the predominant fiber and the chrysotile
8 was the minor percentage.
9 And fibrous glass, amosite was in three percent
10 of the fibrous material. Granular/cementitious, three
11 percent amosite. Crocidolite, we found it in one percent.
12 In those samples, the crocidolite was probably somewhere
13 around 90 to 95 percent of the fiber content and the bulk
14 material.
15 Selection of the appropriate corrective alternative
16 should reach the most efficient long-term solution after
17 material condition,location, function, and cost are considered
18 Each building area which contains FIM must be considered
19 separately in risk evaluation and abatement. The importance
20 and magnitude of proper assessment of alternatives for
21 deficiency abatement cannot be stressed strongly enough.
22 In selecting a corrective method, personel should
23 determine if the situation requires entire removal of
24 asbestos materials to eliminate exposure or merely control
25 of exposure by containment methods. Enclosure and
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1 encapsulation are containment methods that only prevent
2 exposure to the sprayed material but do not eliminate the
3 contamination source.
4 The time between the long-term corrective action
5 such as removal, enclosure or encapsulation, interim control
6 measures should be established. An interim control program
7 should include as a minimum the following elements.
8 One. Educational media system to inform the
9 occupants of the building about the potential health risk.
10 Two. Flagging system for building maintenance
11 file. This alerts the contract writer and trouble call
12 scheduler so they may properly inform bidder or shop personnel
13 of the asbestos hazard in that building.
14 Three. Periodic inspection and air monitoring
15 schedule for detecting any changes in the condition of
16 the remaining asbestos FIM.
17 Four. Maintenance work procedures for various
18 trades. This effort will be to establish methods to protect
19 the worker and occupants of the building and prevent excess
20 release of fibers from the FIM.
21 Five. Proper custodial dust control procedures
22 should be established.
23 I know this is not what we are talking about
24 today, but I wanted to go over these two other methods
25 of long-term control.
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1 Removal. Asbestos removal provides a long-term
2 solution by elimination of the contaminant source. Removal,
3 however, requires renovation involving friable asbestos
4 material, with significant problems of worker protection,
5 considerable interruption of building activities, and possible
6 replacement with asbestos-free insulation.
7 Removal of sprayed material is recommended when
8 any one of the following conditions is present:
9 One, the material is friable and significantly
10 deteriorated or damaged.
11 Two, the material is accessible and potentially
12 subject to damage by vandalism or activities in the space.
13 Three, the material will be damaged during routine
14 maintenance activities.
15 Enclosure. Enclosure of a sprayed asbestos surface
16 places an impervious barrier between asbestos-containing
17 materials and areas of occupancy. Attached lath systems
18 or a framework with gypsum board are usually employed.
19 Depending upon the integrity and type of barrier systems,
20 dissemination of fibers by fallout will take place behind
21 the barrier only, and exposure outside the barrier will
22 be greatly reduced. Entry into these enclosure areas
23 requires personnel protection and fiber containment pre-
24 cautions.
25 Enclosure systems can be employed, similar to
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l a wainscoting, to contain FIM on the lower nine feet. All
2 utilities, where possible, should be removed and rerouted
3 from the enclosure space; when feasible, no access should
4 be built to this space. The space behind a barrier system
5 must not connect with the air plenum, and air from the
6 enclosed space must not circulate within the occupied buildinc
7 Enclosure of asbestos-containing material can
8 be used, provided that the material is not potentially
9 subject to:
10 One, frequent damage during routine maintenance
11 activities;
12 Two, water damage;
13 Three, condensation buildup.
14 And the one that we are discussing today and
15 tomorrow is encapsulation, and this is another method of
16 containing the friable asbestos insulating materials.
17 To control potential asbestos exposure in rooms,
18 encapsulating agents are being applied. Encapsulation
19 of sprayed asbestos surfaces involves applying material
20 that will envelop or coat the fiber matrix, restricting
2i the release of fibers, and afford minimal protection against
22 contact disturbance. Encapsulants consist of polymers
23 with an agent added to enhance penetration into the fiber
24 matrix.
25 Integrity of an encapsulated surface depends
c,
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1 upon bonding between asbestos material and supporting structural
2 members and internal cohesion of FIM. A sprayed asbestos
3 ceiling for example, with initially poor adhesion to a
4 smooth surface will result in shearing exfoliation --
5 and failure of the full thickness of sprayed material and
6 the applied sealant.
7 Desirable FIM properties. These are various
8 categoris of FIM or SAI damage that you should be aware
9 of when you are considering encapsulation. Number one
10 is water damage. This light brown area is where there
11 has been some roof leaks and leeting water penetrate through
12 the roof and damaging the friable insulating material.
13 Deterioration, just due to the age or not adhering
14 well to the structural members such as the steel column.
15 The asbestos is exfoliating.
16 Deterioration and vibration has caused release
17 of FIM from this structure. Accidental damage this
18 is caused by maintenance people who were talking on these
19 catwalks and as they were carrying their equipment or tools
20 and things like that, they have rubbed up against this
21 asbestos-containing insulating material.
22 Vandalism. In remodeling, there is potential
23 significant damage occurring to FIM. In this case, we
24 have two different types of remodeling that have caused
25 FIM to be removed from the steel structure. One is when
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1 an electrical conduit was put in place the electrician
2 just scraped away the FIM, and also when they installed
3 a T bar grid for a suspended ceiling, again, the FIM was
4 scraped.
5 Use of sealants is governed by the characteristics
6 of the FIM surface.
7 All structural materials used in building construction
8 are adversely affected by elevate.d... temperatures. Mechanical
9 properties, such as tensile and compressive strength, stiffnes
10 and ductility, deteriorate with an increase in temperature.
11 Although steel, whether used in a structural frame or as
12 reinforcement in concrete, is noncombustible, it loses
13 strength when exposed to fire. Because it loses its strength
14 at high temperatures, steel must be protected by a fire-
15 proofing material.
16 Thermal insulation).' FIM, when applied as thermal
17 insulation, retards the flow of hat energy by restricting
18 the conductive, convective, and radiative transfer mechanism
19 of the material. The ability of a material to retard the
20 flow of heat is determined by measuring thermal conductivity
21 or heat conductance.
22 TO be of value, thermal insulation materials
23 must have low thermal conductivity or high thermal resistivity,
24 Acoustical control. One of the widest uses of
25 FIM in architectural applications is in control of sound.
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1 FIM has excellent properties for architectural applications
2 because of its lack of reverberant surfaces.
3 Although the characteristics of sound energy
4 absorption depend on the density of sprayable materials,
5 the efficiency generally improves with an incrase in the
6 applied thickness of the FIM material. Since the sprayable
7 product is generally applied to hard surfaces with no airspac
8 behind them, all sound energy must be dissipated within
9 the acoustical control material.
10 Chemistry and technology of encapsulants.
11 Encapsulant Components. Encapsulatns have three basis
12 component parts: the volatile vehicle -- solvent, the
13 nonvolatile vehicle resin -- and the pigment.
14 The desirable FIM properties that should be conside
15 when selecting encapsulation of FIM, will these properties
16 change due to the agent application? We do not know that
17 yet.
18 These are some of the areas that are being investi-
19 gated.
20 The pigment is the only solid material in the
21 coating. The resin component is dissolved in the solvent
22 so that the finely ground pigment dispersed in the mixed
23 vehicle is the only solid material present in the coating.
24 The solvent evaporates into the atmosphere as the coating
25 cures so that none of it remains in the cured film.
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The resin -- sometimes called binder -- is composed
2
of two or more polymers or prepolymers that form a continuous
o
film upon curing of the coating and coatings are classified
generically by the type of resins used in their formulations.
The primary pigments used in coatings are opaque
f*
and, thus, impart hiding as well as color. Because titanium
7 dioxide has more opacity than other primary pigments, it
is used extensively in both white and colored coatings.
Q
Secondary pigments include, one, fillers, such
as talc, to regulate flow, brushability, et cetera; two,
11 fibers to impart reinforcement in the encapsulating agent;
12 three, flakes to reduce water permeability or impart abrasion
resistance.
14 Other materials,, such as driers, plasticizers,
15 ultra-violet light absorbers, and emulsifiers, are added
16 to coatings to impart special properties. For laboratory
17 purposes, they are considered to be part of the resin or
18 pigment, depending upon their solubility.
19 While all solvent is lost upon curing of the
20 coating, the proportions of resin and pigment remain the
21 same. The extent of pigmentation -- particularly opaque
22 pigment is inversely related to coating gloss. Thus,
23 much more pigment is exposed in low gloss -- flat -- than
24 in high gloss coating surfaces. Except for gloss, color,
25 and texture, almost all the important properties of a
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1 coating are determined by the properties of the resin.
2 As shown in this slide, when there is a high
3 percentage of pigment there is a lot of pigment granules
4 showing here, wherein a low pigment, a high resin content,
5 you hae more binding power of the encapsulating agent.
6 Encapsulating agent categories -- the generalized
7 properties relating to chemistry here are the ones which
8 | we are concerned with, particularly in the encapsulation
9 of FIM are one, the performance and different substrate,
10 two, the compatibility with other coatings, three, flexibility
11 and toughness.
12 Asbestos control. With the EPA study and Bill
13 Mirick's work, they were investigating various properties
14 of the encapsulating agent, which Bill Mirick has presented
15 this mornng already.
16 in addition, the ASTM subcommittee is looking
17 at standards to determine friability. This is one of the
18 big questions that has come up. A very muscular person
19 can take even a rock and crush it and say it pulverizes
20 in myhand, where somebody else it would take a tremendous
21 amount of pressure, and so the standardization for
22 friability has not been set, so the ASTM subcommittees
23 are trying to work on that.
24 The asbestos material classification system is
25 being worked on, the cohesion/adhesion. Fire rating is
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1 being looked at. When you apply an encapsulating agent
2 does your fire rating of the material, is it reduced, and
3 then it comes into insurance problems and things like that.
This is being addressed currently. And the question about
bridging versus penetrating materials is being addressed.
So these are being looked at by various experts
in a meeting of the minds on these various subjects.
As Bill Mirick mentioned this morning, encapsulants
9 are divided into two categories, the penetrating type and
10 the bridging type.in which the penetrating agent exhibits
11 improved cohesive strength and impact resistance, potentially
12 through a certain depth of the FIM matrix where the bridging
13 forms a membrane over the surface of the FIM.
14 In various articles and literature manufacturers
15 stated that their product can produce a membrane over the
16 surfaces while others stated that their substance can extend
17 one or two inches into the FIM and bind the product to
18 steel or concrete.
19 The Civil Engineering Laboratory, in conjunction
20 with the U.S. Postal Service and EPA Regional Offices,
21 has conducted a few field tests of several encapsulating
22 agents on the same asbestos FIM. The following slides
23 are Scanning Electron Microscope SEM -- micrographs
24 showing top surface and cross-sectional surfaces of FIM
25 encapsulated with different encapsulating agents.
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I am not going to be using any commercial names,
2
so please don't ask for them. In this encapsulating agent,
q
it was classified or it should be classified as a bridging
4
material.
This is a surface of a FIM material which contained
/?
probably 40 percent chrysotile. It is a 30 magnification.
The holes such as this one here is 100 micrometers in width,
8
which is about equivalent to 4 mils. And as most of you
9
10
11
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realize, the respirable fiber size or the type that are
of concern are proably from about 0.1 micrometers all the
way to somewhere around 30 micrometers.
I am not positive on those numbers, so don't
quote me. This is a cross section of the same material.
The one on the left-hand side is a 30 magnification and
the one on the right hand side is a 500 magnification,
showing the inner section between the encapsulated material
and the non-encapsulated material and this is basically
right in this area here.
(Slide.)
MR. LORY: This is another bridging agent, and
again we have some holes in this continuous membrane, which
is approximately 100 micrometers or 4 mils, and this is
on tfenon-asbestos test material.
(Slide.)
MR. LORY: This is a cross section of the same
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1 bridging agent, with a 30 magnification, and again, 500
2 magnification, showing the area between the encapsulant
3 and the material that is not bound by an encapsulating
4 agent.
5 This 500 magnification is of this area right
6 here. This is the same product which I just talked about,
7 a bridging agent, being applied to an asbestos FIM, and
8 this is a 15 percent chrysotile asbestos matrix. We have
9 a 30 magnification and a 100 magnification.
10 One of the things that we are trying to look
11 at in this cursory investigation is do_ we see fibers in
12 these holes that are not encapsulated or have any binding
13 agent on them.
14 And it is inconclusive, I will let you know now.
15 But it is something to be aware of.
!6 (Slide.)
17 MR. LORY: This is a cross section of the same
18 briding agent on the FIM containing asbestos. Again, the
19 briding agent penetrated only a short distance into the
20 matrix, and it is binding the very top layer of asbestos
21 fibers together, but it is not going to any great depth,
22 and this is, of course, why it is called a bridging agent.
23 (Slide.)
24 MR. LORY: This is a penetrating agent. Again,
25 we are looking at a surface in which vie have a 100
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1 magnification and a 500 magnification. Again, we were
2 trying to look into the fiber matrix to see if we see any
3 fibers that are not coated with the penetrating agent.
4 And again, it was inconclusive.
5 We have to do additional work in this area.
6 (Slide.)
7 MR. LORY: With this same maerial as we just
8 looked at, we looked at again a cross section of it, and
9 we made little sections, as you can see here, and we will
10 be looking at each one of these sections in depth at a
11 greater magnification.
12 . This is a 30 magnification, this is 100 magnifi-
13 cation. Again, this is a penetrating agent. Again, the
14 top surface looks fiarly well bound together, but as we
15 start to go deeper into the material, we are finding pockets
16 of areas that are not encapsulated, and we are talking
17 about this area right in here.
18 (Slide.)
19 MR. LORY: Again, we are finding pockets un-
20 encapsulated, but every once in a while we find areas in
21 which the penetrating agent was able to come down a strand
22 or something and encapsulate certain areas of the FIM.
23 So, in other words, we do not have a continuous
24 agent from the surface of the asbestos FIM all the way
25 to the structural member.
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1 (Slide.)
2 MR. LORY: This is the same agent that we just
3 looked at in cross section -- the other material is a non-
4 asbestos material. I am sorry if I used the word asbestos
5 on that. But this is the same agent that was used on a
6 15 percent chrysotile mixture.
7 Again, we have a ten magnification blow-up and
8 we have a 30 magnification. Again, we appear to have fibers
9 that are not being tied very well to the fiber matrix.
10 We can't absolutely identify them, but we are looking at
11 them.
12 (Slide.)
13 MR. LORY: This is a cross section of the same
14 material that we have looked at in the last six or seven
15 slides. Again, we have a tremendous number of asbestos
16 fibers that are not coated or enveloped with an encapsulating
17 agent.
18 We have some good penetration in this area, but
19 we have a lot of material that is not being bound by any
20 agent.
21 (Slide.)
22 MR. LORY: This is a different encapsulating
23 agent and it is also a penetrating type, a 30 magnification,
24 and, again, 100 magnification. Again, we have tried to
25 look into these holes and see if we found any fibers that
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1 were loose.
2 Again, nothing conclusive. I am saying this
3 time and time again, but we have looked at other SCM micro-
4 graphs and we have found fibers that were quite loose in
5 these holes, showing that the agents were not binding the
6 fibers even right on the surface if the holes were big
7 enough.
8 (Slide.)
9 MR. LORY: This is the same material that I just
10 mentioned in the last two slides, with a cross section
11 here of ten magnification and over here a 30 magnification.
12 Again, we see the encapsulating agent penetrating to a
13 certain depth, and this is blow-up. We get some strands
14 that are coated.
15 We find other strands that are not bound by agents -
16 pardon me fibers that are not bound by agents.
17 (Slide.)
18 MR. LORY: This is another produce of a penetrating
19 classification. We have a 30 magnification and 100 magni-
20 fication.
21 This slide is this area right in front of you.
22 (Slide.)
23 MR. LORY: And this is a cross sectional view
24 of that view we just looked at. This is a ten magnification
25 and over here we have a 30 magnification. You see that
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in the top area right over here.
Again, we are finding some fibers that are not
coated very well.
(Slide.)
MR. LORY: This demonstrates this quite well.
(Slide.)
MR. LORY: But at times we find pockets --
VOICE: What is the binder of the material?
MR. LORY: I do not have a binder composition
of the asbestos materials. We have tried to identify organic
versus inorganic binders of the FIM, but we have not made
anything thus far.
VOICE: Do you have any ball park figure as far
as percentage?
MR. LORY: On this material here it is 15 percent
chrysotile, and I don't have the rest of the makeup of
the material.
VOICE: On the left hand slide, what are the
white areas?
MR. LORY: You are going to have to appreciate
that SEM -- there is quite an art to be able to get a
good coating of gold on the asbestos materials, and you
will get some bright areas. Jim Hubbard may be able to
address that better, but I cannot presently identify this
bright area as being all encapsulant.
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1 VOICE: You made the statement that it is obvious
2 that some are coated and some uncoated. To us sitting
3 here it is not obvious, I don't think.
4 MR. LORY: What we are looking at, over here
5 you can see that some of the fibers are not -- you see
6 this fiber here, you can see a very definite shape to it.
7 But when we have encapsulating agent or a binding agent --
8 pardon me the shape of the fiber changes due to the
9 coating of the materials. And this was one of the areas
10 | that we were wanting to do more extensive work on, is
11 to put a tag into the encapsulating agent in which we can
12 identify through x-ray analysis.
13 In other words, the gallon or five gallons of
l4 encapsulating agent, we will add something else to it so
15 it can be readily picked up by other systems as we are
16 looking at it and we can detect where the resin stopped
17 its penetration and where the asbestos fibers are.
18 As I said, this is just a cursory survey of
19 encapsulating material. I don't want to make any conclusions.
20 I am just presenting them.
21 VOICE: Were thse taken from jobs actually done
22 or are they samples you prepared?
23 MR. LORY: No. When I talk about 15 percent
24 chrysotile, this is actually in a structure in which we
25 used five different encapsulating agents, the same asbestos
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material, using five different encapsulating agents, and
2 these are the series we are going through now.
3 VOICE: Actual job situations?
4 MR. LORY: Actual job situations in which the
5 contractor bought five gallon containers of four of the
6 encapsulating agents and enough agents to finish off the
7 building.
8 VOICE: Were they done as part of a contract
9 or under controlled conditions or how were they done?
10 MR. LORY: The control is that the contractor
11 applied the material as directed by the manufacturer. The
12 only control we had was that the material was all the same.
13 It was the same contractor doing the same application as
14 a contractor would normally apply, using the specifications
15 in which the sealant manufacturer recommended -- let's
16 see if I forget anything -- but basically we did not try
17 to create a laboratory condition.
18 The only condition we had was that we used five
19 different encapsulating agents.
20 VOICE: Was he being observed or monitored? How
21 closely was this whole operation being
22 MR. LORY: The contractor we did not have
23 a paint inspector present during the application, and the
24 only the criterion under which the contract was written
25 was that he apply the encapsulating agent through the
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1 specifications or the recommendation of the manufacturer,
2 so we were trying to do it as to what we normally find
3 out in the field. Nothing special except five different
4 agents.
5 VOICE: What criteria was used in selecting of
6 materials and how was this disseminated down to prospective
7 manufacturers to be entertained in this purpose? Is this
8 the one that was conducted at the post office on the West
9 Coast?
10 MR. LORY: Yes, it was.
11 VOICE: How this disseminated out to responsible
12 contractors that could participate in this for the benefit
13 of the federal government and, of course, to the benefit
14 of the manufacturer?
15 MR. LORY: As I said, this was a cursory field
16 test. We selected five agents and the contractor applied
17 those agents as the manufacturer specified.
18 VOICE: What was the criteria used in the selection
19 by the government of these five agents?
20 MR. LORY: We had selected we did not have
21 control over all five agents. We had control over the
22 candidates of four of the materials. The fifth one was
23 selected by the contractor.
24 VOICE: What criteria was used for the candidates?
25 MR. LORY: The candidates were selected
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according to previous applications in known conditions,
2
and we were not trying to run all 200 agents. That is
the reason why I don't want to give agent names or whatever
else.
This, as I said, is a cursory study, and we were
just trying to see what five different agents would do
H
being applied by a contractor to a similar material, FIM
Q
material .
Q
VOICE: Localized manufacture units? Were thse
scattered throughout the country, these selection of five,
by the manufacturer's materials?
12
MR. LORY: They were scattered. They were not
13 local.
VOICE: Was this advertised that this test was
going to be conducted?
16 MR. LORY: No. It was not advertised.
17
VOICE: Has any of your accumulated data from
1 8
the Civil Engineering Lab been used to confirm or to discredit
any of the Battelle findings, and if it has not, are you
20 doing to do something with the ASTM?
21 MR. LORY: We used the Battelle work as our initial
22
point to look at encapsulating agents. We don't wantt
to reinvent the wheel. It is impractical to reinvent the
wheel .
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And so we have taken Battelle's effort as well
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1 as other known encapsulating agents that have not submitted
2 to Battelle to be evaluated, and we took those agents
3 as i am saying, we have done cursory work in this investigation
4 We are going in a little bit different way than BattelleIs
5 effort in research and our research is not conclusive at
6 this time.
7 The Navy's work will be continued on for the
8 next year, year and a half, which will include additional
9 effort in looking at encapsulating agents, characterization,
10 the potential field test methods that could be used at
11 Navy activities, a guide specification in selecting an
12 encapsulating agent, and a guide specification on the applica
13 tion of encapsulating agents is the area in which the Navy
14 is being directed at the present time.
15 I don't know if I answered your question.
16 VOICE: To some degree. In other words, you
17 are only concerned with the military sector, and that is
18 what the purpose of the
19 MR. LORY: Okay. The term military sector is
20 a ref inaji term, but you must realize that the Navy has as
21 many different buildings as conceivable from administrative
22 buildings, schools, gymnasiums, swimming pools and heavy
23 industrial areas and so on, so we cover a wide range of
24 building types or facility types.
25 So when we are looking at the application of
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encapsulating agents, we are looking at a potential for
2 all of those different types of structures. We hopefully
3 do not have a problem in which the schools have concerning
vandalism and mischievous types of activities that could
definitely curtail the selection of certain corrective
measures.
And so if we were looking at more of the adult
8 population rather than the adolescent or the K--12. Is
9 that satisfactory?
10 VOICE: Yes.
11 MR. LORY: Yes?
12 VOICE: Mr. Lory, could you tell us how thick
13 the sample is in actuality?
14 MR. LORY: The FIM sample?
15 VOICE: The samples that we have been looking
16 at in the slides, how thick are they? An inch, two inches,
17 a quarter inch?
18 MR. LORY: Of the FIM or the penetration?
19 VOICE: The FIM itself, the sample you took off
20 after you had it encapsulated or penetrated by the contractor,
21 MR. LORY: The one that was done on the West
22 Coast, the material was anywhere from a half inch to two
23 inches thick.
24 VOICE: What is the general depth of binding
that you are getting from the penetrating sealants? If
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1 you look at the slide over here,, how far down is it going
2 down and actually binding the fibers? At what point do
3 you get vacuums or areas where the material is not pene-
4 trating to inches, if you can do it that way?
5 MR. LORY: I am not prepared to give it to you
6 in that way. It is just that some of the agents, which
7 I will show you in just a moment, penetrated the full depth
8 of two inches. Other agents we were barely able to detect
9 it within a quarter inch of the surface.
10 And so depending on the agent, and again, I feel
11 it is the type of FIM which you are addressing, so what
12 I am -- the bottom line is that each building is unique.
13 Each application of FIM is unique.
14 There is no standard FIM, asbestos-containing
15 material applied. It was every time the contractor got
16 to a building and was told to apply FIM material, he obtained
17 whatever material he could, off the street or from manu-
18 facturers or whatever else, combined the various components
19 and hoped that it met the acoustic properties or the thermal
20 insulation properties or the fire proofing properties that
21 was required by the specifications or the codes of that
22 city or state.
23 VOICE: The slides that we are looking at, would
24 you classify this material as friable? Would this
25 particular FIM be classified as friable?
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1 MR. LORY: Very definitely.
2 VOICE: You had indicated already still ongoing
3 tests that are being made by Navy?
4 MR. LORY: Correct.
5 VOICE: Will the responsible manufacturers who
6 have a reasonable track record in the field be invited
7 or can they invite themselves in to conduct a test with
8 materials of their own?
9 MR. LORY: We are not in the position to at the
1° present time take in large numbers of manufacturers' products
11 and evaluate them. We are trying to approach it in a different
12 way than the EPA encapsulating agent studies.
13 We are trying to go more towards the overall
14 performance of certain generic types of encapsulating agents.
15 In other words, we probably will never come up with a list
16 saying this, this, this and this is acceptable under these
17 conditions.
18 Our eventual goal is saying that with this generic
19 type of resin and percent solids, pigment solids, being
20 tested, a field test in the building on the specific FIM
21 that is found in the building, you should get this type
22 of characterization of the encapsulant.
23 VOICE: Was the generic polimeric material then
24 confirmed?
25 MR. LORY: This is a cursory study. We have
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1 not addressed all the questions which you are presenting.
2 VOICE: The question was whether the generic
3 nature of the polimers had been determined prior to the
4 test.
5 MR. LORY: They have not. We have got the
6 manufacturers' names and we have got samples of the material,
7 and we can, through our paint lab, we can determine it
8 or we can obtain it.
9 (Slide.)
10 MR. LORY: This is one of the binding agents
11 that was not in the Battelle study as far as I know, but
12 we have seen that it looked fairly good in the one applicatior
13 in which we conducted this field study. Again, we have
14 a surface view, planned view, 30 magnification, 100 magni-
15 fication.
16 it appears like most of the fibers, even on the
17 surface or in depth have some type of encapsulating agent
18 present.
19 (Slide.)
20 MR. LORY: This is a series of slides that will
21 give a cross section of the FIM with the encapsulating
22 agent. This distance is well over an inch and a half.
23 The encapsulating agent of course, we do find, you know,
24 the fibers sticking up, but we do in closer observation
25 of the photographs themselves, this is all encapsulating
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agent.
2 (Slide.)
3 MR. LORY: This is the surface right up in this
4 area here. Again, we find some fibers, but there is a
5 coating of encapsulating agent on them.
6 (Slide.)
7 MR. LORY: We are going down into the material
8 in this area here. Again, the encapsulating agent did
9 penetrate, and I feel that the contractor did apply all
10 of these encapsulating agents according to the manufacturer's
11 specification and did not favor any of the encapsulating
12 agents.
13 (Slide.)
14 MR. LORY: This is continuing down into the depth
15 of the material, and we still see the fibers bound together.
16 We are right in this area right here.
17 (Slide.)
18 MR. LORY: This wishbone shaped structure here,
19 again, we still have the encapsulating agent binding the
20 material.
21 VOICE: Whan you cut those sections, how did
22 you cut them? Did you do any damage? Those holes in the
23 material, were they gouged out in the cutting or what?
24 MR. LORY: On this piece of material I do not
25 feel that the preparation caused any of this damage,
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1 because this material appeared to have a the encapsulating
2 agent all the way through it. It was a condition where
3 you could --- you would have to pull on the material to
4 get it out.
5 VOICE: Did you use a knife?
MR. LORY: Right. I was not actually present
7 during the preparation of the materials, but it is basically
8 for the cross sections we were using razor blades and sharp
9 instruments like that to try to get a representative cut
10 through, and I think basically we have been pretty luck
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in that.
This photograph is a continuation on down from
this first slide over here.
(Slide.)
MR. LORY: And this is another photograph further
on down, but a higher magnification, still showing that
the encapsulating agent is present, even below this slide
here.
(Slide.)
MR. LORY: One of the areas that was presented
by one of the EPA regional office asbestos coordinators
is could we use, quote, unquote, a good quality latex paint
over the surface of granular/cementitious asbestos containing
material.
And so in one of the studies which we worked
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on, we applied a latex paint that -- Bill Mirick, you are
o
going to have to bring it back to my memory. What was
3
the percentage of resin solids?
4 MR. MIRICK: Resin solids, 20 percent; 45 percent
5 total solids.
6 MR. LORY: 45 percent total solids, about 25
7
percent resin solids. I think between 45 and they were
saying sometimes all the way up to 50 or 60 percent total
solids. That is what they were classifying at a good latex
10 paint.
11 I am putting that in quotes.
But here is a surface or planned view, 100
13 magnification, and this is a cross sectional view of it.
14 This is a granular/cementitious material that contained
15 between 10 and 15 percent chrysotile fibers and a lot of
16 plating material as you see. And this is the latex paint
17 in here.
18 In this SEM you see some holes. Within the latex
19 paint, the cured latex paint this was just applied with
20 an airless spray by going two directions, first one way ---
21 first there was a mis-coat put on. Then they applied the
22 latex paint in one direction and allowed it to cure for
23 one hour, if I am not mistaken, and then went 90 degrees
24 from the original direction.
25 This is the normal application of it. It was
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1 interesting enough that they also took in another test
2 area, did the same application and then they what they
3 call backrolled it. You contractors may know what that
4 term means.
5 It is used in cement, the application of sealants
6 to cement, is where you apply your sealant and then you
7 take a roller and work the sealant into the cement. In
8 this case not in this photograph, but in other ones
9 that we have seen, they backrolled the latex paint and
10 these voids were pretty well worked out, and we got a
11 continuous film on it.
12 (Slide.)
13 MR. LORY: Current Philosophy. When encapsulation
14 of FIM is appropriate, the following should be considered:
15 field test several candidate encapsulting agents on the
16 material in your facility to select the best material under
1? the conditions in which you are working.
18 And I want to thank you.
19 VOICE: Before we close, I would like to make
20 a correction on the record. Earlier this morning I believe
21 Bill Mirick stated that the ASTM number was E-1036. For
22 the record, it is E-736.
23 MR. REINHARDT: I think we will take a rather
24 long break for lunch now. If we can be back at 2:30 for
25 Mr. Hubbard's talk, which will last about 45 minutes,
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1 and then we will have a short discussion period and then
2 you get to hear me some more.
3 (Whereupon, at 12:22 p.m., the conference was
4 recessed, to reconvene at 2:30 p.m. the same day.)
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i AFTERNOON ±> H § .s ! P_ N
2 MR. REINHARDT: At this point I want to introduce
3 James Hubbard, who holds degrees from the Georgia Institute
4 of Technology and works at the Experiment Station at Georgia
5 Tech.
6 His specialty is electron microscopy and he
7 is going to tell us everything he knows.
8 MR. HUBBARD: I have brought you some more
9 scanning electron micrographs to look at. You have seen
1° a number of them already this morning and we will try to
H go through them quickly.
12 The main topics that I want to bring up are a
13 couple of experiences that I have had in dealing with sealant
14 materials. Two such incidences in particular. One, an
15 ideal situation as much as that can be, the testing wasn't
16 as much as I would like for it to have been but the fact
17 is we were given the opportunity to test a system, a school
18 system who had a problem with the same type of material
19 which you have been looking at this morning, and about
20 25 percent chrysotile, about 25 percent chrysotile and
21 75 mineral wool, and they, in my estimation, did the ideal
22 thing of asking a consultant to come in and survey the
23 situation, tell them what the problems were and how they
24 might solve it.
25 in doing this, this material, by the way, was
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1 sprayed onto the steel beams above a drop ceiling, but
2 this area between the drop ceiling and the steel beams
3 was the return air plenum. So that any potentially damaged
4 material or any vibrations in the building could be re-
5 leasing fibers into the air stream of the building.
6 So I was asked to come in and test the air and
7 help design some tests so that we could see what perhaps
8 sealants might do in this situation. Air sample tests
9 taken before the sealing of the material began and after
10 sealing of the material, this was done with the optical
11 microscope., not with the transmission electron microscope,
12 because we were still infants in the field and this was
13 the OSHA way to do it and we have little by little been
14 learning that really if funds will allow, transmission
15 electromicroscopy in these situations of non-industrial
16 exposures is the only way to go.
17 Of course, we are dealing with material that
18 is fibrous, but we are working in a school that has some
19 carpeted areas, has a tremendous amount of paper being
20 thrown around, fibers coming off everywhere, the material
21 is 75 percent mineral wool.
22 In the optical microscope in air testing the
23 material how much of the material that you see is actually
24 chrysotile?
25 You can't answer that. You can only answer that
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1 with microscopy. I don't like to do it. It takes a long
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time and is a tedious operation to do those studies.
We tested the air in the building before any
4 of the processes started and in both cases we were well
5 below OSHA's standards of even 0.5 fibers per CC.
c
After the test, we were about five times or six
times higher in actual fibrous count, because they had
o
been in there disturbing the material and it still remained
9 in the air, it hadn't been all cleaned up.
10 Then we divided what I have called a fiber release
11 test, and this is again started from this was sort of
12 the starting point, and these types of tests I have been
13 using on various other materials and in various other situations,
14 and they are sort of evolving as a viable test and changing
15 all the time.
16 So our first thought in trying to decide what
17 is a fiber release test was to decide, okay, we are going
18 to spray this material, let's see first what happens when
19 you brush or disturb this material as far as how many fibers
20 are released into the atmosphere, fibers that the kids
21 might breath, and then what happens after we have sealed
22 this material with a sealant.
23 Let's treat it the same way. Let's also think
24 that perhaps we might want to do more testing. We might
25 want to consider what happens with just inadvertent
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brushing, we might want to consider what happens when the
maintenance man has to go into the roof, into the ceiling
and do work and digs into this stuff.
Let's try and get the whole story. Let's find
out what sealants are doing. In this first test we found
that we couldn't do too much damage to the material because
the sealant really did not penetrate this material very
well.
Again, this was the same type of material that
you have seen shown earlier today. And in even the least
amount of pressure on the material, we could tell that
while the surface had a hard finish due to the sealant,
the sealant had not penetrated through too much of the
thickness and this material didn't I would say none
of it was over certainly not over an inch, and most
of the areas that we tested were less than a half an inch
thick.
Now, I didn't have any say or anything in the
picking of the sealants. Again, the EPA list was consulted
and some sealants, about five, taken, maybe sealants and
a bridging agent, as materials which would be used to test
on different beams in the different rooms.
Maybe one room the ceiling was opened up and
there were six steel beams across, and a piece of plastic
was put down the center so that three beams on one side
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1 could be used for one sealant and three beams on another
2 side could be used for a different sealant and the different
3 sealants were checked in this building.
4 Before the sealants were applied, we did a fiber
5 release testing, to try to release some of the fibers and
6 this material is so mushy, you can't really brush it or
7 abraid it, so it was a matter of just damaging it with
8 the hand and see how many fibers were released by it by
9 having an air sampler immediately below the area that we
10 were damaging.
11 Then after the material had been sealed with
12 the sealant, then we went back and decided we would be a
13 little more scientific about it, so we built this very
14 scientific piece of equipment.
15 (Slide.)
16 MR. HUBBARD: Now, as you can see, this is a
17 very scientific looking piece of equipment, of course,
18 designed at Georgia Tech. We don't have the GT on it,
19 but it consists of a wooden block on the top. I rounded
20 all the corners so I wouldn't get any digging in, took
21 some screen wire and bonded it to the surface -- I tried
22 to take everything that I could into consideration.
23 If I am going to be looking at optical
24 microscopy, I want to be looking at nothing by mineral
25 wool and asbestos.
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1 Bonded the surface with epoxy. If have a stainless
2 steel spring here and a coil spring underneath the thing
3 and you see the plastic gage on the side which has been
4 calibrated with my magic marker and my scales to read the
5 pressure that I am putting onto the surface.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
And I felt like this would at least give me some
other quantified amount of pressure with an area and a
weight that I am pushing onto the surface with.
Unfortunately, the surface just wouldn't stand
up to even the first mark, and we ended up just barely
rubbing this wooden block onto the surface and making our
fiber release test.
The results were that more fibers were released
from the sealed material than from the unsealed material.
And when we reported this and compared this with some other
notes, surprise, surprise, many others in this area, I
think in a Paris study even had discovered exactly the
same thing, more fibers were released from the sealed materia
than from the unsealed material.
This was not true in every case. There were
some of the sealants that we tried that did not show this.
At least one of- the sealants that we tried did not show
this.
The bridging agents were particularly bad about
it. And this especially showed up in the electron
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1 microscopy studies. They did allow us to do some of those.
2 So I feel what has happened in this case is that this fibrous
3 material, this chrysotile, which, of course, exists in
4 this material in the form of bundles of fibers -- after
5 all, the basic chrysotile fiber is only about three to
6 400 angstroms in diameter, it is extremely small, and the
7 chrysotile is very easily cleaved into these fine individual
8 fibers given the chance.
9 Most of the times the material as it exists in
10 this particular type of material is in the form of bundles
11 and these bundles -- the whole material has been mixed
12 with some binder and the bundles have fairly well held
13 together, and fairly well held to the mineral wool. And
14 when one shakes this material and releases some of the
15 fibers, sure you release a lot of the fibers, but most
16 of the material stays together and falls to the floor and
17 it is not released in a small enough fiber to be an airborne
18 fiber.
19 Then the question, okay, that happens, but that
20 material is now on the floor and the kids are going to
21 be walking around and they are going to grind it up and
22 it is going to become breathable asbestos as it gets stirred
23 back up into the area.
24 That also may be true, but our study is concerned
25 with what is going to happen right now. While with the
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l sealed material, now you have a hard surface that is holding
2 these bundles, and again, I believe most of the materials
3 where the data after the fiber release data after the cealing
4 showed tremendous more respirable fibers released.
5 Those materials tend to hold the outside of the
6 bundles, seal the surface, perhaps, but they don't really
7 wet, penetrate into the bundle and secure the thing. Instead,
8 it is like in one instance you have a bundle of fibers
9 and you knock that bundle off and it falls to the floor.
10 In the second case you have a bundle of fibers held but
11 when you brush it you brush out the small fibers inside.
12 You are holding the outside and are able to release these
13 fibers into the air and they are much more respirable.
14 I think we are all agreed anyway that any area
15 which is accessible to any especially the kids, is really
16 not a candidate for a sealant, because they are going to
17 damage it.
18 We know that they are. The next step in our
19 assessment of all of the candidates for sealing was to
20 do a scanning electron microscopy and we went back and
21 took sections of each of the areas where different sealants
22 had been applied, prepared them, I suppose, much the way
23 Ernest's group did by sectioning them as carefully as we
24 could with a razor blade and looking at the cross sections
25 trying to see how deep the penetrant went into this fiber
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1 mass.
2 One of the problems here is that again you have
3 a binder mixed in with this originally, and it is a bit
4 difficult to tell in the scanning electron microscope when
5 you see a coated fiber, is that fiber coated with the original
6 binder or is it coated with the sealant.
7 Some of the things that we tried to look for,
8 for instance, if I am looking in one particular area and
9 I see two fibers that are lying next to each other, if
10 those fibers don't have some material between them and
11 show a wetting between the two fibers, if you can see a
12 nice sharp corner, there is nothing between them holding
13 them.
14 If you have a sealing agent you should see a
curvature there where this material is wetting. The next
16 few slides are just some of those that we took.
17 (Slide.)
18 MR. HUBBARD: This is one of the materials
19 I believe this is the sealed area. The flatter area is
20 the one I think that you will see that is next to the beam,
2i and as you can see, it doesn't really look like a continuous
22 sealed surface through the cross section. .
23 We then took pictures next to the surface a quarter
24 of the way in, half the way in, three-quarters and on the
25 outside surface. I am not going to show them all.
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1 (Slide.)
2 MR. HUBBARD: The next picture shows the outside
3 surface of this particular material. And here you can
4 see the real wetting of this material onto the fibers.
5 The fibers are almost completely encased in this material.
6 You see some sticking out, but you see that the material
7 does wet, and I think this is an indication that we might
8 consider in studying these sealants is how well do they
9 wet.
10 Most of the fibers you see here are the mineral
11 wool fibers. Just because we see the well, if it wets
12 these mineral wool fibers, it is certainly going to encase
13 the asbestos, but we don't really know if it wets the asbesto
14 ; so it might be more difficult to actually find a chrysotile
15 fiber bundle and see whether or not this material forms
16 a node with a very high contact angle which says, I don't
17 like that surface.
18 And the different sealants, by the way, when
19 you are talking about absorbing in and wetting, what is
20 the chrysotile mixed with? Are you going to have catonic
21 or ionic type bonding? Is it really going to wet that
22 material?
23 Maybe it wets this material, but not that. Why
24 do I seem to have less penetration on these tests that
25 we did than those tests that Ernest showed earlier?
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1 Maybe because, you know -- I don't know -- has
2 the stuff been up there longer? It is a little black and
3 dirty on the outside. And being in the air plenum, has
4 it gotten a layer of oil on the outside?
5 There are so many questions as to whether a sealant
6 is going to work on this particular material, and of course,
7 this is a hidden material and if it could be sealed, it
8 is not where the kids can get to it and damage it or other
9 people can get to it and damage it, but if you have things
10 in the air that are going to scrape it and release fibers
11 you don't want to use it.
12 (Slide.)
13 MR. HUBBARD: Here we see at a quarter, like
14 this material in here is binder. This is probably sealant.
15 You will see it seems to wet very.nicely.
16 That is a pretty good angle. In other words,
17 this is sitting up. This is not just coming right out
18 and wetting right out on that fiber. It could be a matter
19 of how much material is there, too.
20 This seems to be bridged in here and holding
21 together, but this is within the first quarter and the
22 distance is probably 3/8 of an inch.
23 Half way into the piece --
24 (Slide.)
25 MR. HUBBARD: I feel like all of this material
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1 that we are seeing is the original binder, and I don't
2 really feel like there is any sealant in here. We see
3 some very fine fibers. They seem fairly clean.
4 There might be just a little touch of stuff down
5 here. You might say some got there, but in all practicality,
6 there is no real sealant there. The next one is three-
7 quarters of the way in and it shows about the same thing.
8 (Slide.)
9 MR. HUBBARD: This is again just another sealant.
10 We will go through this one fairly quickly. A cross section
11 of the material.
12 The surface is really sealed well. Everything
13 seems nicely bound together, but remember, it is from that
14 surface that I am getting a lot of fibers released on fiber
15 release tests, as these things are being held so that when
16 I do rub that surface I am able to tear the fiber bundles
17 of chrysotile into finer and more airborne fibers than
18 before.
19 (Slide.)
20 MR. HUBBARD: Probably a total of less material
21 is released, but I have to look at that. One-quarter of
22 the way in, most of this material I think is original binder.
23 If not, it sure doesn't wet very well anyway.
24 You see maybe here there is a little bit of the
25 sealant in there by the time you get halfway.
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1 (Slide.)
2 MR. HUBBARD: This particular one had the best
o
fiber release data, that is, less fibers actually released
during the fiber release test after the sealant than before.
5 It is a little bit thicker base. The surface is very well
6 sealed.
7 (Slide.)
8 MR. HUBBARD: A quarter of .the way in you still
Q
see a lot of sealant between the fibers, holding the fibers
together, actually glueing them together.
11 (Slide.)
12 MR. HUBBARD: Halfway in again, halfway in,
there doesn't seem to be any of the sealant this particular
14 sealant in with the material, and all of the materials
15 seem that was just from the touch.
16 That is, they weren't hard crusty pieces after
17 being sealed. You could tell they had an outside crust,
18 but the inside was still soft and mushy like the material.
19 (Slide.)
20 MR. HUBBARD: This is just another example, again,
21 sealed material here.
22 (Slide.)
23 MR. HUBBARD: Outside surface, sealed very well.
24 Again, this particular material perhaps doesn't wet as
25 well. You can see where this material is not really
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bonding to this fiber. You have got a film here that is
2
covering the surface, but you can see here, you can see
3
here and here and even here it doesn't run up on the fiber,
4
so this particular material doesn't seem to be really wetting
the surface.
/?
It is forming a film, but not really wetting
7 it.
8 (Slide.)
9 MR. HUBBARD: Within the first quarter of the
thickness, which may have been about a quarter of an inch
11 or 3/8's of an inch, there is no sign of any of the sealant
12
there. I believe all this material is the original binder
13 ! material.
14 (Slide.)
15 MR. HUBBARD: The next slide shows the bridging
agent. As you can see, we have a very thick film. It
17 has a lot of bubbles in it but it is a continuous film
there on the surface. Again, about a quarter of an inch
19 thick there on that piece.
20 The next slide is taken from this area here.
21 (Slide.)
22 MR. HUBBARD: It looks like one continuous surface
no
with no fibers evident. The material has really held tight
24 as I have cut through and cut the fibers off and you can
25 hardly even identify the fibers.
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1 (Slide.)
2 MR. HUBBARD: And, of course, as soon as we get
3 back behind that bridged surface, then there is, of course,
4 no evidence that we can see of any material being there.
5 Again, this binding agent makes it difficult to analyze
6 that, and like Ernie said, if we can perhaps if we were
7 going to do a lot more research, then we could put some
8 trace element -- in other words, I can take a scanning
9 microscope and look at any one spot with my energy dispersive
10 x-ray analyzer and tell the elements that are in any one
11 little spot anywhere along in this material, so that if
12 the bridging agents or sealing agents or whatever I had,
13 I had enough of a trace element, I could go along looking
14 for where it was .
15 But in my estimation, if you can't really see
16 it there doing the job, then it is not enough to really
17 be concerned about.
18 (Slide.)
19 MR. HUBBARD: And that is just on further into
20 that sample.
21 (Slide.)
22 MR. HUBBARD: Now, the next job that we had to
23 do concerned a 15 percent chrysotile I don't say the
24 next job, but the next one I am going to report to you,
25 anyway.
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1 This is one of the semi-cementitious materials,
2 say, 15 percent chrysotile in perlite. And here is probably
3 the situation that occurs more normally than the first
4 situation where the people in charge of the school system
5 really want to test and see what is happening.
6 Here the school system discovers that they have
7 got chrysotile. They have got asbestos. It is sprayed
8 onto concrete in the halls, in the ceiling. And they want
9 to do something about it quick.
10 And they really don't want to let out that they
11 have got this material, and by the way, even in the first
12 situation, all of thse tests, of course, were done when
13 school was out and no mothers or anybody else was around,
14 deep in the dark of night, you know.
15 And you all know exactly what I am talking about,
16 I am sure. But that is the situation. It is interesting
17 that we have had two sessions at Georgia Tech, two three-
18 day seminars on asbestos, and in most of the situations,
19 of course, most of the people are the same way.
20 The building managers and owners, they don't
21 want to create a scare, and we don't want to create a scare
22 either, but it was interesting that one of the architects
23 or people who I believe he was a school person -- who
24 did have the PTA jump on him about having the material
25 in the school, when he really -- when everybody really
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came face to face and really opened up talking about the
problems and the problems of not knowing exactly what to
3 do and all this, everything was worked out so beautifully
4 instead of everybody running around hiding everything,
5 that most people I feel like when really shown all the
6 facts, everybody is fairly reasonable about everything.
7 But anyway, in this situation the school officials
8 said, hey, let's do something, let's seal it up. And so
9 the maintenance people picked out a sealant, ran and bought
10 it and sprayed the ceiling.
11 Unfortunately for the school, the student body
12 president in some newspapers in that area said, hey, is
13 that really the right thing to do. So, again, we were
14 asked to come in and let's just see what the situation
15 is.
16 Okay. We admit we did wrong. Let's do it right.
17 Please tell us what to do. So we went down and sampled.
18 We did ambient air sampling.
19 We found very low counts just in the regular
20 daily run of the use of the particular area, but when we
21 did some fiber release tests, and why was fiber release
22 testing necessary?
23 After all, the stuff was up there on the ceiling.
24 Fiber release testing then went from scraping with my magic
25 tube to simulating exactly what was happening to the material,
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As I mentioned to somebody at lunch the other
2
day, I said, well, you know, the kids had gotten up there
g
and they had written names in the stuff and they had drawn
4
pictures, and he said, oh, yes, those little tikes just
won't leave it alone.
/?
I said, this is a college and the pictures were
7
large pictures. And they are pretty good. So we went
Q
in and did some fiber release testing. We were doing some
g
air sampling, and of course, we picked a boys dorm and
a girls dorm, and the boys dorm, they didn't like it too
much, the pump out there running in the hall for six and
a half hours.
13
The girls didn't seem to mind too much. When
14
I came back, I saw them standing in front of it standing --
they wanted me to find a lot. They were powdering it.
i fi
The whole day was shot as far as that test was concerned.
17
As the maintenance said, if we are going to have
18
trouble , it is going to be here in the girls dormitory.
1 Q
Times are really changing. Maybe I don't know what went
20
on in the girls dormitories before.
21
We didn't have girls at Georgia Tech when I went
22
there, so my education has been neglected. We came in
23
and did fiber release testing on some of the material that
had been coated and some that hadn't been coated. This
95
fiber release test took on a little different aspect.
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1 I decided that really we did need to know exactly,
2 say, everything that is going on, so we just used a piece
3 of metal to scrape like the kids would and remove, say,
4 one square inch of the material and find out what happened.
5 We did this inside of more or less a closed container with
6 two holes in it, a hole on one side for the air sampler
7 to check how much material was released into the air that
8 could be breathed, another hole on the other side to let
9 the air pass through and to allow me to go in and scrape
10 the material loose and then the container to catch the
11 material that was released.
12 We wanted to know how much fiber gets into the
13 air and how much falls to the ground, so these tests were
14 done. Even though we totally removed all of the material
15 and actually the unsealed material was slightly thicker
16 than the material that had been sealed, we still got more
17 fibers released in the air from the sealed material than
18 from the unsealed material.
19 Now, the real scare here is in that one time,
20 from our ambient air samples we know that the exposure
21 that the kids walking down the hall get is not high. It
22 is fairly low exposure, but there are some kids who are
23 getting their noses right in the stuff and scraping it
24 loose and breathing it.
25 It is unfortunate kids are that way, but they
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1 are, and so are some adults, who are kids, I guess.
2 But what are the effects of a one time high exposure
3 to a material which from all that we have learned gets into
4 the breathing passages into the lungs and it never leaves?
5 It is always going to be there. You are certainly
6 not going to get asbestosis. That is high exposure for
7 a long time.
8 But the cancer risks, and I don't care what all
9 the other people say, I have read the reports, I have had
10 questions, I don't accept things without reading over the
11 techniques that were used to determine whether risks were
12 real or not, and I have accepted these things, one I was
13 reading the other day from Dr. Sillocauf, which states
14 that one fiber could cause a cancer.
15 YOU chances of it growing big enough, I suppose,
'
16 or maybe is increased with the number of fibers in your
17 lungs, and it takes 20, 30, 40 years for this kind of thing
18 to develop.
19 So in my opinion, we have to get rid of this
20 material, we have to do something with it, and obviously
21 in this case, again, sealing is not the answer because
22 the kids are going to get to it and damage it, unless it
23 can be completely cemented in by this stuff.
24 Well, again, what we did after the fiber release
25 test was take a sample of the sealed material and take
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it back and look at it with the electron microscope. Let
2
me try to explain a little bit what this is.
o
Now, this perlite material, and I know you have
all seen this material, a very rough looking material on
5 the surface, you know, and it is sprayed up there right
on the concrete, and this is the outside surface and this
7 is a cross section here.
Q
And you can see the asbestos fibers and the thing
about this is that all of the fibers you see are going
to be chrysotile. So you can see them out here. This
is the outside surface.
It, of course, is going in and out and in and
i ^
out and that is why we can see it here, but this line right
14 here represents the outside surface. Is there anybody
15 that don't see what I am talking about?
16 This is the outside surface, because this material
17 is a little bit thicker there than whre I have cut. The
18 cut goes through the material right here and this represents
19 the cross section at this point.
20 Some of the perlitic material has been pulled
21 out. Right here where you see the marker, and this thickness
22 is no more than an eighth of an inch, and so this distance
23 from this surface, we see this particular feature here,
24 which in the next slide --
25 (Slide.)
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1 MR. HUBBARD: -- we see is obviously asbestos
2 fibers, we can see here, here, all around. We look closer
3 at that
4 (Slide.)
5 MR. HUBBARD: -- and we see no sign of any sealant
6 or material, and an even closer view of that square there,
7 you don't see any kind of bridging in there.
8 (Slide.)
9 MR. HUBBARD: Also, putting the electron beam
10 spot right on that fiber, we get the characteristic x-ray
11 elemental analysis of chrysotile, which says to me that
12 that is a bare fiber, with no more than three or four microns
13 thick of material on top of it, if anything there at all.
14 In other words, I don't really have the figures
15 to know exactly what the penetration of the beam would
16 be, but if I had five or six microns of material coating
17 that fiber, I wouldn't be able to get the x-ray elemental
18 output of the fiber because the beam would be absorbed
19 by that other material.
20 And from the look of it, you know. There is
21 a nice sharp edge here. To me that is to be expected in
22 that particular type of material. I don't know -- I am
23 not a surface chemist. I don't know about the real wetting
24 of this cementitious material by these sealants.
25 It would really depend on how thin they are as
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1 to how well they could penetrate into a material like that.
2 Well, we have got a number of problems, and what
3 usually comes out of these seminars we hae at Tech is that
4 everybody goes away realizing that we have more problems
5 than we have answers. And maybe a little more mixed up
6 than when they first came.
7 You know, sometimes ignorance is bliss and we
8 learn a little bit and then we really get mixed up and
9 really don't know what to do. We have gone from using
10 sealants to not even thinking about them to using them
11 again, and maybe perhaps -- it was kind of, I thought
12 earlier, like the story that one of the medical people
13 told at the last conference, which was about one of the
14 fertility drugs.
15 I don't remember the name of it. Thalidamide.
16 Where so much research was done on this particular drug
17 before it was every used using rats and mice, guinea pigs
18 and things like that, and they found absolutely no ill
19 effects at all, and so it was put on the market.
20 As soon as it was put on the market, the birth
21 defects just went right along the graph of it being on
22 the market and being taken off of the market. No, it didn't
23 affect rats, but it affected monkeys and the higher you
24 got into the world of man, the effect increased.
25 So it is like you hate to wait until all of
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1 the data is in from all of the research before you start
2 saying, hey, use this or use that. There are a number
3 of unfortunate things that have happened, of course. The
4 EPA's list, while it is not -- you know, it has the disclaime
5 and it says we have tested these and these seem to work
6 all right, they have the right fire retardants or they
7 don't smoke and this, that and the other, people look at
8 it and they take it for, hey, the EPA approves this sealant
9 and so therefore we can use it.
10 That is not the case. We know that is not the
11 case, but the general person who is managing a building
12 doesn't think about that. He is looking for something
13 desparately that he can use.
14 And that is a problem, and it is part of our
15 job to educate people. There are many sealants that are
16 probably very good that just never got tested. I am always
17 getting calls, hey, I have really got a good product, and
18 I would like for people to try it.
19 i was really glad to hear Larry say earlier that
20 he was going to encourage people, especially, say they
21 haven't been tried to find someone who will let them come
22 in and run a test and show how their material works, to
23 use the same test that Bill Mirick at Battelle used.
24 Maybe others. Maybe this fiber release type
25 of thing. The fiber release, I have been put down a
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1 little bit on that saying what is fiber release testing,
2 when really if the material is in a position where kids
3 are going to get to it or where it is going to get damaged,
4 then you shouldn't use a sealant anyway, so why use a fiber
5 release test.
6 We wanted to see what maintenance might do to
7 the stuff, but if the material is not going to be totally
8 sealed and encapsulated all the way to the substrate, and
9 the more I hear about it, the more I don't believe that
10 that is possible, then sealants perhaps should only be
11 considered if they are completely out of the way and maybe
12 we want to look at fiber release tests from air streams
13 that flow by them, but I really believe if they are in
14 the air plenum, maybe we need to be not only sealed, but
15 hidden some other way as well.
16 Certainly I recommend that some other surface
17 that is after sealing and even after the bridging agents,
18 then some thicker surface film which completely hides the
19 fibers from the immediate surface should be used.
20 This could avoid any inadvertent brushing against,
21 at least. That is really about what we have done and my
22 thoughts on it. I will welcome any questions that you
23 might have or anyway that we can help you.
24 VOICE: On your air sampling, what kind of instru-
25 mentation did ycuuse, how long were your samples run,
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1 what was the air flow through the samplers?
2 | MR. HUBBARD: On the ambient air samples, we
3 tried to go with six and a half hours I believe we were
4 using about five liters per minute for six and a half hours.
5 Of course, the longer time you can run and the more air
6 you can pull through the better sampling you will have
7 so the better data you will have.
8 On the fiber release testing, where I was releasing
9 the fibers in a container, in a very small area, I ran
10 those only about 20 minutes but at 10 liters per minute,
11 which I felt allowed me time to collect all of the fibres
12 that were released into the air.
13 So instead of coming out with an answer in nanogram;
14 per cubic meter, we came out with an answer in nanograms,
15 this many nanograms.
16 How long does it take for this many nanograms
17 to fill up the space of one meter or something, this is
18 the total nanograms, this gentleman painting a pretty picture
19 in the ceiling could breathe.
20 VOICE: What were your levels?
21 MR. HUBBARD: Some of the levels on some of the
22 sealed material were as high as 3,000 nanograms. And that
23 is a lot.
24 Isn't that right? 3,000 nanograms?
25 VOICE: What about the unsealed material?
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1 MR. HUBBARD: I believe it was about 400 nanograms.
2 This, by the way, was a penetrating sealant. Yes. On
3 the unsealed material we got released into the air about
4 400 nanograms. That calculated out, of course, which is
5 kind of I don't know the number of fibrils per cubic
6 cenitmeter, if you will, that is not fibers, now, but if
7 you calculate I give all sort of answers.
8 That really mixes everybody up, see. So nobody
9 knows what I am talking about. You have fibers per CC
10 which is the fiber bundles, but if you take that bundle
11 and say each individual fibril, how many fibrils are in
12 that fiber?
13 Again, that could be something like almost 4,000
14 fibrils per cubic centimeter released in the sealed material,
15 and some 450 in the unsealed material.
16 VOICE: That is calculated?
17 MR. HUBBARD: Yes.
18 VOICE: Is that calculated off your nanograms?
19 MR. HUBBARD: No. Off number of fibers. What
20 I am counting in the transmission electron microscope is
2l every time I find a fiber, I put down that fiber's length,
22 that fiber's diameter, and of course, I have counted the
23 fiber.
24 So when I finish I have total number of fibers,
25 plus I put into my calculator the length and diameter
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1 and come up with the weight.
2 VOICE: Based on this conclusion, obviously the
3 encapsulation wasn't to anybody's satisfaction. It was
4 a complete failure?
5 MR. HUBBARD: Absolutely.
6 VOICE: One is also basing a premise that this
7 deduction shold carry through for all situations.
8 MR. HUBBARD: Absolutely.
9 VOICE: If I may make an assumption, there seems
10 to be more of a tendency for everybody to concern themselves
11 with a complete penetration through the system and unto
12 the substrate and maintain a high interface adhesion as
13 well as a cohesion.
14 is this desirable or necessary assuming that
15 the surface characteristics were monolithically adequate
16 in terms of fiber release under normal, evan vandalistic
IV type situations?
18 Is this penetrant a requisite, assuming that
19 the sheer factor is adequate?
20 We had found in some conclusions, and we used
21 a rotamean B dye that becomes part of the polymeric materials
22 rather than in the vehicles as such, and the conclusions
23 were under ultraviolate light that we have penetrated within
24 a quarter of an inch and still maintained a high, viable
25 system of non-fiber release, even under excessive abrasive
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type situations, which would preclude that there is an
2
answer to the problem, without the thought of complete
3
penetrability, and as you know, the asbestos filter is
4
a darn good one, and we have angstrom sizes to the material
5
of around 700, which is a pretty low polymetric size.
6
We also initiated into the acqueous aspect using
7
floro-chemicals to redynes the dying factor of penetration,
8
wetability of the acqueous phase down to 18 and 16 dynes
9
which almost functioning as an organic solvent.
We injected the material as high as 3300 psi
to affect all the mechanical aspects of penetration and
12
still did not get penetration in excess of one-half inch
13
under certain situations.
14
So I can't see there is a chemical and physical
impossibility under all situations to maintain maximum
1R
or very deep penetration, but is that desirable assuming
17
that the surface characteristics have been affected?
18
MR. HUBBARD: I agree with you. I don't think
19 ^ ,
we yet know.
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If the material seals -- if it stops release
21
of the material into the air, of course, it still leaves
22
the problem of maintenance, which is always going to be
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there as long as the material is there, I don't care what
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form.
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VOICE: I understand.
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1 MR. HUBBARD: What is going to happen to your
2 material in two or three years, five years, what if your
3 material is in an area where there is a lot of ozone created,
4 I don't know.
5 There are too many unknowns.
6 VOICE: We had exposures outside under UV, and
7 I would presume ozone is present exterior in excess of
8 18 years with the system maintaining non-destructability.
9 So the presumption from that standpoint that you have an
10 indefinite life period.
11 It is chemical inertness. None of the reduction
12 type elements will attack the material.
13 VOICE: We can't hear a thing he said. If some
14 guy is going to make a statement, let him have the mike.
15 VOICE: I apologize. I don't think I can repeat
16 what I just said.
17 MR. HUBBARD: We are talking here about the
18 necessity of actually having penetration totally to the
19 base material by a sealant, which some have said is necessary
20 and maybe I have indicated -- I didn't really mean to indicate
21 that -- I did indicate, of course, that that was not happening
22 I think the fiber release test tells more as far as whether
23 or not it is keeping the fibers away from the atmosphere.
24 But I, again, don't have all of those answers either, but
25 I think a combination of Mirick's work and whether or not
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1 the material is going to stay there after the surface is
2 sealed, all of these things have to be taken into account
3 when you decide whether or not you are going to use such
4 a thing.
5 VOICE: Do you have a ball park figure for nanograms
6 MR. HUBBARD: I don't like to what are you
7 going to equivocate that to?
8 When you are talking about fibers per CC, everybody
9 has been talking about optical studies run on the OSHA
10 standards, and that means that you are looking at fibers
11 that are larger than five microns and fibers that hopefully
12 are all asbestos, because these standards were set up for
13 industrial applications where you are looking at somebody
14 sawing some asbestos material or something and you are
15 trying to see how many fibers are there.
16 Whereas, for every one 5 micron fiber, how many
17 fibers below 5 microns, which is what you are looking at
18 with a transmission microscope, everything from 2/10's
19 of a micron on, how many of those are there, and it is
20 really difficult to find any basis, because in the industrial
21 setting, the size distribution of the fibers is going to
22 be considerably different from what you find 15 miles downwinc
23 from a mine where only the finest fibers have stayed aloft
24 and are now counted and maybe the only thing that you see,
25 and probably with optical microscopy you may have nothing
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and you still may have 150 nanograms per cubic meter in
2
the area.
g
So it is very difficult. I can tell you how
4
many fibers it meant to me, in the electron microscope,
how many actually fibers, but don't try to make an equivalent
o
statement of that is what you would find with optical
7
microscopy.
g
But in the 3,000 nanograms in this particular
g
case, in using electron microscopy, it turned out to be
about 1.4 here is a good example.
The 3,000 nanograms in the case of the sealed
12
material, if we just said, all right, how many number of
13
fibers did you find per cubic centimeter of air tested
14
it was 1.4.
The 440 nanograms in the unsealed material came
1 £
out to be 2.4 fibers per CC. More fibers per CC, but they
17
were small, you see.
18
So it is really hard to talk about those things
19
together, because you can have big bundles and you can
20
have little bundles. So we give you another double standard
21
that you can't understand.
22
See, we just always throw these things out at
23
you and try to really keep you mixed up.
24
VOICE: The encapsulants in your study, were
they produced'primarily for correcting asbestos or were
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they products on the market that somebody submitted and
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said this will take care of that problem?
g
MR. MARTIN: If I understood your question, you
asked if the sealant was studied by Battelle.
5 MR. HUBBARD: What was the sealant made just
n
for asbestos encapsulation or was it something already
7
on the market that somebody said I think this will do?
MR. MARTIN: The sealant was a sealing that had
Q
high range in the Battelle study.
MR. HUBBARD: Have your companies are these
things that have been on the shelf and you have said, hey,
12
this ought to make a good sealant, or are both things true,
13
are companies looking and saying, hey, what really wets
asbestos?
15
MR. MARTIN: The thing to keep in mind on this
16 is that we were not there to observe the application pro-
17 cedures. We don't know how it was diluted or how it was
applied. It was an after-the-fact study.
19 We used a Battelle sealant and it was one of
20 the ones they had high ratings on. They could have not
21 followed the manufacturer's specifications.
22 VOICE: It seems like there is such confusion
23 about sealants, asbestos, encapsulants, what have you.
~4 It seems like maybe almost like an orphan drug setup. There
is already something there and we are giving a shot at
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1 ' it.
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Are you working chemically to try to change the
3 asbestos fiber itself?
4 MR. HUBBARD: One of the problems with asbestos
5 is it is one of the most chemically inert minerals around.
6 That is why it is such a beautiful fiber to use because
7 it is so resistant.
8 Chrysotile is the least resistant. Crocidolite
9 and amosite which are high on the scale are chemically
10 resistant.
11 Chrysotile will decompose in water in a couple
12 of years and in the body also. But there is a question
13 as to whether it has already done its damage.
14 Some of the asbestos bodies that they have found
15 in tissues that look like those where they have identified
16 chrysotile as being the center of this body don't have
17 any centers and so the question is was it a chrysotile
18 fiber that has since dissolved into the body.
19 That is why amosite, one used so much in the
20 ship building industry, has been such a real baddy to these
21 guys who come down with a lot of cases of cancer, because
22 it is one of the most chemical resistance.
23 Crocidolite, I think, is one of the most chemi-
24 cally resistant of all the fibers.
25 VOICE: I have had a few of the ones submitted
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1 that were actually formulated for this purpose. There
2 were several companies that sent in chemists and talked
3 things over for a couple of hours and went back absent
4 , in the products.
5 They said they were formulated for this purpose.
6 They are not broken down that way in the report, but we
7 do not have the type of facilities to do that.
8 Some of them were formulated for that specific
9 purose.
10 VOICE: Did you verify that these products that
11 you mentioned, the two studies you did, were actually of
12 products and were applied -- you mentioned that it was
13 a Battelle, if you will, listed product?
14 MR. HUBBARD: They were listed products, but
15 I was asked to do studies on the material after it was
16 sealed. I have no knowledge as to how it was applied,
17 whether it was .applied properly or anything like that.
18 VOICE: Might I ask, then, if you did studies
19 on material as applied, did you run any control with a
20 like product?
21 MR. HUBBARD: With a like product?
22 VOICE: With the same product, did you run any
23 control or just examine exactly what you looked at?
24 MR. HUBBARD: We just examined that that was
25 placed on those beams, yes.
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1 VOICE: No control?
2 MR. HUBBARD: No. What would I have used as
3 a control?
4 VOICE: The same material applied according to
5 spec.
6 MR. HUBBARD: Well, I had to assume it was applied
7 according to spec.
8 VOICE: That is a qualitative judgment on the
9 same material. It is not your job to do that.
10 VOICEi:') j .Did you try to ascertain the mil thickness
11 on the outside, the surface bridging materials, did you
12 see if they had the mil thickness on the surface? You
13 were looking for penetration, but how about the surface
14 mil?
15 Were you getting anything close to what the manu-
16 facturer specified?
MR. HUBBARD: I don't know. I don't know what
18 the manufacturer specified as far as mil thickness is concernejd,
19 Of course, we know how deep into the material you got the
20 solid -- you saw the pictures that showed the outside.
That was not a picture of the outside surface. That was
22 a picture of the cross section as we went into the material
23 and you had a more or less continuous film for a certain
24 mil thickness into the material.
VOICE: I am talking about actually the mil
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thickness of just the bridging material itself.
2 MR. HUBBARD: Explain to me mil thickness.
o
VOICE: When you are coating on any kind of material
you are talking about mil thicknesses, the thickness of
5 the actual coating on whatever substrate you are applying
6 it to.
7 Now you are talking to me about penetration into
8 the asbestos material, so you are going to have a mixture
9 of binders and whatever with the asbestos material, but
10 then you should have a thickness of the bridging material
11 of just the bridging material itself.
12 MR. HUBBARD: But from the work that I did in
13 looking at the material, when I say that we put virtually
14 no pressure on the material, just rubbing the block across
15 it, we did not just -- we simply scraped that for five
16 or ten secons and found all of these fibers released from
17 it, I assume that the mil thickness is nil.
18 VOICE: I wonder if it is a surface bridge. We
19 have a surface bridge that I have applied to some materials
20 and tried to cut through it and had trouble cutting through
21 it.
22
MR. HUBBARD: I didn't I am trying to remember
23 right now how much trouble I had cutting that section.
24 Of course, I used a real sharp razor blade. But it appeared
25 to me, and I am sorry, I do not have a scientific real
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answer for you, that the material did something into the
surface, that there were fibers very close to the surface.
I am sorry, no, I do not have that mil thickness for you.
VOICE: Based on what he just said, that would
indicate a very poor application technique. That first
coat, your :> penetrating sealant, should penetrate, bind
up, but that is not your protective layer.
The second application, let's say in the case
maybe perhaps applied full strength, would be your laminating
layer. This is going to give you the protection, not the
same day of application, because then you are going to
have a continuous phase, but the second day, and that would
give you a thickness that would prevent abrasion.
You wouldn't abrade it with five or ten strokes.
MR. HUBBARD: The point that you are bringing
out here is one of the big points. Who is going to apply
this stuff?
Do you do this? Are you toing to come down and
train the people who are going to apply this material?
When we finally say this kind of sealant is going to work,
I say fine, it is going to work on this material if you
use this guy to spray it on. That is the problem. I am
sure that the people who were spraying this mateial on
had probably never sprayed on a sealant before, because
it was just -- you know, the Battelle study was just
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1 out.
o
Nobody knew how to spray this material on. Nobody
3 still probably knows how to spray this on except the people
who developed it and know what they are doing.
I think that is a very big problem that we are
6 going to have in telling people to use them things, because
7 we need to tell them, fine, use them, but listen - I have
0
contractors who have been to my course at Georgia Tech twice,
and I don't care how much we tell them, this stuff is dangerous,
10 When you go in there to work, you have to be
11
protected. And the very next thing they do is go out the
12 next day and hose down a room without any protection and
13 then put on the protection, because now they are removing
14 the material, remove it and let it fall to the floor, remove
15 their protection, because it is removed, and sweep it up
16 into a bag. Maybe they are really dumb.
17 Maybe that is it. Or maybe they want to get
18 a quick job for a lot of money done fast. But that is
19 the kind of people you are going to be working with. I
20 don't know what kind of regulations you need to combat
21 that, but I agree, there is a way to apply this stuff,
22 and if not applied right, what good is it?
23 VOICE: The thing that started this last study
24 was that the students in the college contacted the EPA
25 because of the toxic fumes being generated from the sealant
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1 because they were applying them in the dorm while the students
2 were still there.
3 That is an indication of the level of education
people have about this problem. When we say they used
5 a sealant that was studied by Battelle, it does not necessarily
6 follow that they applied it properly.
MR. HUBBARD: That is right.
VOICE: Was that confirmed that it was toxic?
9 MR. HUBBARD: When these things come out, you
10 look bad.
MR. MARTIN: They were complaining as to the
12 side effects. It was bothering them. I shouldn't say
13 toxic. Wrong choice of words.
14 MR. HUBBARD: It was just a smell. And all the
15 manufacturers can get to looking bad because of that problem.
16 VOICE: Well, I have an easy question.
17 Did the contractors get paid?
18 MR. MARTIN: They used their own maintenance
19 people.
20 VOICE: We are contractors, and I would like
21 to know what kind of quality assurance. When we do a job
22 we take one of these manufacturer's products and spray
23 it on and we send around for general superintendent and
24 they don't generally carry a microscope of that nature
25 to take and do the x-rays and all that kind of stuff, so
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really, what can we do to make sure that we are doing a
good job?
Contrary to popular belief, not all contractors
are trying to do a less than professional job.
MR. HUBBARD: I have run into some guys that
are really great.
VOICE: I have talked to a number of encapsulant
manufacturers that they have big distribution systems.
Their technical people, they do all these fancy tests and
reporting and they get all their things and they send it
to distributors.
You have your local paint store getting a painting
contractor in the business and saying this is a miracle
cure-all for asbestos. We run into an aircraft and he
says this is great, it has passed all the rules, it even
passed OSHA.
We know that is not true. It is a local small
distributor, so they need to inform their people as well.
MR. HUBBARD: It is a big job for education.
We are lucky that at least this system we worked with was
farsighted enough to say, maybe we can encapsulate this
stuff, let's do these test panels and have it tested. Let's
pay the five or $10,000 just for the test to see if we
can do it.
That is a lot to ask of somebody. It really is.
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1 And most of them aren't going to do it.
2 VOICE: But that is not even conclusive.
3 i MR. HUBBARD: No, sir, but it is better than
4 VOICE: Too many variables.
5 MR. HUBBARD: Yes, but at least you are working
6 on the material. Although, as I have heard here today,
7 that is fine for this room, what about that room. How
8 much testing can you do, and yet if you don't do enough,
9 what are the kids going to be left with in the future?
10 There has to be some breaking point.
11 I don't know where it is.
12 VOICE: The reason I asked you if they had run
13 a control, when the gentleman over here put it better than
14 I did, it does sound like a question of application. The
15 simplest method we have today is to measure off anything
16 that we are involved in.
17 We have also hired a consulting engineer to inspect
18 our jobs if the parties that are having the work done so
19 request it. We also do measurements as best we can. This
20 is quite independent of Battelle.
21 I think it is a question of quality control.
22 And there is as much quality control there as anyone wants
23 to put it. We have distributors and our distributors measure
24 off jobs and they will not issue a certificate of compliance
25 if the material is insufficent for the amount of area
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1 to be covered, as best they can judge.
2 VOICE: I didn't get the last of that. I am
3 sorry.
4 VOICE: It is a question of quality control,
5 nothing more.
6 MR. HUBBARD: Yes.
7 VOICE: No matter what type of material you use,
8 in spite of the fact it might be asbestos, all types of
9 coating materials if not properly applied do not work.
10 MR. HUBBARD: Right. I absolutely agree. I
11 don't have the answer of how to educate the people that
12 are going to use it other than to say that I have noticed
13 that many companies, for instance, won't even sell their
14 material.
15 They only apply it. But every company can't
16 do that. We already have the established man power to
17 do that, and yet they may have an extremely good product.
18 VOICE: The problem with the two samples we
19 did were to investigate a very poor application.
20 VOICE: Quality control can be initiated, but
21 how can you set up a standard for qualitative judgment
22 of the person that is controlling the qualitative controls?
23 Who will make up the standards for the qualitative judgment
24 on the industry?
25 Education, skill, what could you pick? That
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question is rhetorical.
MR. HUBBARD: Thank you very much.
MR. REINHARDT: I would like to announce that
I would like all thet panelists to meet with me briefly
after this day's session is over. I think that the discussio^
we have been having in the last 20 minues or so are probably
more interesting than anything I could think of to say,
so what I would like to do at this point is hae
Mr. Mirick, Mr. Lory, Mr. Hubbard and Mr. Dorsey come up
here and respond to more questions from the audience if
you have any and then I will delivery my little presentation
tomorrow morning.
If you have questions, could you stand up so
that people in the back of the room can hear you and identify
yourself and state your affiliation?
MR. DORSEY: Are there any additional questions
for Bill or anyone that has spoken today?
VOICE: I would like to make -- there have been
two references made Ed Drasga with Kerseden Corporation.
There have been two references made here to a
specific two treatment aspect, and there was no depth of
discussion in this area to optimize the best of the properties
that we are attempting to reach, and that is the control
of emissions and air safety standards as a result of
encapsulation.
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1 The tests from Battelle appear to be singularly
2 treated towards the penetrants and towards the bridging
3 materials. Why not, as there has been investigations and
4 concludions in the field that the correct procedures appears
5 to be, at least the efficacy of the system has been confirmed
6 under proper application, qualitative judgments, controls
7 in a two component system or a two treatment system as
8 opposed to a single treatment system, and why not some
9 emphasis on that aspect?
10 I think the gentleman from this company here
11 indicated that that application was necessary in terms
12 to effect the best results of what we hope to achieve,
13 and that is to at least control or elimination of the problem
14 Has Battelle made any test in conclusion of the
15 application of both a penetrant and a bridging coating
16 too?
17 MR. MIRICK: We haven't looked at a combination
18 of systems, per se. Although, again, I think you can --
19 some of the penetrating sealants and even with some of the
20 bridging sealants, our method of application was to put
21 the first coat in and then a heavier coat, four hours later
22 put another coat on and let that dry overnight and put
23 another coat on in certain areas.
24 Where you let the penetrating sealant or even
25 the bridging sealant cure overnight and then put another
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1 coat on you do have the second barrier effect if you want
2 to call it that.
3 Once a material is secured, whether the penetrating
4 is cured, there will be no further penetration so the next
5 coat you put on just lays on the surface and essentially
6 gives you a bridging coating on the surface.
7 VOICE: If the material is 14 percent solid and
8 you use it as a penetrating seal, essentially a blocking
9 agent, you come back the following day and put the same
1° material on, there is not the quantitative requirement
11 to build you the necessary element of bridging aspect to
12 it and is the interface adhesion going to be a viable one?
13 MR. MIRICK: This is true in the lower solid
14 penetrations. When the penetrations get up to 30, 35 percent,
15 you can get a pretty good bridging surface over the top.
16 Again, we were not evaluating a combination of systems.
17 A penetrating and a bridging sealant probably would do
18 a very good job.
19 I have no real idea on that. But when you start
20 doing that, again, you are getting into cost factors where
21 removal is probably as economical as a double bridging
22 type system. And if you do that, my opinion would be if
23 it is the same cost, I would in all cases say remove.
24 VOICE: But I haven't found any system in terms
25 of removability and maintaining all of the standards that
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1 would equate the cost of an encapsulation, even in a two
2 component or two treatment system.
3 MR. MIRICK: Well, I don't have a real good figure
4 on all the costs out there. I have heard mention of systems.
5 Now, I can mention systems that I have not looked at. I
6 feel they would have a good possibility. I know one company
7 goes in and puts a penetrating material on'to wet the surface
8 After that has dried somewhat, they go in with an eighth
9 inch to quarter inch wire mesh, and core it to the concrete
10 with steel anchors and then go over it with a bridging
11 sealant.
12 They are doing that today.
13 VOICE: I would think that would equate removabilit
14 and I would exercise removability on that basis from a
15 cost standpoint.
16 MR. MIRICK: That is what they are doing and
17 they are selling their product and getting contracts.
18 VOICE: Robin Thoreau. How long will the
19 encapsulation system last? I have heard some say if you
20 expect it to last more than six years, forget it.
21 I have heard contractors and seen photographs
22 where they have encapsulated, turned to walk away and see
23 a whole ceiling peel down the corridor. The weight of
24 it just pulled it down.
25 MR. MIRICK: This has happened and this is some
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1 of the horror stories in encapsulation which turned out
to be nothing but expensive removal jobs. The material
3 sholdn't have been encapsulated in the first place if it
4 is going to come off before you can walk away.
5 There are products on the market that have been
6 applied and now have I think 12 or 13 years life on them.
7 There are some coatings that probably -- I don't know --
8 how long does an organic coating last? That is a good
9 question.
10 MR. HUBBARD: It depends on the atmosphere, where
11 it is going to be.
12 VOICE: What are the problems in removing sealed
13 coatings at a later date?
14 Grossman, Public Works, Canada.
15 MR. MIRICK: Basically, once you have put an
16 encapsulant on a sealed surface where you are sealing that
17 surface it makes it much more difficult to penetrate with
18 amended water or any product to give you a wet removal.
19 If you have done a real good encapsulation job and you
20 have a good eighth inch barrier of a bridging sealant over
21 the surface, unless you penetrate that, you will not get
22 your wetting agent inside to be able to remove it.
23 VOICE: May I add something to that? Why is
24 wetability so important when the room or the area that
25 you are working in presumably is totally isolated?
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The workmen are in their own special environment.
That is required by OSHA, as we well know. And if you
have air exchanging systems through vacuum, and we can
4 put these up that you can develop up to 3,000 CFM and you
5
can turn that air in that room every minute if you want
6 through vacuuming, why does it preclude that that has to
7 be wetted down during the process of removability, that
8 if the gentleman was faced with a situation that had been
9 previously encapsulated and then a decision that it had
10 to be removed, why can't he control the environment within
11 that structure to the adequacy of anybody's testing?
12 MR. MIRICK: If you are going to be able to
13 control the environment completely, I think you could probabl
14 do a dry removal. However, before you do a dry removal,
15 I understnd you have to have permission to do a dry removal,
16 and this would take -- I would have to use a type C respira-
17 tor for the) 'worker/,bin: put the worker in an environmental
18 suite.
19 There is no problem there. But if you are going
20 to use the procedures followed today with a wet removal
21 and you Have encapsulated, you have problems.
22 VOICE: Doesn't: the settling velosity change
23 when it is dry as opposed to wet?
24 MR. MIRICK: That is a definite true statement.
25 When they are dry, they take a lot longer to settle than
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1 when they are wet. But you are having air exchange systems,
2 so you are pulling those fibers out, so you shouldn't have
3 that problem if you get a complete air exchange.
4 VOICE: But you-.vwould still need permission?
5 MR. MIRICK: From what I understand, you do need
6 permission.
7 MR. DORSEY: I have not seen the air data and
8 the tests to support the idea that the heppa systems are
9 100 percent effective.
10 VOICE: We did this in an area on a complete
11 takeoff with this situation going on and it came up zero.
12 Every person there had the devices on himself. Outside
13 the air where nothing was being conducted, they had more
14 asbestos than inside.
15 EPA was there and an outside agency conducted
16 the tests, so there is efficacy to the system under proper
17 controls.
18 VOICE: Was that analyzed?
19 VOICE: Yes. I am not much for optical analysis.
20 There is a human element there that I don't completely
21 trust. Again, qualitative, who is the person, what is
22 his experience and how am I to accept his judgment as being
23 a valid one.
24 The results of the residuals have been presumably
25 captured by the air sampling. And they come up zero.
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1 Not 0.001, zero in that area.
2 MR. HUBBARD: X-ray refraction is not a good
3 technique.
4 VOICE: It is a supportable technique. You can
5 go to extremes and then it gets out of hand. So you conduct
6 the best that you can, as best as you can, pardon the pun,
7 that meets the situation, and which would indicate good
8 control factors if the results are reasonably positive.
9 MR. HUBBARD: It would have been nice for you
10 to have a few samples done with a TEM. It is expensive,
11 though.
12 VOICE: Tom Diguardson, Carbolite.
13 Mr. Dorsey, I guess this should be directed towards
14 you.
15 Are there going to be any guidelines directed
16 towards the limit of liability of the suppliers of possible
17 sealants? When we were talking just a short time ago,
18 we were saying that after the material had been coated
19 it was giving off more fibers than in the past, is there
20 going to be any guidelines as to what a manufacturer is
21 going to be liable for in terms of court cases 20 or 30
22 years down the road?
23 MR. DORSEY: Again, areas of responsibility,
24 as an agency we are attempting to promote the research
25 and dissemination of the best technical information
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1 available, but we are certainly not in the position to
2 dictate what will happen as far as your use of a product
3 in a specific situation.
4 And it would be impossible to task anyone if
5 we could do that. Under the Toxic Substances Control Act
6 we have the authority to regulate control of various
7 hazardous materials, but certainly not the legal liabilities,
8 which dictate what you can and cannot do with your product.
9 VOICE: Should we offer any guarantees or warranties
10 on the material, then?
11 MR. DORSEY: I can't answer that for you. I
12 can say as an agency if we find certain materials work
13 and are effective, we can promote certain protocols saying
14 if you follow these your chances of success are high, then
15 that is what we will do.
16 MR. HUBBARD: Your problem there is that your
17 peopli who are using your product are liable, and they are
18 going to want to -- want you to relieve them of their
19 liability, and so for that reason, not for EPA or regulation,
20 you are going to want to have some sort of guarantee.
21 VOICE: Only to the point that you meet the govern-
22 ment requirements in terms of the safety, and if it is
23 one fiber per cubic centimeter, then the guarantee would
24 presumably reach that end.
25 MR. MARTIN: That is not necessarily true at
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1 all.
2 VOICE: Then what would be the criteria to use,
3 zero?
4 MR. DORSEY: I am not sure there is a magic standarc
5 as far as exposure levels. The two fibers per cubic centi-
6 meter is a workplace standard. The OSHA act is not strictly
7 a health standard. It is a work practice standard.
8 So I don't think you can apply that as a strict
9 health standard in any situation or exposure to asbestos.
10 VOICE: What position does the government take
11 in terms of exposure; aspects of fibers that they would
12 consider safe?
13 MR. DORSEY: Well, I have a risk assessment documen
14 that I will give you a copy of. We have gone through and
15 collected voluminous numbers of researchers and documents
16 concerning health effects and levels, et cetera, and we
17 have a compilation of all of those papers.
18 I will share that with you. At this point I
19 don't think you will find that there is a magic number
20 that people feel comfortable with. I don't think you want
21 to say two fibers is safe for you.
22 VOICE: What is the government position in this?
23 MR. DORSEY: The OSHA regulation, which is the
24 only position at this point is two fibers per cubic
25 centimeter, but you have to understand how that standard
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1 is set.
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MR. MARTIN: What do you put in specifications
then after final clean up is accepted?
4 MR. DORSEY: I don't know.
5
VOICE: EPA is not going to come up with standards
£>
using PEM or SEM analysis on samples because there is too
7 much variation of sampling technique. Until they do a
round robin amongst the different labs and get levels where
9 they are basically going to be compatible with one another
within a factor of two, we will never see levels.
11 This amount, say, 100 fibers per cubic centimeter
12 is going to be acceptable or not acceptable. The only
levels that have ever come out is at Mt. Sinai.
14 Dr. Sillocoff said 45 nanograms per meter of
15 air he considered acceptably safe. That is the only place
16 where I have seen that printed.
17 But you are not going to come up with a level.
18 VOICE: Even in the removability or encapsulation,
19 there is a certain element of risk involved and they will
20 never get anything done in this regard.
21 VOICE: There is not enough information. Until
22 you get a standardization and technique, and you are dealing
23 with mostly with somebody looking under the microscope,
24 right now there is only a handfull of labs that are expert
25 in knowing what they are doing.
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1 Even those disagree with one another. In a
2 sampling of air, we had variations anywhere by a factor
3 of a thousand on the same filter.
4 VOICE: What would be the responsibility of
5 applicator or a manufacturer of the material?
6 VOICE: Use an OSHA standards because that is
7 the only thing you have.
8 MR. DORSEY: The OSHA standard does make sense.
9 it says you can't violate two fibers per cubic centimeter.
10 You are also wearing a respiration mask. With the NESHAPS
11 regulation;, that is what we said was appropriate. Nobody
12 is going to give you a magic standard.
13 It is not like we are dealing with a water
14 pollutant where we can kill 50 percent of the goldfish
15 and say that is an acceptable level.
16 Working with asbestos, I don't think we can measure
17 a level and say that you are completely save, but following
18 the OSHA work practices, using the respirators, using them
19 in the water, we have tested and we say yes, that this
20 is acceptable today.
21 That doesn't mean that the two fibers per cubic
22 centimeter is a health standard or that anybody out here
23 exposed to two fibers per cubic centimeter is necessarily
24 safe.
25 it is not a health standard. If you are working
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with asbestos, there are certain precautions that have
to be followed. The respirators, you have to be careful
about contaminating the rest of the environment, the plastic
around.
VOICE: If a facility owner comes to this conclusior
and he says I want zero after the encapsulation or removability
throughout this whole facility, how could you possibly
give him that assurance that he is going to get that?
MR. DORSEY: Zero, is that really attainable?
VOICE: Absence of any asbestos in the atmosphere
by any testing.
MR. DORSEY: Do you have controls on the ambient
environment to measure against what is happening in the
building? That might be one way to convince him that you
are at an acceptable level, because you can probably measure
asbestos if you want to in the ambient environment outside
the building.
VOICE: This is all a little confusing for me.
I hear early this morning statements saying that there
are safe areas where asbestos is present in existing facilities,
I have seen numerous specifications come out in the public
sector where they say meeting all EPA criteria, and that
is all they leave it at.
Specifications are not laid out specifically.
In comes a painting contractor bidding on these projects,
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1 my question is that if they say meeting all EPA requirements
2 and they were below two fibers per cubic centimeters, are
3 we required to go through all the preparatory procedures
4 outlined in your dockets?
5 MR. DORSEY: It is a little confusing, what you
6 have said.
7 VOICE: I have seen a lot of superintendents
8 be very confused on this same issue. They say we are treating
9 it as asbestos, but I want you to know that we do not have
10 a problem. What that opens it up to is they are looking
11 for a painting contractor to alleviate the liability, and
12 as long as they are not above two fibers per cubic centimeter
13 MR. DORSEY: As long as they have the non-friable
14 material, there is a great deal of material out there under
15 a wide range of conditions and there are degrees of friabilit]
16 There is a tremendous amount of cementitious material.
17 We will probably go through a building, survey it, if it
18 is cementitious, is in good repair, is not going to be
19 disturbed, we would say that is not a problem today.
20 YOU want to manage that material. You want to
21 periodically inspect it.
22 VOICE: What if they chose to treat that material
23 and they are below the two fibers per cubic centimeter?
24 Must they adhere to your procedures for effecting asbestos
25 containing sealing?
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1 VOICE: In other words, a plastic application
2 on the walls, the ceilings
3 VOICE: Respirators, what-not.
4 MR. DORSEY: I have not encountered that question
5 before. Ernie commented that they should actually test
6 the application, the type of sealant being used. I would
7 be conservative and recommend that they put up the plastic.
8 If there is asbestos material and they are going to spray
9 it and work with it, I would take the precautions.
10 VOICE: But they are not required. What is
11 happening in the bidding process is that you have people
12 going out there with no intention of doing that and basically
13 preparing the bids, running through all the proper preparatory
14 procedures that I feel is necessary, because you are dis-
15 turbing that with high pressure spray and increasing those
16 amounts, you are opening it up to fly-by-night organizations
17 coming in and basically treating it as they would any
18 normal ceiling structure.
19 MR. LORY: This is where air monitoring in the
20 contracts, if you air monitor the beginning of the operation
21 and finding the contractor is kicking off the asbestos
22 fiber is greater than two fibers per CC, then by OSHA
23 regulations his personnel will have to put on the proper
24 respirator.
25 VOICE: That is only required during a removal
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1 operation.
2 MR. LORY: No.
3 VOICE: If you are putting that up in a spray,
4 you are going to have one hell of a housekeeping job to
5 get this off the floor and walls. Some you can't even
6 use organic solvents to take that off. You have to sand
7 it off.
8 MR. MIRICK: I also feel you should use the plastic
9 when you are doing a barrier type system. If you are working
10 with asbestos, you should use the barrier system.
11 MR. MARTIN: The medical monitoring limit point
12 one, if they exceed point one or greater, they have to
13 maintain medical records on those people.
14 VOICE: Almost anyone will preclude that the
15 insurance company will want that. There is a lot of con-
16 tingent liability involved with this ten years hence.
17 VOICE: I think what the gentleman was saying
18 that the specifications are written too vaguely to begin
19 with, and all the guess work and procedures are left up
20 to the contractor, you would never get accurate bids out
21 of this contractor.
22 VOICE: For the project, yes.
23 VOICE: That is why it is very important to get
24 the specification prepared to the right rate and actually
25 put the procedures in the specification. The engineer
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has to do some guess work in advance and say, okay, it
o
can get this bad, I am going to specify that the contractor
o
has to do this and this way he can be pinned down, and
4 not leave anything up to contractors.
5 VOICE: I feel that is the responsibility of
6 EPA
7 MR. DORSEY: Chapter 9 of the guidance document
Q
has the minimal specs, plus the regulations are in the
9 appendices. Working with ASTM, these are being revised.
10 Many times a contractor is not aware of that suggested
11 spec in chapter 9 or they are trying to bid without including
12 the specs there, and they will have a low bid.
13 We are having problems with people that are definit
14 asbestos exposure problems out and there and corrective
15 action should be taken.
16 We are having trouble getting people to follow
17 the requirements. Some of the suggestions that we hae
18 made in our guidance documents are not law, but they are
19 highly recommended.
20 They are suggested specs in chapter 9, the guidance
21 document does detail procedures. It is very, very difficult
22 to get people to follow those specs.
23 In situations where we say you do not have to
24 encapsulate, remove, put up a barrier at this time, and
25 they still decide to take an action and encapsulate, it
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is very, very difficult to convince them that they have
2
to follow the procedures.
g
Anybody working with the material, any time you
are in proximity of this sprayed on material, you can disturb
it very easily and it can be the cementitious type.
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VOICE: How successful has the encapsulation
n
been in your getting out and taking your test samples of
0
an area that has been sprayed? Are you finding around
Q
up on top of the beam and inbetween bar joists that you
are not getting a sufficient spray?
11 MR. MIRICK: Basically, I have not seen a large
12
amount of encapsulation work. I have seen and looked at
13
some jobs, but I have not been out where I could look at
applied jobs. This is one of the further parts of the
program we would like to pursue further, that I get out
1 fi
and look at a large number of jobs to evaluate how the
17 encapsulants are being applied and used.
10
I have done a couple on field studies and a special
19 trip that I hae made for EPA.
90
VOICE: In the bridging type, the slides shown
21
this morning, the large voids that were left, is it possible
22
for fibers to sift and find their way out through these
voids and bridging agents?
MR. LORY: Again, in that cursory study we were
trying to look into the voids to see if the fibers within
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1 the voids were encapsulated or not, and according to our
o
initial observations, we could not in several cases
o
we found fibers that were not encapsulated.
In other cases we could not see well enough into
5 the voids to determine if the fibers were encapsulated
or not. Some of those voids that you saw on the slides
7 which I presented were 100 micrometers across, which is
Q
20 times greater than five micrometers, so we are talking
9 about sometimes rather large holes.
10 With respect to the five micrometer size fiber,
11 but to the human eye it is maybe a pinhole. So I can't
12 answer your question, will fibers come through those holes
13 or not.
14 These were some of the areas that we are pursuing.
15 MR. HUBBARD: In the observations that I made,
16 now I wasn't looking at the surface for holes, but in the
17 cross section that I made and I noticed a number of voids
18 through the cross section, but those voids did not make
19 a network of voids through that bridging agent.
20 Rather, they were individual voids in the material,
21 gas bubbles, whatever, that were left there. But there
22
was no network by which a fiber would find itself way out
23 in those that I looked at.
24 VOICE: A question perhaps for someone that is
25 involved in the business of removing it or encapsulating
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it. Comparative cost of encapsulating, say, a flat surface
2
like over top of a swimming pool as compared to removing
3
it. What is the cost of encapsulation? Is it 25 percent
less than removing or --
VOICE: I would say approximately that, possibly
/*
a little bit more. Usually you have a lot of angles to
overcome when you are spraying I beams. Talking about
Q
a flat surface, it is tremendous.
I think the cost factors can be significantly
higher. Percentages, I recally can't give you without
looking at a specific projection.
12
One thing I will say is that I have done projects
i s
where they have removed it and have been required to wipe
the facility down and have removed it from I beams and
15 structures and they found out a month or two later that
they had higher levels of exposure than before, why have
they not when EPA drew up the guidelines, in the removal
18
process, why do they not require once it is wiped down
19 that a sealant be applied to solidify the residual materials
90
present in the system.
21
You can never remove 100 percent of these
22
materials to my experience.
VOICE: I was going to ask this of you because
in Virginia now they are starting to do this. After they
have removed, they are coming back and spraying.
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1 VOICE: I think that is wise.
2 Pittsburgh Wheeling and Steel had the same problem.
3 It was necessary later to go back and solidify those residuals
4 MR. DORSEY: It makes sense, but many times you
5 have to apply a substitute. If you remove the sprayed
6 on material, you spray something else up there.
7 VOICE: Yes, but, for example, a building that
8 has been taken over by a new, and they do not have the
9 same requirements as the old tenant in an existing facility,
10 remodelling procedures, a lot of times that is not done.
11 MR. DORSEY: We have found problems where people
12 have not cleaned thoroughly.
13 VOICE: That is the human element, again.
14 VOICE: Do you think this would be a good
15 recommendation then in your guidelines?
16 MR. DORSEY: We are recommending that after you
17 have removed or encapsulated the asbestos that you wash
18 allk the surfaces, allow it to settle for 24 hours, go
19 through and wash again and allow it to settle again for
20 24 hours. It is two cleanings.
2i VOICE: I can get cost breakdowns on it, two
22 similar existing facilities and encapsulation.
93 VOICE: Then another question, what are the other
24 states saying as far as encapsulation or removal?
95 VOICE: It doesn't work that way. In the
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l removal processes they mentioned, in Hawaii they started
2 on that premise and now are taking a step forward rather
3 than backward and are going to encapsulate because of the
4 problem of having residual particles.
5 VOICE: I participated in the first seminar in
6 Hawaii several years ago when they were considering products
7 and I brought to his attention several products that were
8 not tested by Battelle Labs, but what I considered some
9 of the best in the field and they told me unless it is
10 approved by Battelle, we are not interested in looking
11 at it.
12 Subsequently, they were not tested and two similar
13 products were written into those state specifications.
14 And because of the human element involved in applying those
15 and the failure rates incurred, they basically reverted
16 and said thesame thing as New Jersey, that we are opting
17 for total removability.
18 MR. DORSEY: That is part of it, but I have been
19 to Hawaii, also. It is interesting, Hawaii had unique
20 problems with their schools. They started off with extensive
21 encapsulation work.
22 Then they discovered they had a number of schools
93 that had a great tendency for water damage. Another problem
94 is the high humidity in some of the areas and the rain.
95 It is very, very difficult to consider an encapsulating
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1 agent in those areas, so they backed off considering using
2 encapsulating agents.
3 I think recently they have gone back and surveyed
4 their schools. They have removed in a number of the schools
5 but they are coming back now and are going to remove in
6 a few and encapsulate a few. That has been a change within
7 the last few months.
8 VOICE: How do you apply this reasoning, and
9 there are two buildings in Philadelphia now, 36 stories,
10 all in plenums, total removability. An impossible task.
11 I You would have to have trained monkeys to get into some
12 of these areas to remove it.
13 Physically it is impossible to remove it withoutt
14 the destruction of the building. The Air Force base in
15 Ohio. Same thing. It is in a hospital unit. What could
16 you do?
17 Nothing but encapsulate. Our response to this
18 is 90 percent is better than no percent.
19 MR. DORSEY: Well, my first question would be,
20 I would check the material, the condition. The first thing
21 I would ask is what is happening in that air plenum. I
22 have been in buildings where there is a great deal of activity
23 in the air plenum and a number of construction changes
24 taking place in the air plenums.
25 In that case, I am not sure I would recommend
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1 an encapsulating agent. If they couldn't stop the activity -
2 many times you see the sprinkler systems going in, the
3 conduits are being changed, communication lines, computer
4 lines, et cetera, and it is disturbing a great deal of
5 the material in that air plenum.
6 In that I would recommend if the material is
7 basically in good condition that they not disturb it anymore,
8 If they have to modify the building, they do something
9 other than disturbing the asbestos.
10 VOICE: The other peripheral elements are already
11 in there.
12 MR. DORSEY: In many buildings I have been in
13 today they are in good condition. Is the material in good
14 condition?
15 VOICE: It has been tested that high contamination
16 release of the materials has been effected.
17 MR. DORSEY: Through what, air monitoring?
18 VOICE: Yes.
19 MR. DORSEY: What levels are they finding?
20 VOICE: A high content of asbestos in the
21 atmosphere.
22 MR. DORSEY: What are the levels?
23 VOICE: They indicate exceeds what the minimum
24 requirements were on the exposure of two fibers per CC.
25 MR. DORSEY: I would like to see that. There
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1 is a building in San Francisco with problems with asbestos
2 and a difficult building to remove. Unless the material
3 is being disturbed, we have problems violating that two
4 cubic CC standard.
5 VOICE: A graduate school in New York City,
6 60,000 square feet in their laboratory and their cafeteria.
7 I stuck my head in there and you can grab handfulls off
8 the drop ceiling. It is a plenum.
9 You can actually see it coming down and hanging
10 in streamers. You can blow and see the stuff come floating
11 down. I wouldn't even hesitate -~ if they took another
12 sampling test on that, it would be out of this world.
13 MR. DORSEY: But applying an encapsulating agent,
14 would you apply an encapsulating agent?
15 VOICE: We backed away from it. The same thing
16 with a situation in Staten Island College. You have a
17 16-story building, exactly that condition. They have been
18 trying to bypass it. They said we want to encapsulate.
19 We backed away.
20 That is being culpable, really. May I ask one
21 other question?
22 At what physical state is it all other physical
23 states in terms of size of the asbestos fiber or fibrils
24 that would be considered carcinogenic?
25 MR. DORSEY: What do you mean?
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1 VOICE: If you have in excess of five milimeters
2 or smaller and down to a dust factor below even micron
3 size, spherical in nature, say, from automobile brake linings
4 that are being released all over the country, would that
5 be considered carcinogenic, the release of this material
6 into the atmosphere?
7 MR. DORSEY: At one point there was a recommendation
8 that the fibers had to be five micron, up to a range of
9 nine, some said 12, that these are the fibers that caused
10 the cancers.
11 Today I think the researchers have changed their
12 mind that all fibers are suspect.
13 VOICE: You wouldn't be discussing a fiber in
14 the ase of an automobile braking system?
15 MR. DORSEY: I am sure that there are asbestos
16 fibers released that that could cause problems. Some studies
17 have shown with the heat and the changes, there are fibers
18 that have to be released from the brake lining. I don't
19 think those are the same fibers encountered in these building;;
20 From simulation studies, we have shown that there are
21 elevated levels.
22 If a janitor is changing a light bulb, some will
23 be disturbed. If a student is going to gouge a handfull,
24 you will see some falling off.
25 VOICE: Any physical state of the material being
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1 emitted inside of a building then would be considered
2 carcinogenic in nature, can induce --
3 MR. DORSEY: If you are talking about levels
4 VOICE: No, We are talking about the physical
5 state of the material.
6 MR. DORSEY: Yes.
7 VOICE: John Met, Plexoflec Corporation.
8 Listening to Dr. Sawyer, to answer your question,
9 his comment about a year or a year and a half ago at a
10 conference down at GSA here was that there are no safe
11 levels of fibers for carcinoma. However, he would go ahead
12 and say that there was some safe level for asbestosis,
13 which is similar to black lung disease.
14 If that helps you any, that is fine. I have
15 attended many of these things over the past three years,
16 and I wish I could say I see progress, but I really don't.
17 Where do you see the program going?
18 We have as a corporation assisted the State of
19 Virginia in writing up guidelines for encapsulation;
20 Maryland; the City of Washington, D.C.; the City of
21 Baltimore, and we end up making judgments basically at
22 some point without much help from anybody.
23 And I suspect that many people in this field,
24 including this gentleman here who is an architect is asked
25 to make judgments. I know he is reaching for answers.
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1 But there is nothing that you can sink your teeth
into. Do you feel that there is going to be a point, anyone
3 of you, that we don't talk in terms of there is a tremendous
4 variety of asbestos, we have a tremendous variety of applica-
5 tion technology, so we have a difficult time talking about
6 that.
7 We have a problem in fiber counts, not just counting
it, but in establishing a test method for counting it.
9 We have a probelm in identifying what should be removed
10 or what should be encapsulated.
11 I can keep going. Where are you going to get
12 to?
13 MR. DORSEY: I disagree with the statement that
14 we have not made any progress. But the other point that
15 is made is that we do not have all the answers. The reason
16 for this conference today is that I would love to have
17 complete guidance documents, and I would love to be able
18 to give you definitive guidelines on the use of sealants.
19 I don't have it and no one else has it. We have
20 made progress, but I don't have all the answers for you.
21 I am hoping to share what we have or don't have and share
22 the experience with you maybe to learn something.
23 Resarch is still needed. I think with the pro-
24 tocols we are going to suggest to be developed in the next
25 few years, it will be a step forward as far as testing
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1 the material and the substrata, but I don't have the answers.
As far as the program, I know twice as much about
3
this problem as I did two and a half years ago when I started
4 the program.
5 The guidance document has been widely distributed
/?
and used. Others in the business, the other programs around
7 the country, and there are people here that have conducted
8 outstanding programs, and I have learned a great deal from
9 them also.
10 Chris Williams is here from Maryland. We have
11 made advances. The guidance document is available now,
12 the one on the sealants that is available to you. It is
13 certainly a step forward.
14 I did not have that a year ago. I know more
15 about sealants now and what they do and don't do, where
16 to use them and where not to use them than I did a year
17 ago.
18 We have a system now that I think we will be
19 able to take long term air monitoring information and corro--
20 late with the findings of the study and give you that
21 information.
22 VOICE: I didn't mean to raise your ire on this.
23 I am sure you are putting up with a lot of us picking this
24 thing apart. I am trying to say yes, we do have more
25 information, we are all getting experience in this particular
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arena.
I guess what I am asking is when is -- when are
we going to see, for example, a list of sealants, encapsulants
that either somebody someplace more knowledgeable than
most of us in this room, such as this gentleman from
Georgia Tech or the U.S. Navy or Mr. Mirick from Battelle
Labs, that will say this is not a list of things that we
have tested them and we think they will work but don't
take our word for it, they are not really recommended,
but they are, so we are in a position where we can use
it, but we don't have to, but then it is a good idea, because
we spent three million dollars doing it.
MR. LORY: Could I add something? Several points
that I made earlier this morning, and I think have been
brought up several times this morning besides myself and
this afternoon, is we do not have currently, at least the
U.S. Navy does not currently have a good system for inspecting
the friable insulating material to determine if it will
accept and encapsulating agent.
MR. LORY: That is number one, is to determine
if the asbestos-containing material is actually a good
candidate for an encapsulation.
Number two is that currently we do not feel like
we have a good method of writing a type quote, unquote
a type spec in the Navy that will insure that the contractors
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1 bidding on it and that the contractor is going to do the
2 job that is acceptable for the encapsulation.
3 Number three is that we do not have a good method
4 of determining if the application is acceptable. This
5 has been mentioned several times before. One gentleman
6 said that he had an engineering group that was capable
7 of determining that.
8 Fine. He has one, maybe that is one of the few
9 in the whold world that is capable of doing that. But
10 in the Navy we are trying to standardize the system so
l1 that the 200 activities or more, that we can have a standard
12 system for inspection.
13 And so we have got the problems from the user's
14 sdde as well as I realize you people on the manufacturing
15 side as well as the contractors as well as the architects.
16 We all see the problem from different lines. We are trying
17 to put it down on paper.
18 I have met many times with various people here
19 in the Washington D.C. area, with the painters union, somebody
20 as a go-between, but with the painters' union and various
21 other people who actually apply paints, sealants, encapsulating
22 agents, and trying to find out, is there a good standard
23 technique, is there a good application technique?
24 We have yet to come up with some good information
25 that we have got some paint manufacturers saying this is
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1 the way to do it, that is the way to do it, but yet when
2 we try to put it down on paper and try to use it as a
3 generalized method, it falls short.
4 So it sounds like I got more questions that I
5 have answers, which is true, but we are pursuing these
6 areas. They are not dead in the water. They are being
7 pursued.
8 it is just that meetings like this is where we
9 are gaining our knowledge, and I would like to see more
10 contractors, possibly tomorrow, express their experience.
11 Some of them won't say anything, because they are afraid
12 that their competition sitting there in the audience is
13 going to say, hey, that is what Joe is doing and it seems
14 like we can do that, too.
15 We found this out in several other meetings where
16 architects refused to talk about their specifications and
17 talk about this and that because they don't want their
18 competition to hear.
19 But I hope you appreciate from the Navy's standpoint
20 that we are trying to gain this knowledge so that we can
21 use it in the various Navy activities around the United
22 States as well as around the world, and not try to re-
23 invent the wheel.
24 it can take an architect and engineer two to
25 three months to get up to speed to write a good, tight
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specification. That is a lot of time involved in writing
o
a good specification. The Navy has developed a guidance
document and writing a specification. It is not perfect.
4 It is a system that the engineer/architect can start out.
5 It is a stepping stone, and then they can apply it to their
own particular requirements.
7 But we have questions, we have a few answers.
But this is where we are learning as well.
9 MR. DORSEY: Let me state the purpose of this
meeting was to share our research findings and also solicit
11 ideas and suggestions from you.
12 Again, it is research, and there is a lot of
13 problems. There is a lot more work that has to be done.
14 If it were as simple as if we had the answers we could
15 give them to you, you would have the guidance documents
16 and that would be it.
17 VOICE: I would like to agree that we have come
18 a long way since the time the EPA came out with those guidance
19 documents. We used them in New Jersey and came up with
20 our own minimal specifications for removal of asbestos.
21 We also have a course for the contractors who want to do
22
the work, which, again, the U.S. EPA helps us with.
23 So I think there has been a lot of progress.
24 In the case of encapsulation, we saw the problems in
25 New Jersey a couple of years back and we decided the best
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1 thing we could do for our constituents there is at this
2 time we do not recommend the use of sealants at all, as
3 most of you are aware. Tomorrow we are gonig to have a
4 couple of panel discussions, where a lot more of the field
5 experience and other experience will be brought up.
6 I would ask a question of Mr. Lory. In these
7 five or six test cases, could you visibly tell that the
8 sealants were not doing the job, or in other words, the
9 holes that you saw in the SEM, could you see that there
10 were some problems by looking at them visibly?
11 Also, not being familiar with the actual practice
12 for SEM, these surface samples, are they small portions
13 that you cut off, are these large sections that you cut
14 off?
15 I wasn't quite clear when you look at it in the
16 SEM. I know you tried to discuss preparation earlier.
17 One question for the gentleman over there who has had a
18 lot of questions himself, in those places where you said
19 people can't physically get to it,how would they be able
20 to encapsulate it?
21 VOICE: There are extension tubes that you can
22 put in where cockroaches will go, but no human being. There
23 is too much regidity and the interface adhesion is too
24 strong for high vacuuming procedures.
25 We have done it where sheer factors would indicate
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that the surface characteristics were highly friable and
loose, but the inner-structures of it were quite solid
and we removed these from the surface and encapsulated
the rest with good success, and they have been in in excess
of 10 years and are still functioning.
VOICE: What sheer test did you use?
VOICE: The sheer material, because of, I suspect,
the atmospheric pressures, a failure of the binder has
occurred on the outward phase of the material. You can
grab a handful off, but you can't take it off the substrate
completely.
That half inch section is relatively loose and
easily removed. That obviously would preclude no application
VOICE: No, you said you did sheer tests. What
test did you use?
VOICE: The sheer phase.
MR. MARTIN: What test did you use to determine
the sheer capacity?
VOICE: You can reach up and release it from
the surface with your hand.
MR. MARTIN: It is not a standard test?
VOICE: No. There are so many constituencies
involvd with the total asbestos matrix, it is almost impossibl
to establish a standard.
MR. LORY: Number one is that the size of the
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sample is very small. The samples we use is something
probably smaller than your smallest finger, thumbnail.
It is very small.
Maybe Jim can give a better description of size.
MR. HUBBARD: Actually in the test that I used,
it depends on the scanning electron microscope. My new
one, I can put something in there three or four inches
in diameter and an inch thick and on my samples it was
the full thickness of the material, which happened to be
only a quarter of an inch, but if it had been two inches
I could have put that in there.
Different SEM's hold different sample sizes,
but the SEM is capable of magnification as low as ten times,
so that you can in effect look at large areas and magnifica-
I
tion capable of 70,000 times.
MR. LORY: Let me clarify mine, too, Jim. What
I was stating was that was the surface area, but we do --
at least that is how our technicians prepare, abot a quarter
inch in diameter, but the full depth of the material. So
we did run when possible the full depth of the material
that was present.
Your other question concerning field observation
versus SEM, a comparison, I would not want to make at the
present time any field judgments. I do not feel I am
qualified.
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1 I have seen a number of applications, but I would
2 not make any field judgments because I am not
3 VOICE: The reason I asked that is because EPA
said that field testing should be done before you decide --
5 MR. LORY: Yes, but this is exactly what I said,
6 but I am also saying that we have not come up with the
7 protocol for doing field tests. It sounds like, do it,
but we don't have the method.
9 MR. DORSEY: We are working with ASTM to develop
10 these protocols, but they will have to be tested and that
11 will have to be sometime in the future.
12 VOICE: ASTM is a test method. Who is going
13 to set the standards as to what is a pass or fail criteria?
14 ASTM writes tests and test methods. What is a pass or
15 fail on that test?
16 MR. DORSEY: But the test will be does the encapsula
17 agent successfully encapsulate the asbestos-containing
18 material.
19 VOICE: Who is going to be the specifying body
20 to say yes
21 VOICE: You have to certify it. Just like you
22 do now. Just like a federal specification. You certify
23 it. So long as you certify it, your neck is on the line.
24 VOICE: ASTM does not certify.
25 VOICE: I am saying the manufacturer will have
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1 to certify that he is in compliance with the ASTM test
2 method?
3 VOICE: The test method is just a test method.
4 Who is going to be the specifying body to say this is a
5 minimal acceptable performance on this test method?
6 VOICE: That the material is suitable for the
7 intended purpose.
8 VOICE: Right. What we are looking for in essence
9 is the four or five tests that Bill talked about earlier
10 today, he says this is the kind of test that we do and
11 this is what we are looking for, smoke generation, what
12 not. There can be an ASTM test on each of those, but is
13 there going to be a specifying body saying we want no more
14 than ten percent smoke generation or zero flame spread
15 or whatever.
16 VOICE: Who is going to be specifying that for
17 the entire industry?
18 MR. MIRICK: On those specifications, the smoke
19 generation, the toxic gases, the percentage of those and
20 the flame spread rating are based on HUD standards that
21 specify for interior spaces, that they cannot exceed these
22 points. And those are specific HUD standards and are outlined
23 in the final report.
24 VOICE: Would that be considered a class A treat-
25 ment?
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1 MR. MIRICK: A class A treatment.
2 VOICE: What about fire resistance, the effect
3 of these sealants on the fire resistant capacity of the
4 coating, the original coating?
5 MR. MIRICK: Fire rating is one of the things
6 the. ASTM committee is studying and there will be a gentleman
7 here tomorrow, I understand, from UL. He can speak to
8 that tomorrow about what they are planning to do on that.
9 The flame spread does not mean the fire classification.
10 The flame spread is a different test, strictly a single
11 test.
12 VOICE: It seems to be a practice as of late
13 that certain municipalities, various health departments,
14 I just heard it here now, it is like a cleansing of the
15 soul.
16 It is easy to advocate total removal of anything
17 because you have advocated total removal, but in reality
18 you are not going to have total removal. A lot of people
19 won't want the cost, so you are not going to hear about
2» it.
21 I don't get inquiries from New Jersey. I will
22 get them from New York State, Maryland, Kentucky, throughout
23 the United States, but not from New Jersey.
24 Does that mean everbody has taken care of asbestos
25 in New Jersey and removing it? No. People find out they
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l have a problem, find out what the cost of removal is and
2 you don't hear about it anymore. If you think you are
3 going to remove all of this, you are not going to do that.
4 As the gentleman said about the intricate patterns in the
5 building structures, nobody is going to remove that. Even
6 if you did do it with any degree of success or marginal
7 success, you would have residuals all over the place.
8 So I don't understand how one can advocate complete
9 removal.
10 VOICE: In New Jersey we have a program in my
11 program itself, that there are people who go out and do
12 inspection and when we find a problem they do correct it.
13 At least we do not have a problem with something saying
14 they are not corecting it yet.
15 Sometimes it is a localized problem. They can
16 do encapsulation. We have nothing against encapsulation
17 if it can be done.
18 Sealant used, as we said a few years back, there
19 were too many questions unanswered and we were actually
20 saving them the cost of doing it and found out two years
21 later they had to reseal it or remove it, at which time
22 the cost was much more.
23 . Some people did remove it prior to our decision
24 about the sealants. They have tried it and they have
25
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1 failed in those places. That is what we will be discussing
2 tomorrow.
3 VOICE: What would you do if you ran into a situatiojn
4 that the condition would be literally impossible to effect
5 removal?
6 Do you throw up your hands and walk away from
7 it?
8 VOICE: If nothing else works, yes. If that
9 gives you a little bit more protection, ues it. I have
10 to see a situation like that.
11 VOICE: Rutgers University took encapsulation
12 four years ago and it is working.
13 VOICE: We haven't heard about that. -
14 VOICE: Monmouth College is another, and thse
15 are all state institutions.
16 VOICE: We will have somebody from D&P also who
17 has more information.
18 VOICE: I am trying to inject into it that there
19 are insoluable situations that one doesn't have to go to
20 an expert to say how can I correct this asbestos, because
21 I can get a janitor or somebody completely informed, can
22 say it is easy- take it off.
23 if it were that simple there would be no problem
24 in the United States. The government can print money like
25 it has been. That is why we get inflation. We keep printing
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1 money and we can eliminate the problem by taking it off
2 in the United States.
3 VOICE: We use the algorithm, we use our own
4 experiences. We use all of that to decide and say well,
5 you really don't have as serious a problem. Watch it to
6 see if it becomes worse.
7 I have gone to the schools and told them you
8 don't have to remove it, but there is so much pressure
9 from the teachers and the parents that feel it should be
1° removed anyhow.
11 So they get this time to work it out into their
12 budget and we think that finally they are saving money
13 by getting rid of it.
14 If the schools are going to take it out, we heard
15 that in schools sealants are definitely not going to work.
16 VOICE: A superintendent has been appealing to
17 a school in Trenton for two solid years and got no direction
18 from them.
19 VOICE: The reason they were going to Trenton
20 was to ask for money, not for help.
21 VOICE: It got into the congressional record.
22 VOICE: I am from Alperto. Can we make this
23 more general than New Jersey?
24 MR. DORSEY: I ask that we stop the discussion
25 for now. We have moved into some areas that would be
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1 great for the panel discussion tomorrow. I would ask the
2 gentleman if they would like to convene separately
3 and discuss the problems of New Jersey, fine.
4 If you have questions, we will have a forum set
5 up tomorrow to answer that. This is the kind of exchange
6 I was expecting, and I really appreciate it. Thank you.
7 (Whereupon, at 4:55 p.m. the conference was
recessed; to reconvene at 8:30 a.m. the following day.)
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REPORTER'S CERTIFICATE
4 DOCKET NUMBER:
5 CASE TITLE:Conference on Encapsulation of Asbestos-Containing
Building Materials
6 HEARING DATE: June 8, 1981
7 LOCATION: Arlington, Virginia
8
9 I hereby certify that the proceedings and evidence
10 herein are contained fully and,accurately on the tapes and
11 notes reported by me at the hearing in the above case before
12 U.S. Environmental Protection Agency
13 and that this is a true and correct transcript of the same.
14
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16 Date: June 18, 1981
17
18
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20 Official Reporter
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