Transcript of Proceedings
 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 CONFERENCE ON ENCAPSULATION OF
 ASBESTOS-CONTAINING BUILDING
 MATERIALS
 Volume 1
 Arlington, Virginia
June 8, 1981
        Acme Reporting Company
                    1411 K
                  Washington, D» C 2000S
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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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                                                       13
     material in the field.

 2
               One of the first things we did then was to go

 g
     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

 f*
     for a base background data was one containing 35 percent

 n
     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
19
21
23
     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.


 2
               In our study we could only  look  at  one  test matrix.


 g

     So this is one of the problems you are going  to run  into


 4
     today.




               Even though these sealants  prove to be  satisfactory


 /?

     on that test matrix, they may or may  not be on the material


 7
     you are putting it on in the field.   Getting  back into


 Q

     the testing, we did then, we applied  these encapsulants


 9
     to this test matrix we used and this  is what  we did  our




     testing on.




               We tried to develop testing on this test matrix.



12
     Remember, we are talking now about the friable matrix,



13
     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


1 c*

     that would give us the most logical properties of these



17
     encapsulants.



18
               We wanted to find out how much it penetrated




     or how well it wet the surface of that material.  We developec



90
     a penetrating test, we pourted the material on the surface




     of this.  This made a good screening  test,  because some



22
     of them, if they wouldn't wet it, it  would bunch  up  on



9S
     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

2
     do it on a metal matrix,  it  is  not  true.   We  have  stone

o
     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

O/i
     about the same, but the amount  of toxic gases did  increase

95
     sometimes.



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                                                        21
 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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                                                        22
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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                                                        23
     usually lies within a quarter of an  inch  from  the top.
 o
               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
22
     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
n A
      sealant to  it.

25              What happens  afterwards  I don't  really  know.
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                                                        24
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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                                                        25
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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                                                               27
     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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1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

18

19

20

21

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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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                                                        29






              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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                                                        30
 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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                                                        31
 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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                                                       33





    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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                                                        34
    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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                                                            37
 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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                                                        38
 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
3
4    should do according to your dockets and they go ahead and
5
6    thepenetration of the sealants and is EPA going to contact
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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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1





2





3





4





5





6





7





8





9





10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





25
                                                        64
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

9
     to anyone that has an  asbestos problem.


3              VOICE:   There is one for Virginia?


4              MR.  DORSEY:   Region III has a coordinator,
5
6
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

2
     from, the federal government?

g
               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
23
     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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                                                        67
     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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                                                         70
 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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                                                         78
 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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                                                          79






 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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                                                          81
 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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                                                         82
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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                                                          83


 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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                                                         84
 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

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                                                         85






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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                                                         86
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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                                                          87
 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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                                                         88
               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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                                                         89
 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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                                                         90







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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                                                          91
               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



12



13



14



15



16



17



18



19



20



21



22



23


24



25
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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                                                         92
 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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                                                          93






 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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                                                         94
 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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                                                          95
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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 1





 2





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 7





 8





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10





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12





13





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15





16





17





18





19





20





21





22





23





24





25
                                                         96
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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                                                          97
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 .


95
               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
11

12

13

14

15

16

17

18

19

20

 21

 22

 23

 24

 25
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.)

5

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                                                       Ill






 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

 o
     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

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19

20

21

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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.

20
               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

93
     there as long as the material is there, I don't care what

24
     form.

25
               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

2
     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.
 2
               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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                                                         148
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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                                                         151
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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                                                          154
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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                                                          157
 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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                                                         158
 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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                                                          159
               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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                                                          161
 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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                                                         162






 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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                                                          163
 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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                                                          164
 1    is set.

 o
               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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                                                          166
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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                                                          167
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.


 £>

               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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                                                         189
  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




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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

15

16                                  Date:  June 18, 1981

17

18

19
20                                  Official Reporter
                                   Acme Reporting Company, Inc.
21                                  1411 E Street, N.W.
                                   Washington, D.C.  20005
22

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