APTD-1503
BACKGROUND INFORMATION
ON
DEVELOPMENT
OF
NATIONAL EMISSION STANDARDS
FOR
HAZARDOUS AIR POLLUTANTS:
ASBESTOS. BERYLLIUM, AND MERCURY
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR AND WATER PROGRAMS
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
TRIANGLE PARK, NORTH CAROLINA 27711
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APTO-1503
BACKGROUND INFORMATION
ON THE DEVELOPMENT
OF NATIONAL EMISSION STANDARDS
FOR HAZARDOUS AIR POLLUTANTS:
ASBESTOS, BERYLLIUM, AND MERCURY
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
March 1973
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The APTD (Air Pollution Technical Data) series of reports is issued by the
Office of Air Quality Planning and Standards, Off tee of Air and Water Pro-
grams, Environmental Protection Agency, to report technical data of interest
to a limited number of readers. Copies of APTD reports are available free of
charge to Federal employees, current contractors and grantees, and non-
profit organizations as supplies permit - from the Air Pollution Technical
Information Center, Environmental Protection Agency, Research Triangle
Park, North Carolina 27711 or may be obtained, for a nominal cost, from the
'National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22151,
Publication No. APTD-1503
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Table of Contents
I. INTRODUCTION 1
II. GENERAL PROVISIONS 9
A. Applicability of the Standards 9
B. Approval for Construction or Modification 9
C. Notification of Startup 9
D, Waiver of Compliance 10
E. Source Reporting 11
F. Source Sampling and Analytical Methods 12
III. ASBESTOS 16
A. Health Effects 16
B. Development of the Standard 23
C. Evaluation of Comments 27
D. Environmental Impact 35
E, Economic Impact 37
F. References 41
IV. BERYLLIUM 47
A. Health Effects 47
B, Development of the Standard 52
C. Evaluation of Comments 57
0, Environmental Impact 62
E. Economic Impact . . . . 63
F. References 65
V. MERCURY 66
A. Health Effects 66
B. Development of the Standard , 70
C. Evaluation of Comments ' 75
D. Environmental Impact 87
E. Economic Impact 90
F. References 95
iii
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List of Tables
1. List of Contributors 4
2. EPA Beryllium Emission Testing Results ... 53
3. EPA Survey of Be Alloy Operations 60
4. Emission Testing of Mercury Sources 72
5. Emissions of Mercury to the Atmosphere 73
6. Emissions of Mercury in the U.S 88
iv
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INTRODUCTION
The preamble to the National Emission Standards for Hazardous
A1r Pollutants (asbestos, beryllium, and mercury) sets forth
1) the bases for the Administrator's determination that asbestos,
/
beryllium, and mercury are hazardous, 2) the derivations of the final
standards promulgated, 3) the Environmental Protection Agency's
response to the significant comments received, and 4) the principal
revisions to the proposed standards. The purpose of this document
1s to provide a more detailed discussion of the statements made in
the preamble.
Section 112 of the Clean A1r Act requires the Administrator to
establish National Emission Standards for Hazardous A1r Pollutants.
A hazardous air pollutant 1s defined as "...an air pollutant to which
no ambient air quality standard 1s applicable and which in the judgment
of the Administrator may cause, or contribute to, an increase 1n
mortality or an increase in serious Irreversible, or incapacitating
reversible, Illness." Section 112 defines three steps to be followed
in the establishment of emission standards for such pollutants. The
required steps and the actions taken pertinent to these requirements
follow:
1. Paragraph (b)(l)(A) requires that the Administrator publish a
11st of those hazardous air pollutants for which he intends to establish
emission standards. Publication of the initial 11st was required within
90 days after the date of enactment of the Clean Air Act, as amended
(December 31, 1971). In response to this requirement, an initial 11st
1
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containing asbestos, beryllium, and mercury was published in the
Federal Register on March 31, 1971 (36 F.R. 5931).
2. Paragraph (b)(l)(B) requires that, within 180 days after an
air pollutant is included in a published list, the Administrator publish
proposed regulations establishing emission standards for such pollutant
together with a notice of public hearing within 30 days. Pursuant to
this requirement, proposed regulations for the control of emissions of
asbestos, beryllium, and mercury were published in the Federal Register
on December 7, 1971 (36 F.R. 23939), and Public Hearings were held in
New York City, on January 18, 1972 and in Los Angeles on February 15 and
16, 1972. A notice of the Public Hearings was published in the
Federal Register on December 16, 1971 (36 F.R. 23931). This hearing
notice included a planned hearing on February 1, 1972 in Kansas City, Mo.
The hearing scheduled for Kansas City was canceled as a result of a lalck
of requests to participate.
3. Paragraph (b)(l)(B) further requires that, within 180 days
after the publication of a proposed emission standard, the Administrator
prescribe an emission standard, unless he has found, on the basis of
information presented at Public Hearings, that the pollutant is clearly
not a hazardous air pollutant.
The public comment period for the proposed standards closed
on March 3, 1972. One hundred and two contributors submitted comments
on the proposed standards. The three largest groups represented were
industry (54 contributors), State and local air pollution control
agencies (20), and groups concerned over the environment (12). A list
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of these contributors 1s Included 1n Table 1. In an attempt to clarify
s
and/or evaluate the coimients received,, the Agency held numerous
discussions with Industry groups, State and local air pollution control
agencies, other Federal agencies, environmental groups, and experts in
fields relevant to the standards and to the comments received.
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Table 1
1. Allen, J.D., Puget Sound Air Quality Coalition.
2. Ballard, B.F., Manager of Environmental Control, Phillips Petroleum
Company.
3. Bettoli, P.S., Technical Director, Building, Industrial, and Floor
Products Division, GAP Corporation.
4. Cahn, D.S., Ad Hoc Committee for Machine Applied Portland Cement
Plaster.
5. Cusumano, R.D., Director, Nassau County Bureau of Air Pollution
Control.
6. DarreH, W., Director of Manufacturing, Industrial Products Division,
GAP Corporation.
7. Fenner, E.M., Director of Environmental Control, Johns-Manville
Corporation.
8. Gerson, R., Assistant Commissioner, New York City Department of Air
Resources.
9. Graham, W.D., Director, Product and Process Research, Farmland
Industries, Inc.
10. Leslie, J.C., Vice-President, Tnemec Company, Inc.
11. Lindell, K.V., Quebec Asbestos Mining Association.
12. Lunche, R.G., Chief Deputy Air Pollution Control Officer, Los Angeles Air
Pollution Control District.
13. Massachusetts Bureau of Air Quality Control, Department of Public
Health, Commonwealth of Massachusetts.
14. Megonnell, W.H., Chief, Division of Stationary Source Enforcement,
OAP, EPA.
15. Nelson, K. W., Director, Department of Environmental Sciences, American
Smelting and Refining Company.
16. Poston, H.W., Commissioner, City of Chicago Department of Environmental
Control.
17. Pundsack, F.L., Vice-President, Research and Development, Johns-Manville
Corporation.
18. Roland, R.A., Executive Vice-President, National Paint and Coatings
Association.
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19. Romer, H., New York City Department of Air Resources.
20. Rosenthal, C., Los Angeles Chapter, Sierra Club.
21. Schueneman, J.J., Director, Maryland Bureau of Air Quality Control.
22. Schulte, H.F., University of California Los Alamos Scientific
Laboratory.
23. Skillern, C.P., President, Rocky Mountain Section, American Industrial
Hygiene Association.
24. Stover, E.E., President, Welco Manufacturing Company, Inc.
25. Tate, H.L., Arizonans in Defense of the Environment, Inc.
26. Tucker, R.J., Pacific Asbestos Corporation.
27. Weil, H., Asbestos Information Association of North America.
28. Williams, B.R., W.R. Grace and Company.
29. Williams, L.F., Executive Director, Oregon Environmental Council.
30. Wilson, E.F., Assistant Health Commissioner, Department of Public
Health, City of Philadelphia.
31. Woolrich, P.P., Manager of Environmental Health and Safety, The
Upjohn Company.
32. Zimmerman, F.H., Asbestos Information Association of North America.
33. Bendix, S., Oceanic Society.
34. Blejer, H. P., Head, Bureau of Occupational Health, Southern
California.
35. Castleman, B. I., Division of Air Pollution & Industrial Hygiene,
Baltimore County Department of Health.
36. Menefee, C., Chairman of Environmental Control Council,
Hamilton County (Ohio) P.T.A.
37. Rawlings, J. W., Vice President and Product General Manager,
Mining and Metals Division, Union Carbide Corp.
38. Schaper, E. H., Vice President of Operations, Kaiser Gypsum Company, Inc.
39. Wood, J. F., Secretary, Air and Water Pollution Committee, Kansas
City Paint, Varnish, & Laquer Association.
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40. Wybourn, W. E., President, Clean Air Now.
41. Younger, E. J., Attorney General, Department of Justice, State
of California.
42. Ferrand, E. F., Director of Bureau of Technical Services, Department
of Air Resources, City of New York.
43. Troilo, A. C., Acting Director, Office of Community Goals and Standards,
U.S. Dept. of Housing and Urban Development.
44. Eisenbud, Dr. Merril, Professor of Environmental Medicine and
Director of the Laboratory for Environmental Studies at the Institute
of Environmental Medicine at New York University Medical Center.
45. Kossack, William, Coordinator, Safety and Industrial Hygiene, Lockheed
Missies & Space Co., Inc., Sunnyvale, California.
46. Powers, Martin, Brush Wellman, Inc.
47. Velten, Edmund M., Vice President, Kawecki Berylco Industries, Inc.
48. Lieben, Jan, Past Director of the Div. of Occupational Health, Pennsylvania
1055-1968.
49. Butler, James, Assistant to the President, Kawecki Berylco Industries, Inc.
50. Goldwater, L. J., Duke University Medical Center.
51. Sutter, R. C., Vice President, Diamond Shamrock Chemical Company.
52. Oppald, W. A., Vice President of Manufacturing, Chemicals Group,
01 in Corporation.
53. Emery, D. L., Production Superintendent, Aluminum Company of America.
54. North, Morgan, Morgan North Mine Management.
55. Wilding, R. E., Vice President of Manufacturing, Industrial Chemicals
Division, PPG Industries, Inc.
56, Conant, E., Manager, Environmental Control.
57. Laubusch, E. J., Assistant Secretary-Treasurer, The Chlorine Institute.
58. Hunter, J. F., Corporate Manager of Environmental Control, BASF Wyandotte
Corporation.
59. Lutkewitte, S.B., Jr., Monsanto Industrial Chemicals Corporation.
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60. Hyder, C. L., NASA - Goddard Space Flight Center, New Mexico Station.
61. Santa Clara Quicksilver Co., Almaden, California.
62. Fopp, S. M., Gordon I. Gould & Co.
63. Corcoran, R. E., State Geologist, Dept. of Geology & Mineral Industries,
State of Oregon.
64. Klascuis, Al, Southern California Section, American Industrial Hygiene
Association.
65. Smith, T. J., American Smelting and Refining Company.
66. Baily, B., New Idria Mining and Chemical Co.
67. Jackson, S. H., Monsanto Co.
68. Donald J. Sibbett, Geomet, Inc.
69. C. W. Axce, BASF Wyandotte Corp.
70. Evan E. Campbell, Univ. of California, Los Alamos Scientific
Laboratory.
71. Dr. Stanley Rokaw, Tuberculosis and Respiratory Disease Association
of California, Los Angeles, Calif.
72. Booberg, C. C., Secretary, Florida Council For Clean Air.
73. Verhalen, J. P., President, United States Mineral Products Company.
74. Kallin, F. J. Manager of Facility Environmental Control, Ford Motor
Company.
75. Johnson, W., Assistant to the Vice-President, Mining and Metals
Division, Union Carbide Corporation.
76. J. D. Stockham, Illinois Institute of Technology Research Institute.
77. Dr. R. E. Sievers, Aerospace Research Laboratories, U. S. Air Force.
78. N. W. Know!ton, Aerospace Industries Association.
79. Environmental Health Administration, State of Maryland.
80. Mr. Fergin, Geo Science, Ltd.
81. Idaho Tuberculosis & Respiratory Disease Association.
82. Robert E. Westfad, 1103 E. McDowell Rd., Suite B-7, Phoenix, Arizona
85008.
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83. Atomic Energy Commission
84. Wesley G. Bruer, Div. Mines & Geology, Sacramento, Calif.
85. Carol Menefee, Hamilton County Council of P.T.A.
86. William F. Briney, M. D., Box 88, VA Center, Prescott, Arizona 86301
87. Heart of America TB & RD Association, Kansas City, Mo.
88. Lloyd Gordon, P.O. Box 728, Cedar City, Utah 84720
89. Meier Schneider, State of Californai - Human Relations Agency, Dept.
of Public Health, Bureau of Occupational Health & Environmental
Epidemiology, P.O. Box 30327, Terminal Annex. Los Angeles,, Calif. 90030
90. Steven M. Schur, State of Wisconsin, Dept. of Justice, Madison, Wis. 53702
91. Mac Roy Gasque, M.D., Corporate Medical Director, Olin Corporation,
Stamford, Conn.
92. Mr. R. Power Praser* Vice President, GAP Corporation
93. Oscar J. Balchum, M.D., Hastings Professor of Medicine, University of
Southern California School of Medicine
94. Mr. Arthur L. Harvey, Chairman, National Air Committee, The Izaak Walton
League of America
95. , Stucco Manufacturers Association, Inc., 14006 Ventura Voulevard - Suite 204,
Sherman Oaks, Calif. 91403
96. Tauno Laine, Laine Research & Development Co., Box 3219, Fullerton,
Calif. 92634
97. A Drywall Sundries Manufacturer
98. Mr. J. B. Jobe, Executive Vice President, Johns-Manville Corporation
99. Dr. George W. Wright, Director of Medical Research, St. Luke's Hospital,
Cleveland, Ohio.
100. Dr. J. C. McDonald, McGill University, Montreal
101. E. C. Bratt, Group General Manager - Asbestos, H. K. Porter Company, Inc.
102. Hardy, H. L., M.D., Dartmouth Medical School, Hanover, New Hampshire.
8
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GENERAL PROVISIONS
The primary purpose of the general provisions is to set forth
the administrative requirements related to compliance with the
standards. Changes from the pVoposed regulations were made to improve
and clarify the general provisions. The general provisions are
summarized and explained below, with changes from the proposed
regulations noted.
Applicability of the Standards
The standards are applicable to new, modified, and existing sources.
New or modified sources must comply with the standards upon beginning
operation. Existing sources must comply within 90 days after final
promulgation of the standards, unless granted a waiver of compliance.
Approval for Construction or Modification
Prior to commencement of construction of a new source or
modification of an existing one, a source owner is required to obtain
the approval of the Administrator. The application must include,
among other information, emission estimates 1n sufficient detail to
permit assessment of their validity. The Administrator is required
to approve or deny such application within 60 days after submission
of sufficient information to evaluate the application.
Notification of Startup
The proposed regulations did not include provisions specifically
requiring new or modified sources to notify the Administrator of their
startup date before beginning operation. Such a provision, requiring
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that the Administrator be notified 30 to 60 days 1n advance of startup,
has been added.
Waiver of Compliance
Under the provisions of Section H2(c)(l)(B){11) of the Act, the
Administrator may grant existing sources waivers of compliance for up
to two years after the effective date of a standard. The conditions
for such a waiver are that such time 1s necessary to Install controls,
and that steps are taken during this period of the waiver to assure
that the health of persons 1s protected from Imminent endangerment.
The general provisions outline 1ri detail procedures for application
for waivers, and for approval or denial of such applications. There
1s no regulatory deadline for applications for a waiver of compliance.
However, continued operation 1n violation of a standard beyond the
90th day after final promulgation 1s a violation of the Act unless a
waiver has been obtained. For this reason, the owner or operator
of an existing source should submit the request within 30 days after
final promulgation of the standards.
The Administrator has no authority to waive compliance for any
period exceeding two years from the effective date of the standard.
However, the President may exempt any new, modified, or existing
source from compliance with the standards for a period of up to two
years, provided technology 1s not available to implement the
standards and the operation of such source 1s required for reasons of
national security. The President may grant exemptions for additional
periods of two years or less.
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Source Reporting
The proposed regulations required existing sources to submit
certain information to the Administrator within 30 days after the
effective date of the standards. The promulgated regulations allow
90 days for submission of the information and a form was added to the
regulations as Appendix A to help simplify the reporting. The form
also includes the information a source must submit when applying for
a waiver of compliance and a waiver of initial emission testing.
Requirements for Emission Testing
The proposed regulations required all sources of mercury and
beryllium to test their emissions within three months of the
effective date and at least once every three months thereafter.
Comments received Indicated that this provision imposed an unnecessary,
and expensive burden on a large number of small sources.
The promulgated regulations require the sources covered by the
standards to conduct an initial stack test within 90 days after final
promulgation; however, the Administrator may waive the requirement
under certain conditions. Periodic emission testing (of sources
which have already been certified to be 1n compliance) is not required
by the promulgated standards. The Administrator may require any source to
test Its emissions at any time under the authority of Section 114
of the Act. Compliance will be monitored by regular inspection of
the sources unless such Inspection indicates the need for a stack
test.
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Upon request, the Administrator may waive the Initial stack test
requirement when a source has requested a waiver of compliance, or has
submitted sufficient Information to demonstrate that 1t 1s 1n compliance
with the applicable standard. Some very small sources may be able
to demonstrate that they could not reasonably emit enough of a pollutant
to exceed the applicable standard, even 1f operating completely uncontrolled.
Sources which are granted a waiver of emission testing during the period
of a waiver of compliance will be required to demonstrate compliance
by an Initial stack test at the end of the waiver of compliance.
These changes 1n the emission testing requirements were made
primarily 1n response to comments from small beryllium users. As
revised, the requirements are applicable to beryllium and mercury
sources.
Source Sampling and Analytical Methods
Three terms are associated with determining compliance by means
of source testing: (1) reference method, (2) equivalent method, and
(3) alternative method. Reference methods are the preferred methods
of sampling and analyzing used to determine compliance. The reference
methods for beryllium and mercury are Included 1n appendix B to the
regulations. An equivalent method 1s any method of sampling and
analyzing which has been demonstrated to the Administrator's satisfac-
tion to have a consistent and quantitatively known relationship to
the reference method under specified conditions. An alternative
method 1s any method of sampling and analyzing which does not meet
all the criteria for equivalency but which can be used 1n specific
cases to determine compliance. Alternative methods may be approved
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by the Administrator for source testing; however, 1n cases where
determinations of compliance using an alternative method are disputed,
use of the reference method or Us equivalent will be required by the
Administrator.
The reference methods for beryllium and mercury have been used
successfully 1n five tests (beryllium) and seven tests (mercury),
respectively. Results from these tests have been reliable, precise,
and apparently accurate. Neither method has been submitted to
rigorous testing, although EPA has performed limited Inter!aboratory
comparisons and found the methods to have relative standard
deviations of 10% to 15%.
A number of comments were received which criticized the complexity
of the sampling procedures 1n the beryllium and mercury reference
methods (I.e. the requirements for 1sok1net1c sampling, and the use
of wet 1mp1ngers). Simpler methods could have been adopted, but only
with a drastic reduction 1n accuracy and precision. The characteristics
of the gas effluents from the affected mercury and beryllium sources
warrant the complex sampling procedures.
The reference method for beryllium 1s the only beryllium sampling
procedure 1n use that uses both a dry filter and wet 1mp1ngers.
This 1s required because significant quantities of beryllium have been
detected 1n the wet 1mp1ngers. During EPA test runs, an average of
39.9% of the total collected beryllium passed through the dry filter
and was collected 1n the wet 1mp1ngers. From this, EPA has concluded
that nonfUterable beryllium 1s being generated by many sources and
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the reference method 1s substantially more accurate than any other
procedure 1n use.
Recognizing the complexity of the beryllium reference method, an
alternative method for beryllium has been approved 1n the promulgated
regulations. The approved alternative method can take many different
configurations, each of which would probably yield somewhat different
results. The method uses equipment and techniques that are widely
accepted, albeit not necessarily as accurate or precise as those
specified 1n the beryllium reference method. The beryllium emissions
from a large number of sources covered by the standard are significantly
below the 10 gram per day emission limit. Using the alternative method
to determine the beryllium emissions from the sources whose emission
rate 1s very low will give results sufficiently below the 10 gram
per day emission limit that 1t will be clear that the sources are
complying with the standard. Where the alternative method gives
results which Indicate that the beryllium emissions from a source are
close to the 10 gram per day limit, the Administrator will require
that the reference method be used to clearly determine 1f the source
1s complying with the standard.
Many comments on the proposed methods were addressed to the
o
possible Inaccuracy of mercury analysis below concentrations of 1 yg/nr.
However, the lowest concentration measured 1n a stack test to date 1s
3 3
3700 vg/m ; the highest 1s 200,000 yg/m . While mercury analysis may
be Inaccurate at the relatively low levels encountered 1n ambient
monitoring, Its accuracy 1s adequate for stack testing to monitor
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compliance with the hazardous pollutant emission standards. The
major threat to accuracy 1n the concentration ranges generally
characteristic pf effluent streairs 1s the potential for laboratory
contamination; the reference method has been written to emphasize the
precautions which must be followed to avoid such contamination.
Mercury sampling trains were operated with three wet Impingers
and one dry filter either before or after the wet implngers. Separate
analysis of the three v/et Impingers detected mercury in a ratio of
89/10/1, with a following dry filter capturing less than 0.1% of
the total mercury collected. This suggests a collection efficiency
of 99.9% for the mercury train.
The Administrator has not approved an alternative method for
mercury because there 1s no known method available that is easier
to use than the reference method and gives reliable results. The
standard for chlor-alkall plants, which are the most difficult to
test, allows a source to follow certain housekeeping and maintenance
practices to avoid the source testing problems. This 1s explained
1n irore detail later 1n this report.
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ASBESTOS
The following Information augments that given 1n the preamble
to the promulgated regulations.
Health Effects
The proven or suspected effects of asbestos minerals on human
health Include nonmallgnant changes, such as pulmonary and pleural
flbrosls, and several types of malignancy, notably of the lung, pleura,
and peritoneum. Nearly all the positive evidence of an association
between asbestos and human disease has come from studies of occupational
groups. With few exceptions, these have consisted of workers engaged
in the mining and milling of asbestos, the manufacture of asbestos-
containing products (such as textiles and construction materials),
and the application and removal of asbestos-containing Insulating
materials.
Asbestosls, or asbetotic pneumoconiosis, was the first clearly
53
demonstrated adverse effect of asbestos in man. Many persons exposed
to asbestos dust develop asbestosis if the dust concentration is high
or the duration of exposure is long. There 1s evidence that
persons experiencing intense Intermittent exposures also are at
risk.52
A large number of studies have shown that there is an association
between occupational exposure to asbestos and a higher-than-expected
incidence of bronchogenic cancer. " Some studies have demonstrated
differences in the degree of risk among different occupationally
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exposed groups, probably related to dose, as well as to other factors.
Asbestos also has been Identified as an etlologic factor in
47
mesothelial malignancies. In 1960, there was a report of 33 cases
of pleura! mesothelloma 1n a part of South Africa Important for
croddollte mining. For all but two of the patients, the authors
discovered likely asbestos contacts two decades or more earlier.
However, only 17 of. these had had occupational exposure. The remainder
had lived near mines or had had household contacts. A large number of
studies providing additional Information supporting a relationship between
asbestos and malignant mesothelloma have been reported since 1960. " '
Included among them are reports of mesothelioma associated with non-
occupational exposures in the neighborhood of asbestos sources. ' ' '
An outstanding feature has been the long period, commonly over 30 years,
49 50
between the first exposure to asbestos and the appearance of a tumor. *
This disease may occur after a very limited exposure; furthermore, 1t
may occur at exposure levels lower than those required for prevention of
rad1olog1cally evident asbestosis.51'52'69
It has been suggested that the various types of asbestos differ
1n their relative pathogenlclty, but neither laboratory nor epidemic-
. co
logical data are conclusive on'this question. All the commercially
used forms of asbestos can produce asbestosis. In only relatively few
studies has the Incidence of malignancies been determined in groups with
exposures to a single asbestos type. Where there are data that suggest
a lower risk, as 1n the chrysotile-produdng areas of Canada • and
Italy, there are possible explanations for the difference other than
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asbestos type. The high incidence of mesothelial tumors in the
North Western Cape area of South Africa has led to the suggestion
that crocidolite is unusually hazardous, but mesotheliomas have
been rare in the Transvaal, where crocidolite is produced also. '
Although one investigator found many mesotheliomas in insulation workers
whose exposures had been largely to chrysotile and amosite, others '
have not found the incidence of mesothelioma high in areas where amosite or
chrysotile were mined and milled. All epidemiologic studies that appear
to indicate differences in pathogenicity among types of asbestos are
flawed by their lack of quantitative data on cumulative exposures, fiber
characteristics, and the presence of cofactors. The different types,
therefore, cannot be graded as to relative risk with respect to either
53
asbestosis or neoplasia.
Direct and indirect evidence that persons other than those working
directly with asbestos minerals are being exposed to asbestos is of
several types. For example, asbestos fibers can be demonstrated in
the lungs of persons not occupationally exposed. In a few geographic
areas, pathologic changes regarded as representing a reaction to
asbestos, e.g., pleural calcification, have been found in populations
with no history of occupational exposure. Asbestos fibers have been
53
shown to be present in ambient air.
Evidence is strong that most human lungs harbor thousands or
52
millions of fibers. Some of these are chrysotile asbestos, and
other types of asbestos minerals are probably there also. In most
persons not occupationally exposed to asbestos, the numbers of fibers
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are relatively small, compared with the numbers found in the occupationally
exposed.52'58 Although there appears no doubt that asbestos fibers are
present in many human lungs, there are sources of airborne fibers other
than asbestos. '* Some are probably derived from the burning of
53
leaves and plant products, such as paper, wood, and coal. Man-made
(mostly vitreous) fibers have also been identified in the sediment
:ing
53
S3
isolated from human lungs. Talc, often used generously as a dusting
powder, may contain a significant amount of tremolite asbestos fibers,
as well as chrysotile and anthophyllite. Information is sparse
concerning possible increase of fibers in lungs with increasing use
of asbestos and concerning the existence of significant differences
53
between urban and rural populations. A comparison of lung tissues
obtained in 1934 and 1967 revealed no significant increase in the
CO
proportion containing ferruginous bodies (a term used to describe
coated fibers found in lung tissues, without regard to whether the
fibers are asbestos or other material). This suggested that, despite
increasing use of asbestos in New York between 1934 and 1967, fibers of
a type producing ferruginous bodies had not been increasing at a
corresponding rate. However, there has also been a report of an increase
over each decade in asbestos bodies in samples of lungs from persons
who died in London in 1936, 1946, and 1956.58 The significance of the
presence of ferruginous bodies (and, in particular, of asbestos fibers
arid fibrils) in a large percentage of the lungs of adult urban dwellers
52
is as yet unknown. Annual world production of asbestos has risen
CO
from 50,000 tons at the turn of this century to 4,000,000 tons at
19
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present.
Studies have Implicated asbestos 1n the development of
malignancies 1n persons not occupatlonally exposed; I.e., 1n
development of diffuse mesothelloma, a tumor that 1s uncommon but
has been the subject of special attention 1n recent years. ' Many
of the mesothellomas reported 1n South Africa were attributed to household
and neighborhood exposures 1n a croc1dol1te-produc1ng area. Although
nonoccupatlonal, these exposures have been described as substantial.
Among 76 patients with mesothelloma diagnosed 1n London Hospital from
1917 to 1964, 31 (40.8%) had occupational exposures to asbestos, 9
(11.835) had a relative who worked with asbestos, 11 (14.5%) had neither
of those backgrounds but had lived within a half-mile of an asbestos
source, and 25 (32.9%) had no known contacts. Of 42 persons with
mesothellomas reported 1n Pennsylvania, 10 had worked 1n asbestos plants,
8 lived or worked close to an asbestos Industry, and 3 were members of
families that Included asbestos workers; 1n 11, no history of exposure
" 38
could be obtained, and the remaining 10 had questionable random exposures.
While no quantitative conclusions can be drawn from these studies, which
present serious methodologlc problems to the epidemiologist, they suggest
a risk 1n household contacts and 1n residence 1n the Immediate
neighborhood of an asbestos plant. There appear to be different levels
of risk 1n different types of occupational exposures, and some of
these may be reflected 1n corresponding household and neighborhood
53
experiences.
In summary: Any of the commercially used asbestos minerals,
when Inhaled 1n sufficient numbers, as 1n uncontrolled occupational
20
-------
exposures, can cause disabling flbrosls of the lungs. An
association between occupational exposures to asbestos and
bronchogenlc carcinoma has been established, but the dose-response
relation and the role of cofactors other than smoking have not been
defined. Evidence of a causal association between some but not all
exposures to asbestos fibers and diffuse malignant mesotheliomas of
the pleura and peritoneum 1s substantial. Although the different
types of asbestos differ 1n some of their biologic effects, no type
53
can be regarded as free of hazard.
The demonstration of ferruginous bodies, similar to those found
1n asbestos workers, 1n a large proportion of randomly selected lung
specimens 1n many parts of the world 1s presumptive evidence that
persons with no occupational contact may have Inhaled and retained
asbestos. Proof has come 1n some areas with positive Identification
52
of chrysotile asbestos fibers 1n the Tungs. Analyses of community
air for asbestos have been too limited to define the sources,
concentrations, and distribution of fibers 1n the environment. The
fiber concentrations that have been demonstrated in ambient air are
small, compared with those in industry, but data are inadequate for
53
definitive comparisons.
\
Industrial experience indicates that there is no likelihood of
53
significant asbestosis In nonoccupatlonal exposures. However, any
carcinogen (initiator) must be assumed, until otherwise proven, to
have discrete, dose-dependent, Irreversible and cumulative effects on
cells that are transmissible to the cell progeny. Thus, Initiation of
21
-------
malignancy following single small exposures to asbestos 1s possible,
but of a low probability. With frequent or chronic exposure and a
low dose rate, the probability of initiation of malignancy is
increased. Yet, even under optimal conditions of cell proliferation
(in the presence of promoters) these malignant transformations do not
lead to instantaneous cancer, but remain latent, often for decades.
The major potential for risk appears to lie in those with direct
occupational contacts, indirect occupational contacts, household contacts,
or residence in the immediate neighborhood of an asbestos source; and
even there, the actual risk is poorly defined. The appearance of a
gradient of effect in such groups, however, suggests that there are
53
levels of inhaled asbestos without detectable risk, so that even with respect
to neoplasms, consideration must be given to the concept that an inverse
relationship exists between dose rate and the latent period; as the
dose rate becomes progressively lower, the latent period may approach
51
or exceed the life span of exposed individuals. It is not known what
range of respirable airborne asbestos fibers will ultimately be found
to have no measurable effects on health. At present, there is no
evidence that the small numbers of fibers found in most members of
co
the general population affect health or longevity.
It is probable that the effects of asbestos inhalation are
cumulative; that is, low-level and/or intermittent exposure to
asbestos over a long time may be equally as important in the etiology
of asbestotlc disease as high-level and/or continuous exposure over a
shorter period. On the other hand, the available evidence does not
22
-------
indicate that levels of asbestos in most community air cause asbestotic
disease. Taking both these considerations into account, and in light
of the known serious effects of uncontrolled inhalation of asbestos
minerals in occupational situations and the uncertainty as to the shape
and character of the dose-response curve for man, the Administrator
has made a judgment that, in order to provide an ample margin of safety
to protect the public health from asbestos, it is necessary to control
emissions from major man-made sources of asbestos emissions into the
atmosphere, but that it is not necessary to prohibit all emissions.
In making this judgment, the Administrator relied largely on the
53
National Academy of Sciences' report on asbestos which reached
similar conclusions.
Development of the Standard
An important consideration in the development of the asbestos
standard was the former lack of satisfactory methods of sampling,
identifying, and measuring airborne asbestos, which could be used to
establish dose-response relationships. Only within recent years have
methods for determining concentrations of fibers for industrial hygiene
purposes been standardized; '»66'68 they use* samples collected or membrane
filters in which fibers are counted with phase contrast illumination.
Electron microscopic methods give a much more complete indication
of the total fiber content of the air; but when the need for fiber
identification is included, they are tedious and relatively expensive
for routine use.
23
-------
The aforementioned phase contrast Illumination method for
quantifying occupational exposures to asbestos determines the number
of fibers (longer than 5 microns) per unit volume of air sampled;
no chemical analyses are performed to verify that the fibers are asbestos,
and studies have shown that the method accounts for less thai> 5% of
the total number of fibers present in a sample. Nor is there any
evidence that only those fibers longer than 5 microns are significant
in the production of adverse health effects in humans.
It 1s impossible to specify with reasonable accuracy an
ambient concentration for asbestos which provides an ample margin
of safety to protect the public health. The needed definition of
a dose-response relationship is not available. Research and analysis
1n this area have been hampered severely by two factors: (1) The effects
of Inhaling asbestos do not usually become evident until long after
the exposure, I.e., a 30-year latent period is not uncommon; consequently,
exposure histories can only be roughly estimated; and (2) until recently,
there were no reliable techniques for measuring ambient concentrations
of asbestos; therefore, the concentrations to which the public might
be exposed remained unknown. In addition, a satisfactory means of
measuring asbestos emissions 1s still unavailable.
W. E. Davis & Associates were contracted to study the sources
of asbestos emissions. Their emissions inventory was based on
Information obtained from production and reprocessing companies,
1968 production and use statistics from the Bureau of Mines and emission
factors developed by Davis personnel. Although these emission factors
24
-------
are not based on quantitative data (I.e. emission tests), they
are considered adequate for the purpose of Identifying major sources.
The estimated emissions of asbestos from sources studied by Davis
Associates are as follows.
SOURCE CATEGORY
70
ASBESTOS EMISSIONS
1968
SOURCE GROUP
SHORT TONS
MINING AND
OTHER BASIC PROCESSING
REPROCESSING
CONSUMPTIVE USES
INCINERATION OR OTHER
DISPOSAL
NA-Data not available.
Mining and Milling
Friction Materials
Asbestos Cement Products
Textiles
Paper
Floor T1le
Miscellaneous
Construction
Brake Linings
Steel Fireproofing
Insulating Cement
TOTAL
5,610
312
205
18
15
100
28
61
190
15
25
NA
6,579
Considering this and other information, the major sources identified
were: asbestos mine-mill complexes; asbestos users, both manufacture of
asbestos-containing products and fabrication operations using asbestos
products; demolition; and spray application of asbestos products to
buildings and equipment. Although demolition was not identified as a
major source in the Davis report which was published in 1970, it was
so identified in the National Academy of Sciences' report53 which was
25
-------
published 1n 1971.
The preamble to the promulgated regulations describes the
sources covered by the promulgated standard, the changes made to the
standard between proposal and promulgation, and the factors the
Administrator considered 1n making his final judgments.
TKe proposed standard for asbestos was not given in terms of
numerical values. Instead, the standard was expressed 1n terms of
required control practices that would have limited asbestos emissions
to an acceptable level. In part, control of atmospheric emissions
would have been achieved by:
1. Utilizing industrial fabric filters to clean forced exhaust gases
from asbestos- mining, milling, and manufacturing Industries and from
fabricating operations that involve materials containing asbestos.
2. Eliminating visible emissions of particulate matter from ore
dumps, open storage areas, external conveyors, and tailing dumps
associated with asbestos mining and milling facilities as well as from
manufacturing and fabricating operations carried out with asbestos-
containing materials In areas directly open to the atmosphere.
3. Prohibiting certain applications of asbestos fireproofing
and insulation by spraying processes.
Also, Indirect atmospheric emissions of particulate matter would have
been controlled at manufacturing and fabricating sites where visible emissions
normally result from operations using asbestos materials. The maximum
allowable emissions would have been equivalent to those attained by
either ventilating an entire work space through a fabric filter or by
hooding emission sources and subsequently passing the required dust-
control air through a fabric filter.
26
-------
The promulgated standard is not given in terms of numerical
values. The provisions of the promulgated standard are limitations
on visible emissions, or, as an option in some cases, the use of
designated equipment, requirements that certain procedures be followed,
and prohibitions on the use of certain materials or of certain operations.
These provisions are included because of the impossibility at
this time of prescribing and enforcing allowable numerical concentrations
or mass emission limitations known to provide an ample margin of safety.
The alternative of no control of the sources subject to this standard
was rejected because of the significant health hazard of unregulated
emissions of asbestos into the atmosphere from the designated major sources.
Evaluation of Comments
Many representatives of industry, State and local governments,
the academic community, and environmental groups expressed their views
on the proposed standard for asbestos. All of the comments received
during the comment period were evaluated, and the proposed standard
was revised to reflect this evaluation. More comments were received
on the proposed asbestos standard than either the proposed beryllium or
mercury standards. A discussion of the evaluation of the comments and
the resulting action by EPA follows:
1. Comments received questioned the listing of asbestos as a
hazardous pollutant. While admitting the hazardous nature of
occupational exposures to asbestos, they suggested that ambient
concentrations of asbestos are not hazardous. The Administrator's
reasons for considering asbestos a hazardous air pollutant are given
in the section of this report which discusses the health effects of asbestos,
27
-------
2. Some of the comments received after proposal of the standard
suggested that the wearing of brake linings is a major source of asbestos
emissions. As the Davis report indicates, wear from asbestos brake
linings does generate a substantial amount of asbestos emissions, primarily
in urban areas. This was not considered a major source of asbestos
emissions because there is evidence ' * which shows that only a
very small proportion of the asbestos worn from brake linings is
released as free fiber; the remainder is converted into some other
nonfibrous mineral, i.e., the material is no longer asbestos, as a
result of the extreme temperatures generated on the lining surface.
3. Comments received indicated that the asbestos standard should
be a numerical emission standard. Some of the difficulties of
this approach are outlined in the section of this report on development
of the standard.
It has been determined not to be practicable, at this time, to
establish allowable numerical concentrations or mass emission limits
for asbestos. Satisfactory means of measuring ambient asbestos
concentrations have only recently been developed, and satisfactory
means of measuring asbestos emissions are still unavailable. Even if
satisfactory means of measuring asbestos emissions did exist, the
previous unavailability of a satisfactory means of measuring ambient
levels of asbestos makes it impossible to estimate even roughly the
quantitative relationship between asbestos-caused illness and the
doses which caused those illnesses. This is a major problem, since
some asbestos caused illnesses have a 30-year latency period.
28
-------
EPA considered the possibility of banning production,
processing, and use of asbestos or banning all emissions of
asbestos to the atmosphere but rejected these approaches for the
following reasons: (1) The available evidence relating to the
health hazards of asbestos does not suggest that such prohibitions are
necessary to protect public health; rather the evidence now available
suggests that there are levels of asbestos exposure that will not be
associated with any detectable risk, although these levels are not
known. (2) The difficulty of measuring "zero" emissions of any
pollutant, together with the presence of asbestos in many commonly
used materials, make such prohibitions impracticable. Either approach
would result in the prohibition of many activities which are extremely
Important. Such prohibitions would mean, for example, that demolition
of any building containing asbestos fireproofing or insulating materials
would have to be prohibited as would the use of materials containing
even trace amounts of asbestos which could escape into the atmosphere.
4. Many comments questioned the need for regulating mine-mill
complex emissions other than those from process gas streams. Evaluation
of these comments led to revisions in the standard.
As applied to mines, the proposed standard would have limited
the emissions from drilling operations and prohibited visible emissions
of particulate matter from mine roads surfaced with asbestos tailings.
The Bureau of Mines has prescribed health and safety regulations
(30 CFR 55.5) for the purpose of protecting life, the promotion of
health and safety, and the prevention of accidents in open pit metal
29
-------
and nonmetallic mines. As related to asbestos mines, these regulations
prohibit persons working in a mine from being exposed to asbestos
concentrations which exceed the threshold limit value adopted by the
64
American Conference of Governmental Industrial Hygienists. The regu-
lations specify that respiratory shall not be used to prevent persons from
being exposed to asbestos where environmental measures are available.
For drilling operations, the regulations require that the holes be
collared and drilled wet. The regulations recommend that haulage
roads, rock transfer points, crushers and other points where dust
(asbestos) is produced sufficient to cause a health or safety hazard
be wetted down as often as necessary unless the dust is controlled
adequately by other means. In the judgment of the Administrator,
implementation of these regulations will prevent asbestos mines from
being a major source which must be covered by the promulgated standard.
Furthermore, the public is sufficiently removed from the mine
work environment that their exposure should be significantly less than
that of the workers in the work environment. Accordingly, the promulgated
standard does not apply to drilling operations or roadways at mine
locations.
For asbestos mills, the proposed standard would have applied
to ore dumps, open storage areas for asbestos materials, tailings dumps,
ore ckyers, air for processing ore, air for exhausting particulate
material from work areas, and any milling operation which continuously
generates in-plant visible emissions. The promulgated standard prohibits
visible emissions from any part of the mill, but it does not apply to
30
-------
dumps of asbestos tailings or open storage of asbestos ores. The
Bureau of Mines' regulations previously referenced and regulations
issued by the Occupational Safety and Health Administration (20 CFR
1910.93a) protect workers from the hazards of air contaminants in
the work environment. The Occupational Safety and Health Administration
regulations were promulgated on June 7, 1972. The regulations are
intended to protect the health of employees from asbestos exposure by
means of engineering controls (i.e. isolation, enclosures, and dust
collection) rather than by personal protective eguipment. It is the
judgment of the Administrator that measures taken to comply with the
Bureau of Mines and Occupational Safety and Health Administration
regulations to protect the health of persons who work in proximity
to dumps and open storage areas will prevent the dumps and storage
areas from being major sources of asbestos emissions.
5. Other comments were directed at the proposed provisions
for manufacturing and fabricating uses of asbestos. The proposed
standard would have applied to buildings, structures or facilities
within which any fabricating or manufacturing operation is carried
on which Involves the use of asbestos materials." Comments received
on the proposed standard indicated that the requirements for fabricating
and manufacturing operations were confusing. Much of the confusion
was created by the use of terms such as "any," "continuously," and
"forced gas streams." The promulgated standard is more definitive
as to applicability of the provisions. The promulgated standard
prohibits visible emissions from the nine manufacturing operations
31
-------
which, 1n the judgment of the Administrator, are major sources of
asbestos. The promulgated standard does not cover fabrication
operations. Of all fabrication operations, only those operations
at new construction sites are considered to be major sources of
asbestos emissions. The Occupational Safety and Health Administration
regulations specify that all hand- or power-operated tools (i.e. saws,
scorers, abrasive wheels, and drills) which produce asbestos dust be
provided with dust collection systems. In the judgment of the Administrator,
implementation of these regulations will prevent fabrication operations
from being a major source which must be covered by the promulgated
standard.
The nine manufacturing sources which are covered by the promulgated
standard are listed below:
Manufacture of Asbestos Textiles
Manufacture of Asbestos Cement Products
Manufacture of Asbestos Fireproofing and Insulation
Manufacture of Asbestos Friction Products
Manufacture of Asbestos Paper
Manufacture of Asbestos Floor Tile
Manufacture of Paints, Coatings, Caulks, Adhesives, and Sealants
Manufacture of Plastics and Rubber Materials
Manufacture of Chlorine
6. Some comments suggested that a complete ban on open spraying
of asbestos-containing materials unnecessarily restricted a wide variety
of products, some of which contain trace amounts of asbestos.
32
-------
Evaluation of the comments led to revisions of the standard.
The proposed standard would have prohibited the spraying of any
material containing asbestos on any portion of a building or structure,
prohibited the spraying of any material containing asbestos in an
area directly open to the atmosphere, and limited emissions from
all other spraying of any material containing asbestos to the amount
which would be emitted if specified air-cleaning equipment were used.
The proposed standard would have: (1) prohibited the use of materials
containing only the trace amounts of asbestos which occur in numerous
natural substances, (2) prohibited the use of materials to which
very small quantities of asbestos are added in order to enhance their
effectiveness, and (3) prohibited the use of materials in which the
asbestos is strongly bound and which would not generate particulate
asbestos emissions. The promulgated standard applies to those uses
of spray-on asbestos materials which could generate major emissions
of particulate asbestos material. For those spray-on materials used
to insulate or fireproof buildings, structures, pipes and conduits,
the standard l^nits the asbestos content to no more than one percent.
Materials currently used contain from 10 to 80 percent asbestos. The
intent of the one percent limit is to ban the use of materials which
contain significant quantities of asbestos, but to allow the use of
materials which would (1) contain trace amounts of asbestos which
occur 1n numerous natural substances, and (2) include very small
quantities of asbestos (less than one percent) added to enhance the
material's effectiveness. Although a standardized reference method
33
-------
has not been developed to quantitatively determine the content of
asbestos 1n a material, there are acceptable methods available,
based on electron microscopy, which Independent laboratories have
developed. Determining the asbestos content of a material with these
methods c.osts approximately $300, and the results are accurate within
plus or minus fifty percent; these limits on accuracy were taken Into
account 1n establishing the one-percent limitation.
7. One corrment questioned the practicability and enforceablHty
of a no visible emissions provision for demolition; such a provision
would, 1n effect, prohibit repair or demolition 1n many Instances.
Evaluation of the comment confirmed its validity, and the standard
was revised.
The promulgated standard specifies certain work practices which
must be followed when demolishing certain buildings or structures. The
standard covers Institutional, Industrial, and commercial buildings
or structures, Including apartment houses having more than four
dwelling units, which contain friable asbestos material. This coverage
53
1s based on the National Academy of Sciences' report which states
"In general, single-family residential structures contain only small
amounts of asbestos Insulation. Demolition of Industrial and commercial
buildings that have been flreproofed with asbestos-containing materials
will prove to be an emission source 1n the future, requiring control
measures." Apartment houses with four dwelling units or less are
considered to be equivalent to single-family residential structures.
The standard requires that the Administrator be notified at least 20
34
-------
days prior to the commencement of demolition.
8. Other comments indicated that disposal of asbestos wastes
should be covered by the standard. These comments were evaluated
and rejected.
Consideration was given to including provisions in the standard
requiring proper disposal of the asbestos material generated during
demolition and collected in control devices used to comply with the
requirements of this standard. It was decided that this was
not necessary because the Occupational Safety and Health Administration
regulations [29 CFR 1910.93a (h)] include housekeeping and waste
disposal requirements. These regulations require that any asbestos
waste, consigned for disposal, be collected and disposed of in sealed
impermeable bags or other closed, impermeable containers.
Environmental Impact
The asbestos standard will substantially reduce asbestos
emissions. A five-year projection of estimated control costs and
74
emission reductions was prepared for EPA in 1972. The estimated
emissions for 1970 and projected reductions for 1977 are as follows:
Source
Category
Milling Products
Asbestos Cement
Floor Tile
Friction Material
Asbestos Paper
Asbestos Textiles
Number of Plants
(1970)
9
48
18
30
29
34
1970
Current
Control
3,860
206
101
314
15
20
Emissions
1977
Current
Control
5,440
290
142
441
21
28
(tons/year)
1977
Meeting
Standard
218
58
28
88
2
15
-------
The number of affected sources and the amount of emission reduction for
demolition, spray application, and other manufacturing sources has
not been estimated.
Two potentially adverse environmental effects of the asbestos
standard have been Identified as:
1. The asbestos materials which will be collected 1n control
devices and generated during demolition will have to be disposed of
or recycled.
2. Materials, such as mineral wool, fiberglass, and ceramic
wool, will be substituted for asbestos presently contained 1n spray-
applied f1reproofing and Insulating materials.
Dry asbestos-containing particulate matter captured by fabric filters
1s expected to account for the major portion of the Increase 1n
asbestos-containing wastes; the Increased usage of wet collectors
which would generate larger quantities of asbestos-containing sludge
1s anticipated to be minimal. A preliminary evaluation Indicates
that 1n some manufacturing operations a major portion of the asbestos
materials collected by fabric filters are either recycled to the process
or can be marketed for other uses. For example, one asbestos textile
mill recycles large quantities of longer-fiber asbestos for process
use and sells more than 90 percent of the remaining collected materials
to a brake lining manufacturer. Consequently, a significant portion
of the Increased quantities of "waste" asbestos-containing materials
which will result from the Implementation of the standard will not
require disposal. Proper solid and liquid waste management practices
36
-------
are available which can ensure the environmentally acceptable
ultimate disposal of asbestos wastes. Occupational Safety and
Health Administration regulations [29 CFR 1910.93a(h)] require that
manufacturing wastes which contain dry, unbound asbestos be disposed
of 1n sealed, Impermeable baps or other closed, Impermeable containers
to control potential airborne asbestos emissions, The possible
contamination of ground water supplies with asbestos from the landfill
disposal of asbestos sludges and dry wastes has not been Identified
as a potential problem; the asbestos materials will be disposed
of 1n Impermeable containers and even 1f they were not, there 1s no
evidence which Indicates that such materials would be carried to
surface or underground water supplies,
The substitution of mineral wool, ceramic wool, and fiberglass
for asbestos 1s not known to be a problem. There 1s no evidence
that these materials cause health effects 1n the concentrations found
In occupational or ambient environments,
Economic Impact
Although the standard was not based on economic considerations,
74
EPA 1s aware of the Impact and considers 1t to be reasonable. Costs
among the various sources covered by the standard are variable.
Although the standard may adversely effect some Individual plants
or companies which are marginal operations, It appears that such
effects will be minimal and the Impact to the asbestos Industries
as a whole will not be large.
Approximately 15 percent of the asbestos consumed 1n the
United States 1s obtained from domestic production and 85 percent
37
-------
from Imports. Canada, with Quebec having the world's largest deposit,
provides about 90 percent of the asbestos imports and the Republic of
South Africa most of the rest. U. S. production has tripled since
1956, representing a growth rate of about 7 percent per year. Domestic
consumption is growing at 3 percent per year.
The basic processing of domestic asbestos ores is carried out by
nine companies owning nine mine-mill operations with production
capacities ranging from 200 to 65,000 tons per year.
Although mining is not covered under the standard, the associated
milling operations are subject to controls. Milling facilities are
located at or within 60 miles of the mine site with the exception
that the small-volume North Carolina output is transferred to a mill
in Baltimore, Maryland. The estimated total investment cost of $400,000
required of the nine existing mills for compliance with the standard
yields an annualized cost range of $0.50 to approximately $6.00 per
ton, with the average being approximately $1.00 per ton and the maximum
figure applying to facilities accounting for less than 5 percent of
domestic production. These costs represent a range of less than 1
to 7 percent of the average selling price per short ton of domestic
asbestos in 1969 of $86.22, F.O.B. mine. Investment outlays range
from $3,000 for a partially controlled mill of 200 ton/year capacity
to $225,000 for a partially controlled mill of 65,000 ton/year capacity.
Because asbestos prices are determined in the world market and
U. S. production supplies only a small fraction of the U. S. consumption,
it is expected that domestic plants will in general not be able to pass
on their higher costs in the form of price increases. However, no plants are
38
-------
expected to shut down due solely to the cost burdens Imposed by the
standard.
For the major categories of industries that manufacture products
containing asbestos, I.e., producers of asbestos-cement products,
asbestos-containing floor tile, asbestos-reinforced friction materials,
asbestos paper, and asbestos textiles, a total additional investment
of about $5,000,000 is estimated to be required to bring existing,
partially controlled sources into compliance with the standard. An
annual 1zed cost of 0.4 percent of the output product value will be
requlretl. In terms of alterations in product price, there would result
an average Increase of 0.4 percent; the most significant increase would
be 5.2 percent for asbestos textile products.
For the categories of manufacturers that process small quantities
of commercial asbestos, e.g., producers of paints and coatings, a total
additional investment of approximately $1,500,000 will be required to
bring existing sources into compliance with the standard. This represents
an annual1zed cost of less than 1 perc°nt of product vclue.
The use of asbestos in spray-applied fireproofing and insulation
represents less than 0.5 percent of the annual domestic consumption of
asbestos. No major Impact on the price of asbestos or upon producers
of asbestos would result from the limitations on asbestos content of
spray-applied asbestos fireproofing and insulation. Further, increased
costs for substitute materials, available or scheduled for introduction
in the near future, range from zero to a maximum of 15 percent. The
use of these materials, some of which are asbestos-free, does not
require new equipment or extensive retraining of personnel.
39
-------
It 1s estimated that the wetting and removal of asbestos fireproofing
and pipe insulating materials prior to the demolition of buildings or
structures will increase demolition costs by less than 8 percent. Based
on a rough estimate that 4,000 apartment buildings and 22,000 commercial
or industrial buildings are demolished annually at a total cost of
approximately $550 million, compliance with the standard would cost
about $45 million. Further, since demolition costs represent a minor portion
(probably less than 10 percent) of the overall costs of rehabilitation
and construction projects, the increase in demolition costs as a result
of the promulgated asbestos standard is insignificant.
40
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3. Dreessen, W. C., J. M. Dallavalle, T. I. Edwards, J. W. Miller,
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4. McDonald, S.: History of Pulmonary Asbestosis. Brit. Med. J.,
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41
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15. Elwood, P. C., and A. L. Cochrane: A Follow-up Study of Workers
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16. Enter!1ne, P. E. Mortality Among Asbestos Product Workers 1n
the United States. Ann. N. Y- Acad. Scl., 132. 156-165, 1965.
17. Enter]1ne, P. E., and M. A. Kendrlck: Asbestos-dust Exposures at
Various Levels and Mortality. Arch. Envlr. Health, 15, 181-186,
1967. ~"
18. Gloyne, S, R.: Pneumonconlosls: A H1stolog1cal Survey of
Necropsy Material 1n 1,205 Cases. Lancet, I, 810-814, 1951.
19. Isselbacher, K. J., H. Klaus, and H. L. Hardy: Asbestosls and
Bronchogenlc Carcinoma: Report of One Autopsled Case and Review
of the Available Literature. Am. J. Med., ]£, 721-732, 1953.
20. Jacob, G., and M. Anspach: Pulmonary Neoplasla Among Dresden
Asbestos Workers. Ann. N. Y. Acad. Sd., 132, 536-548, 1965.
21. Klelnfeld, M., J. Messlte, and 0. Kooyman: Mortality Experience
1n a Group of Asbestos Workers. Arch. Envlr. Health, 15, 177-180,
1967. ~"
22. Knox, J. F., R. S. Doll, and I. D. Hill: Cohort Analysis of
Changes 1n Incidence of Bronchial Carcinoma 1n a Textile Asbestos
Factory. Ann. N. Y. Acad. Sd., 132, 526-535, 1965.
23, Knox, J. F., S. Holmes, R. Doll, and I. D. H111: Mortality frp,
Lung Cancer and Other Causes Among Workers 1n an Asbestos
Textile Factory. Brit, J. Ind. Med., 25,, 293-303, 1968.
24. Lleben, J.: Malignancies 1n Asbestos Workers. Arch. Envlr.
Health, H, 619-621, 1966.
25. Lynch, K. M., and W. A. Smith: Pulmonary Asbestosls, III.
Carcinoma of Lung 1n Asbestos-s111cos1s. Am. J. Cancer, 14,
56-64, 1935.
26. Mancuso, T. F., and A. A. El-Attar: Mortality Pattern 1n a Coh
of Asbestos Workers. J. Occup. Med., 9_, 147-162, 1967.
27. McDonald, J. C., A. D. McDonald, G. W. G1bbs, J. S1em1atyck1,
and C. E. RossHer: Mortality In the Chrysotlle Asbestos Mines
and Mills of Quebec. Arch. Envlr. Health, 22., 677-686, 1971.
28, Merewether, E. R. A.: Asbestosls and Carcinoma of the Lung. In:
Annual Report of the Chief Inspector of Factories for the Year
1947. London: H. M. Stationary Office, 1949, 79 pp.
42
-------
29. Newhouse, M. L.: A Study of the Mortality of Workers 1n an
Asbestos Factory. Brit. J. Ind. Med., 26, 294-301. 1969.
30. Sellkoff, I. J., J. Churg, and E. C. Hammond: Asbestos
Exposure and Neoplasla. JAM A, 188. 22-26, 1964.
31. Borow, M., A. Cons ton, L. L. Llvornese, and N. Schalet:
Mesothelloma and Its Association with Asbestosls. JAMA, 201,
587-591, 1967.
32. Elmes, P. C., W. T. E. McCaughev, and 0. L. Wade: Diffuse
Mesothelloma of the Pleura and Asbestos. Brit. Med. J., 1,
350-353, 1965.
33. Elmes, P. C., and 0. L. Wade: Relationship between Exposure to
Asbestos and Pleural Malignancy 1n Belfast. Ann. N. Y. Acad.
Sc1., 132. 549-557, 1965.
34. Entlcknap, J. B., and W. N. Smlther: Peritoneal Tumors 1n
Asbestosls. Brit. J. Ind. Med., 21., 20-31, 1964.
35. Fowler, P. B. S., J. C. Sloper, and E. C. Warner: Exposure to
Asbestos> and Mesothelloma of the Pleura. Brit. Med. J., 2,
211-213, 1964.
36. Hammond, E. C., I. J. Sellkoff, and J. Churg: Neoplasla Among
Insulation Workers 1n the United States with Special Reference
to Intra- abdominal Neoplasla. Ann. N. Y. Acad. Sc1. 132, 519-525
1965.
37. HouHhane, D. O'B.: The Pathology of Mesothellomata and an
Analysis of Their Association with Asbestos Exposure. Thorax,
19, 268-278, 1964.
38. Ueben, J., and H. Plstawka: Mesothelloma and Asbestos Exposure
Arch. Envlr. Health, 1, 559-563, 1967.
39. Mann, R. H., J. L. Grosh, and W. M. O'Donnell: Mesothelloma
Associated with Asbestosls. Cancer, 1j9, 521-526, 1966.
40. McCaughey, W. T. E., 0. L. Wade, and P. C. Elmes: Exposure
to Asbestos Dust and Diffuse Pleural Meso the Homes. Brit.
Med. J., 2., 1397, 1962.
41. McDonald, A. D., A. Harper, 0. A. El-Attar, and J. C. McDonald:
Epidemiology of Primary Malignant Mesothellal Tumors 1n Canada.
Cancer, 26,, 914-919, 1970.
42. Newhouse, M. L., and H. Thompson: Epidemiology of Mesothellal
Tumors 1n the London Area. Ann. N. Y. Acad. Sd., 132. 579-588, 1965.
43
-------
43. Owen, W. 6.: Mesothelial Tumors and Exposure to Asbestos Dust.
Ann. N. Y. Acad. Sci., 132, 674-679, 1965.
44. Selikoff, I. J., J. Churg, and E. C. Hammond: Relation Between
Exposure to Asbestos and Mesothelioma. New Eng. J. Med., 272,
560-565, 1965.
45. Wright, G. W.: Asbestos sind Health in 1969. Am. Rev. Resp. Dis.,
100, 467-479, 1969.
46. Selikoff, I. J., E. C. Hammond, and J. Churg: Asbestos Exposure,
Smoking, and Neoplasia. JAMA, 204, 106-112, 1968.
47. Wagner, J. C., C. A. SI eggs, and P. Marchand: Diffuse Pleural
Mesothelioma and Asbestos Exposure in the North Western Cape
Province. Brit. J. Ind. Med., 17., 260-271, 1960.
48. Champion, P.: Two Cases of Malignant Mesothelioma after Exposure
to Asbestos. Am. Rev. Resp. Dis., 103, 821-826, 1971.
49. Selikoff, I. J., and E. C. Hammond: Environmental Epidemiology.
III. Community Effects of Nonoccupational Environmental Asbestos
Exposure. Am. J. Pub. Health, 59_, 1658-1666, 1968.
50. Wagner, J. C.: Epidemiology of Diffuse Mesothelial Tumors:
Evidence of an Association from Studies in South Africa and the
United Kingdom. Ann. N. Y. Acad. Sci., 132, 575-578, 1965.
51. National Institute for Occupational Safety and Health: Occupational
Exposures to Asbestos (Criteria for a Recommended Standard).
Washington, U. S. Department of Health, Education and Welfare
(PHS, HSMHA), 1972 (HSM 72-10267).
52. Selikoff, I. J., W. J. Nicholson, and A. M. Langer: Asbestos
Air Pollution. Arch. Envir. Health, 25, 1-13, 1972.
53. National Academy of Sciences: Asbestos (The Need for and
Feasibility of Air Pollution Controls). Washington, National
Academy of Sciences, 1971, 40 pp.
54. Vigil am', E. C., I. Ghezzi, P. Maranzana, and B. Permis:
Epidemiological Study of Asbestos Workers in Northern Italy.
Med. Lav., 59_, 481-485, 1968.
55. Gilson, J. C.: Health Hazards of Asbestos: Recent Studies on
Its Biological Effects. Trans. Soc. Occup. Med., 1_6_, 62-64, 1966.
56. Sluis-Cremer, G. K.: Asbestosis in South African Asbestos Miners.
ETvir. Res., 3, 312-319, 1970.
44
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57. Webster, I.: Asbestos Exposure in South Africa. In:
Pneumonconiosis: Proceedings of the International Conference,
Johannesburg, 1969, H. A. Shaniro, Ed. Cape Town: Oxford
University Press, 1970, pp. 209-212.
58. Selikoff, I. J., and E. C. Hammond: Asbestos Bodies in the New
York Population in Two Periods of Time, ibid., pp. 99-105.
59. Cralley, L. J., R. G. Keenan, and W. S. Lainhart: Source and
Identification of Respirable Fibers. Am. Ind. Hyg. Assn. J.,
29, 129-135, 1968.
60. Gross, P., R. T. P. deTraville, E. B. Toler, M. Kaschak, and M. A.
Babyak: Experimental Asbestosis: The Development of Lung Cancer
in Rats with Pulmonary Deposits of Chrysotile Asbestos Dust. Arch,
Envir. Health, 15, 343-355, 1967.
61. Newhouse, M. L., and H. Thompson: Mesothelioma of Pleura and
Peritoneum following Exposure to Asbestos in the London Area.
Brit. J. Ind. Med., 22, 261-269, 1965.
62. Clifton, R. A.: Asbestos. In: U. S. Department of the Interior,
Bureau of Mines MINERALS YEARBOOK - 1970, Vol. I. Washington,
U. S. Government Printing Office, 1972, pp. 195-203.
63. British Occupational Hygiene Society: Hygiene Standards for
Chrysotile Asbestos Dust. Ann. Occup. Hyg., lj_, 47-49, 1968.
64. American Conference of Government Industrial Hygienists:
Threshold Limit Values of Airborne Contaminants and Physical
Agents with Intended Changes Adopted by ACGIH for 1971.
Cincinnati, ACGIH, 1971, 82 pp.
65. Federal Register: 37 F. R. 11318, June 7, 1972.
66. Edwards, G. H., and J. R. Lynch: The Method Used by the U. S.
Public Health Service for Enumeration of Asbestos Dust on
Membrane Filters. Ann. Occup. Hyg., 11, 1-6, 1968.
67. Thompson, R. J., and G. B. Morgan: Determination of Asbestos in
Ambient Air. Presented at International Symposium on Identifica-
tion and Measurement of Environmental Pollutants, Ottawa, June
14-17, 1971.
68. Subcommittee on Asbestosis of the Permanent Commission and
International Association on Occupational Health: Evaluation
of Asbestos Exposure in the Working Environment. J. Occup.
Med., 14., 560-562, 1972.
45
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69. Murphy, R. L., B. W. Levlne, F. J. AT Bazzaz, J. J. Lynch, and
W. A. Burgess: Floor Tile Installation as a Source of Asbestos
Exposure. Am. Rev. Resp. .D1s., 104, 576-580, 1971.
70. National Inventory of Sources and Emissions - Cadmium, Nickel and
Asbestos. Report by W. E. Davis & Associates under contract to
Department of Health Education and Welfare (Contract No. CPA
22-69-131). February 1970.
71. Hatch, D.: Possible Alternatives to Asbestos as a Friction
Material. Ann. Occup. Hyg., 13, 25-29.
72. Luxon, S.: Technical Implementation of the New Asbestos Regulations,
Ann. Occup. Hyg., ^3, 23-24.
73. Lynch, J. R.: Brake Lining Decomposition Products. JAPCA, Vol. 18,
No. 12, 824-826.
74. Research Triangle Institute: Comprehensive Study of Specified A1r
Pollution Sources to Assess the Economic Impact of Air- Quality
Standards - Asbestos, Beryllium, Mercury. Report prepared under
contract to the Environmental Protection Agency (Contract No.
68-02-0088). August 1972.
-------
BERYLLIUM
The following Information augments that given 1n the preamble
to the promulgated regulations.
Health Effects
Beryllium and many of Its compounds are considered to be among
the most toxic and hazardous of the nonradioactive substances in
Industrial use. The proven effects of airborne beryllium materials
on human health Include both acute and chronic Inhalation effects
123
as well as skin and conjunctlval effects, • • and there Is limited
evidence that an association exists between the Immune status of the
1311
host and Its vulnerability to beryllium Inhalation. ' •
The first such disease to be recognized was an acute Inflammatory
reaction 1n the respiratory tract of man. Only water-soluble compounds
of beryllium are thought to cause this Inflammatory response in the
respiratory tract; however, many relatively Insoluble beryllium compounds
and the pure metal, in addition to the soluble compounds, are
o
suspected as potential causes of acute pneumonitis.
The course of acute beryllium-Induced pneumonitis depends upon
exposure levels. Overwhelming acute pneumonitis, progressing to
pulmonary edema and death, may result from Inhalation of heavily
contaminated air. Exposures to lower concentrations of beryllium
2
(100-400 vg/m ) may cause an Illness with Insidious onset,
characterized by non-productive cough, substernal pain, fatigue,
238
weight loss, ' • and the subsequent appearance, one to three weeks
after Initial symptoms, of a hazy chest radlographic pattern.3
47
-------
Provided that the beryllium exposure 1s terminated, complete
2 3
recovery usually occurs 1n one to four weeks. The acute form
of beryllium disease has been observed, with a single reported
exception, only 1n persons with occupational beryllium exposures.
The chronic form of beryllium disease, with a sometimes long
3
latent period that renders difficult the retrospective calculation
of the nature and magnitude of the exposure, 1s a progressive granulomaf
disease, located 1n the Interstitial tissues and the alveolar walls
i o "?
of the lung, ' ' that develops not only 1n a significant percentage
3
of acute cases, but has been observed 1n Individuals who never have
3
been employed 1n a beryllium Industry. Symptoms of chronic beryllium
disease are similar to those of the acute disease and Include shortness
of breath, non-productive cough, chest pain, fatigue, and weight
3 13
loss. * However, unlike the acute disease, the chronic form may have
a prolonged progressive course, and systemic manifestations, such as
enlargement of right heart or of liver or spleen, cyanosis, digital
"clubbing", and kidney stones, have been reported. ' BerylHum-
123
Induced cancers have been demonstrated 1n laboratory animals *'
(monkeys, rabbits, guinea pigs, hamsters, and rats). Insufficient
121
data are available to Incriminate beryllium as a human carcinogen, '
but there 1s no mechanism for the total elimination of beryllium
body burdens, and the resulting possibly long residence time
may Indeed enhance the opportunity for cancer Induction.
48
-------
The Beryllium Registry5 now contains over 800 cases, but since
many of these cases are most likely due to exposure prior to the
Institution of controls, proper assessment of the period of exposure
1 2
1s not always possible. ' It 1s known, however, that chronic beryllium
disease 1s not only associated with activities Involving extraction
processes, but that 64 Registry cases resulted from exposure during
machining operations (37 from machining the pure metal, 27 from
machining copper alloys whose maximum beryllium content was 4%);
the chronic disease has also been associated with foundry operations
where 4% beryl11urn-copper (BeCu) alloy was melted and diluted to
2% BeCu alloy. There are at least 45 cases of non-occupationally-
Incurred disease on file with the Beryllium Registry.
Retrospective studies of the concentrations of beryllium that
resulted 1n some cases of chronic beryllium disease from non-
occupational exposure have concluded that the lowest concentration
which produced disease was greater than 0.01 yg/m , and probably less
than 0.10 yg/m3.4
In 1949, when 1t became apparent that beryllium was a toxic material,
the Atomic Energy Commission (AEC) adopted a limit for beryllium concentra-
tions 1n community air (I.e., 0.01 yg of beryllium per cubic meter of air
averaged over a 30-day period). Beryllium refining companies holding contracts
with the AEC to operate AEC-owned refinery facilities and expand their own
refinery capacity to meet AEC's beryllium requirements, were required to
49
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observe the community air limit. With the termination of these contracts
1n the 1961-1963 period due to a reduction 1n AEC requirements for
beryllium, the refineries were no longer subject to the AEC community
air limit. The AEC's health and safety requirements, however, have
continued to apply to all AEC-owned facilities, some of which
fabricate and assemble beryllium parts. In the period since the Imple-
mentation of the AEC guideline, no reported cases of chronic beryllium
disease have occurred as a result of community exposure, ' and the
Committee on Toxicology of the National Academy of Sciences concluded
3
that the average concentration of 0.01 vg/m for a 30-day average 1s
a proven safe level of exposure.
Emissions of beryllium from the sources covered by the proposed
EPA standard occur as dust, fume, or mist. Alterat1on-of a beryllium
product by burning, grinding, cutting, or other physical means can,
1f uncontrolled, produce a significant hazard. In contrast,
beryllium alloys 1n the form of strip or other wrought products
are sometimes utilized 1n operations that do not generate significant dust,
fume, or mist. The number of operations that use beryllium 1s estimated
2
to be 1n the thousands. Approximately 300 operations, such as
machine shops, ceramic plants, propellant plants, extraction plants, and
foundries, comprise the major users of beryllium that could cause emissions
to the atmosphere. Annual U.S. consumption of beryllium has grown
from an estimated 1438 tons 1n 194810 to 9511 tons 1n 1970.14
Data from the National A1r Surveillance Networks do not show
the existence of dangerous levels 1n the ambient atmosphere. Nevertheless,
50
-------
because of the known serious and sometimes lethal effects of uncontrolled
Inhalation of beryllium dust, fume, or mist, and uncertainty as to the
shape and character of the dose-response curve 1n man, 1t would be
highly Imprudent to permit additional contamination of the public
environment with these forms of beryllium. Continued use at minimal
risk to the public requires that the sources of beryllium dust, fume,
or mist emissions Into the atmosphere be defined and controlled. In
the absence of such controls, local concentrations might at times
approach those 1n occupational sites.
Since 1966, emissions from the firing of rockets utilizing beryllium
as a propel1ant component have been limited by U.S. Public Health Service
policy; since 1967, they have been limited as well by U.S. Department
of Defense directive. Both agencies direct that emissions from
this source shall not cause atmospheric concentrations of soluble beryllium
3
compounds to exceed 75 yg-m1nutes/m of air within 10 to 60 minutes, accumulated
during any 2 consecutive weeks, 1n any area accessible to the
general public or at any place of human habitation.
The sources covered by the promulgated standard, 1f not controlled,
can potentially release amounts of beryllium that will produce
3
concentrations greater than 0.01 yg/m 1n the ambient air. All
sources known to have caused, or to have the potential to cause,
dangerous levels are covered by the beryllium standard.
51
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Development of the Standard
The basic approach used to develop a standard for beryllium was
to identify an ambient level sufficient to protect public
health from the effects of beryllium and then relate emissions to
this ambient level by using meteorological procedures. In order
to determine what sources of beryllium emissions were capable of
o
exceeding the ambient guideline (0.01 vg/m - 30-day average),
EPA conducted a characterization study of the sources of beryllium.
The study included contracts ' to develop information on beryllium
emission sources and communications with industrial representatives,
trade associations, and air pollution control experts. Further,
visits were made to representative plants which had been identified
as sources of beryllium emissions. Some of these plants were
tested for beryllium emissions, and the results of the tests are
presented in Table 2.
One difficulty in developing a national emission standard for
beryllium was the application of one national meteorological model
to the large number of beryllium sources that are characterized by
differing emission parameters, climatic conditions, and topography.
The release of beryllium into the atmosphere varies from continuous
to intermittent, from release at essentially ground level to
several hundred feet through tall stacks, and from a single stack
to a group of stacks at a single source spread over a large area.
A maximum allowable emission rate of 10 grams/24-hour period was
calculated by assuming meteorological conditions which are conducive to
52
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Table 2.
EPA Beryllium Emission Testing Results
Emissions
Date Type Plant (grams/24-hour period)
Feb. 1972 Large ceramic 0.16
plant! 7
Aug. 1971 *Large pure ,« 0.16
Be machine shop
Aug., Dec. 1971 *Large pure lg 4.2**
Be machine shop
Aug. 1971 *Beryllium foundry20 .08?.
3. OS1"1"
*Emissions based on 8-hour per day operation since the plants operate
only one shift and are shut down 16 hours.
**In a previous test an emission rate of 11.7 grams/day was measured.
A baghouse filter bag had ruptured and was indicated to be the source
.of the high emission.
.[After baghouse.
"Before baghouse.
53
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poor dispersion and the ambient guideline concentration (0.01 yg/m - 30-
day average). These assumptions were employed in order to provide an
ample margin of safety to protect public health, i.e., to be reasonably
confident that the calculated maximum emission rate would not result in
3
a 30-day average ambient concentration in excess of 0.01 yg/m under any
realistically possible circumstances. The assumptions and equations used
to make the dispersion estimate are given in the background Information
21
report which was published at the time the standards were proposed.
The four existing beryllium extraction plants have structured
their facilities in configurations which are designed to meet a
3
0.01 yg/m (30-day average) level, primarily by dispersing emissions
through the use of multiple emission points. No non-occupational
cases of chronic beryllium disease have been identified in the
vicinity of these sources since 1949. The community health
record of the extraction plants for a period of more than 20 years
was determined to be sufficient evidence that this compliance
method is workable and provides an ample margin of safety to protect
public health. Consequently, as an alternative to complying with the
10 grams/24-hour period maximum emission, the proposed standard also
allowed the operator of any affected source to demonstrate compliance
3
by not exceeding the ambient beryllium guideline (0.01 yg/m - 30-day
average). In order to demonstrate compliance with the ambient option,
the operator of a source was required to operate an EPA-approved
monitoring network designed to measure the maximum ambient beryllium
concentration.
54
-------
Because of the Inherent high concentrations possible during
rocket motor propel!ant firing and the non-sustained (Intermittent)
nature of this source of beryllium emissions, a different standard
was developed for this source category. A dose of a high concentration
of beryllium for a relatively short period may pose a beryllium hazard
to public health and must be prevented even though the 30-day ambient
3
average of 0.01 yg/m may not be exceeded. The Committee on
Toxicology of the National Academy of Sciences recommended, after
studying the Intermittent exposure problem 1n 1966, two time weighted
3
beryllium exposure levels, 75 yg-minutes/m for soluble beryllium
3
compounds ajid low-fired beryllium oxide and 1500 yg-minutes/m for
high-fired beryllium oxide (within the limits of 10 to 60 minutes,
accumulated during any consecutive two-week period). EPA has applied
the more restrictive of these two recommended levels to rocket motor
test facilities and propellent disposal sites. This level was applied
since the composition of the combustion products of the intermittent
sources covered may contain soluble beryllium compounds or low-fired
beryllium oxides depending on the type of propel!ant tested or waste
disposed of and the firing conditions. Thus-, Intermittent beryllium
sources were required to design test firings and the disposal of
beryllium propel1 ant to not exceed a time weighted concentration
3
of 75 yg-m1nutes/m (within the limits of 10 to 60 minutes accumulated
during any consecutive two-week period).
Beryllium sources are generally well controlled; however, under
55
-------
certain conditions, processes and control equipment can be operated
so that beryllium emissions will result in excessive ambient
concentrations. The following sources were determined to be capable
of generating emissions which could exceed the ambient beryllium
guideline and, therefore, were covered by the proposed standard:
Beryllium extraction plants
Beryllium metal and alloy machine shops
Beryllium foundries
Beryllium ceramic plants
Incinerators that dispose of beryllium-containing wastes
Power plants which burn coal that typically contains from 1 to
2 parts per million of beryllium are known to be sources of beryllium
emissions, but were not covered by the proposed beryllium standard.
Beryllium emissions from power plants may be larger than emissions
from some sources that were covered by the proposed standard; however,
due to the dispersion provided by tall stacks and hot gases
characteristic of these sources, the attainment of ambient concen-
o
trations in excess of 0.01 yg/m (30-day average) has been determined
to be unlikely even in restrictive dispersion situations.
The proposed beryllium standard was reviewed by several
governmental and expert advisory groups prior to being proposed in
the Federal Register on December 7, 1971. Simultaneously, EPA
21
published a background information report which gives a summary
of information available, prior to proposal and the developmental
approach used to establish the standard.
56
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Evaluation of Comments
All of the comments received during the comment period were
evaluated and the proposed standard was revised to reflect this
evaluation. The revised standard was reviewed by several advisory
groups prior to final promulgation. A discussion of evaluation of
the comments and the resulting action by EPA follows:
1. Comments on the proposed standard for beryllium were
received which claimed that the ambient compliance option was
inconsistent with Section 112 of the Act because it is not an
emission standard and that enforcement would be difficult. This
comment was given much consideration and it was concluded that under
certain conditions, compliance with an ambient level can be considered
an emission standard because emissions must be limited to the
extent necessary to avoid exceeding the established ambient level.
In the case of beryllium, the effectiveness of this mode of compliance
has been proven over the past 20 years in the beryllium extraction
industry. The community health record of the extraction plant since
1949 is considered sufficient evidence that the use of an ambient
level is workable and provides an ample margin of safety.
The principle of allowing compliance with the beryllium
standard by ambient monitoring has been retained in the promulgated
standard; however, the applicability of this option has been restricted
for enforcement purposes. The proposed standard would have allowed
all sources of beryllium to choose between meeting the 10-gram-
per-24-hour emission limit and complying by use of.ambient
o
monitoring to insure that the 0.01 yg/m (30-day average)
57
-------
1s not exceeded. Enforcement of this provision would have been
very difficult due to the problem of distinguishing between and
among sources of beryllium emissions. The standard was revised
to allow this option only to existing sources which have at least
three years of current ambient air quality data which demonstrates
to EPA's satisfaction that the 0.01 yg/m (30-day average) can be
met in the vicinity of the source. A minimum of three years of
data was judged to be necessary to demonstrate that the ambient
3
guideline of 0.01 yg/m (30-day average) can be met because of the
possibility of monthly, seasonal, and even annual variations
in ambient levels caused by variations in meteorology and
production. The existing sources that can qualify for this option
are four beryllium extraction plants and possibly a small number of
machine shops. These sources were designed or modified to facilitate
3
compliance with the 0.01 yg/m ambient limit. In addition, these sources
are located sufficiently far apart so that the ambient levels of beryllium
in the vicinity of a source can be attributed to the emissions from that source,
2. Information received after proposal indicated that the open
burning of beryllium-containing wastes could cause ambient concen-
3
trations of beryllium in excess of 0.01 yg/m . The scope of the
promulgated beryllium standard was revised to prohibit the open
burning of beryllium-containing waste because the control of emissions
from such sources is not feasible. The standard does allow, however,
disposal of beryllium-containing waste in incinerators that are
regulated by the 10 grams per 24-hour limit. The disposal of beryllium-
containing explosive wastes is covered in the standard applicable to
rocket testing.
58
-------
3. Comments were received which claimed that numerous machining
operations use alloys containing low concentrations of beryllium and
do not exceed the 10 gram per 24-hour emission limitation. An
Investigation of these comments revealed that alloys which Include
beryllium generally either contain a large amount (greater than 60%)
or a small amount (less than 5%), and that approximately 8000
machining operations use the low-content beryllium alloys. A
survey was conducted by EPA to determine if significant beryllium
emissions could result from the operations which use low beryllium
content alloys (e.g. stamping, tube drawing, milling, and sawing).
(See Table 3.) The survey consisted of measuring maximum concentrations
of beryHlum Inclose proximity to the operations which generate beryllium
emissions. The values measured, usually within one to two feet of the
emitting operation, were very low.
The data presented in Table 3 are in terms of concentrations
Instead of an emission rate since the flow volumes close to the
machining operations are very low and difficult to measure. The
operations that were measured generally were not hooded and vented
to the atmosphere but were operated openly in the shop building.
In order to evaluate the potential emissions that could result from
these operations, a properly designed hooding system was assumed that
would ventilate the machining device according to the American
22
Conference of Governmental Industrial Hygienists (ACGIH) guidelines
and the beryllium emissions were calcuated. The following additional
assumptions were made:
59
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Table 3.
EPA Survey of Be Alloy Operations
Concentration In
Date
July 1972
Aug. 1972
July 1972
Aug. 1972
Aug. 1972
Aug. 1972
Aug. 1972
Aug. 1972
Aug. 1972
Aug. 1972
Process
Machine
shop -
milling
machine
Machine
shop -
stamping
& heat
treatment
Machine
shop -
sawing
Machine
shop -
drilling
Machine
shop -
drilling
Machine
shop -
stamping
Machine
shop -
cutting
& slitting
Machine
shop -
stamping
Metal
working -
tube
forming
Machine
shop -
stamping
& heat
treating
Work Area
65.8 yg/m3 - 18"
above tools
0.0891 yg/m3 - 3 ft
above heat treatment
0.12 yg/m3 - 2 ft
above machine
0.0725 yg/m3 -
18" from drill
0.0293 yg/m3 -
2 ft from drill
0.251 yg/m3 -
6" from stamping
die
0.594 yg/m3 -
1 ft from
slit tool-
0.159 yg/mj -
1 ft from saw
3
0.006 yg/m
4" from die tool
0.0573 yg/m3 -
8" from tube die
0.0826 yg/m3 -
8" from heat
treatment
Unde tec table
from die operation
Alloy (% Beryllium)
2
2
0.5 to
2
2
2
2
2
2
2
2
60
-------
a. An open hood area of 5 square feet.
b. Two machines operated continuously on a 24-hour-per-day basis.
c. The beryllium concentration of the ventilation air was
equal to the concentration measured in close proximity to
the machining operation.
d. A required ventilation flow rate of 300 CFM per square
22
foot of open hood area.
e. No emission control devices.
3
The highest concentration measured in EPA's survey was 65.8 ug/m
obtained during an alloy milling operation. This concentration is
over 400 times higher than the average of measurements obtained
for 10 other machine operations. It is suspected that this
concentration is not representative of the machining operations due
to the capture of unrepresentative alloy chips on the filter during
sampling which would not be vented to the outside air. The average
q
concentration of the 10 operations (excluding the high value of 65.8 ug/m )
3 3
is 0.15 yg/m . Using 0.15 yg/m and the assumptions given above, an
uncontrolled emission of .02 grams/24-hour period is calculated. The
results indicated that even if the emissions were vented, without prior
treatment to the outside air, which was not the case in the operations
tested, the emissions would be signflcantly below the 10-gram-per-24-hour
emission limitation. Accordingly, the standard was revised to exempt
the machining operations which use the low beryllium content alloys.
Five percent beryllium was used as the dividing line since this would
exempt all of the Innocuous sources of beryllium from coverage while
61
-------
insuring that those sources which are most likely to cause ambient
3
concentrations in excess of 0.01 yg/m would be covered.
Environmental Impact
It is estimated that the impact of the standard on reducing
beryllium emissions will be small since most of the potentially large
beryllium emission sources are already well controlled.
The disposal of waste material collected by the additional
control devices that are required for a few existing sources and
the devices installed on new sources are potential sources of
beryllium environmental contamination; however, this is not
considered to be a problem because it is economically desirable
to recycle beryllium waste due to its high value. Most-gas streams
emitting significant quantities of beryllium are controlled
with dry collectors which produce a waste material that is generally
easy to handle and recycle. This waste material is recycled or
sold back to primary producers for reprocessing. Absolute filters
are used in some applications as final filters to collect small
quantities of beryllium from very low concentration gas streams.
The beryllium collected by this type of filter cannot be easily
recycled; therefore, filters are usually packaged after removal and
burled 1n segregated dumps or stored 1n unused mines. Procedures to
deal with this type of beryllium waste are well developed and currently
in use. No additional environmental Impact caused by the standard
1s expected from the disposal of final filters.
The use of wet collectors 1s not anticipated to be a problem
because these collectors are rarely used strictly as an air pollution
62
-------
control device, but more often as an extraction process control
device allowing recycle of waste liquids to the process.
Economic Impact
Although the standard 1s not based on economic considerations,
the economic impact of the standard 1s discussed below. Since most
of the sources of beryllium emissions are already controlled and
in compliance with the standard, the economic impact will be very
small.
The beryllium processing industry includes the primary producers
(extraction plants) which extract beryllium from ores and manufacture
metal, alloy, and oxide forms. Secondary processors, such as ceramic plants,
machine shops, and foundries, further process beryllium oxide, beryllium
metal, or beryllium-copper alloy products for applications in electrical
switchgear, electronic microcircults, welding equipment, defense
purposes, and nuclear reactors.
The extreme toxldty of beryllium requires the practice of
good industrial hygiene to protect employees' health. This
practice frequently Includes collection of beryllium pollutants
from ventilation ducts to prevent re-entra1nment Into the
plant. The limitation on ambient beryllium concentration which
will result from the standard has already been applied to government
facilities and government contractors associated with the Atomic
Energy Commission. This resulted from recommendations Issued 1n
1949 by the Beryllium Medical Advisory Committee to the AEC.
Of four basic classes of manufacturing sources that emit
beryllium—extraction plants, ceramic plants, machine shops, and
63
-------
foundries—it is probable that only foundries will have to add
control equipment beyond existing levels to meet the standard.
It is estimated that there are hundreds of foundries which process
very small quantities of beryllium compounds in conjunction with
the manufacture of beryllium-copper alloy products. Because
beryllium-copper alloy conventionally contains no more than 4 percent
beryllium, only those facilities that handle relatively large
quantities of material are likely to exceed the emission limitation
of the standard, even in the absence of emission controls.
Based on the above, it is estimated that there will be little
economic impact on the beryllium industry. Only large foundries
will need to finance installation of fabric filters, or perhaps
scrubbers, to meet the standard. The control costs are estimated
to be on the order of 0-2 percent of individual company sales.
64
-------
References
1. Committee on Toxicology, National Academy of Sciences: Air
Quality Criteria for Beryllium and Its Compounds. Report
prepared under contract to the U.S. Public Health Service
[Contract N7onr-291 (61)], Washington, March 1, 1966.
2. National Institute for Occupational Safety and Health: Occupational
Exposure to Beryllium (Criteria for a Recommended Standard). Washington,
U. S. Department of Health, Education, and Welfare (PHS, HSMHA), 1972
(HSM 73-10268).
3. National Institute for Occupational Safety and Health: The
Toxicology of Beryllium (Tabershaw, I.R., Ed.). Washington, U.S.
Department of Health, Education, and Welfare (PHS, HSMHA), PHS
Publication No. 2173, 1972 (HSM 73-11008).
4. Eisenbud, M., R. C. Wanta, C. Dustan, L.T. Steadman, W.B. Harris,
and B.S. Wolf: Non-occupational Beryl!iosis. J. Ind. Hyg.
Toxicol., 31_, 282-294, 1949.
5. Massachusetts General Hospital: United States Beryllium Case Registry.
6. Tepper, L.B., H.L. Hardy, and R.I. Chamberlin: TOXICITY OF BERYLLIUM
COMPOUNDS. New York, Elsevier, 1961.
7. Shipman, T.L., and A.J. Vorwald: History of Beryllium Disease,
In: Beryllium: Its Industrial Hygiene Aspects (Stokinger, H.E.,
Ed.). New York, Academic, 1966.
8. Aub, J.C., and R.S. Grier: Acute Pneumonitis in Workers Exposed
to Beryllium Oxide and Beryllium Metal. J. Ind. Hyg. Toxicol.,
31, 123-133, 1949.
9. U.S. Department of the Interior, Bureau of Mines: Mineral Facts
and Problems. Washington, U. S. Department of the Interior, 1965.
10. Hardy, H.L.: Beryllium Disease: A Continuing Diagnostic Problem.
Am. J. Med. Sci., 242, 150-155, 1961.
11. Resnick, H., M. Roche, and W.K.C. Morgan: Immunoglobin Concentrations -
in Berylliosis. Am. Rev. Resp. Dis., 101, 504-510, 1970.
12. Hall, T;C., C.H. Wood, J.D. Stoeckle, and L.B. lepper: Case Data
from the Beryllium Registry. Arch. Ind. Hyg., 19., 100-103, 1959.
13. Hardy, H.C., and J.D. Stoeckle: Beryllium Disease. J. Chron. D1s., —
9., 152-160, 1959.
65
-------
14. U.S. Department of the Interior, Bureau of Mines: Minerals
Yearbook, V.I. (1970). Washington, U.S. Department of the
Interior, 1972.
15. National Inventory of Sources and Emissions, Arsenic, Beryllium,
Manganese, Mercury, and Vanadium - 1968, Beryllium - Section 2,
Leawood, W. E. Davis and Associates, Environmental Protection
Agency, Contract No. CPA 70-128, Sept. 1971.
16. Levin, H. A Basis for National Air Emission Standards on
Beryllium. Camarillo, Litton Environmental Systems, CPA 70-107,
April 1971.
17. Environmental Engineering, Inc., Coors Porcelain Co. Ceramic
Plant, Golden, Colo. EPA Contract Mo. CPA 70-82, Task Order No. 6.
18. Environmental Engineering, Inc., Shiller Industries, Speedring, Inc.
Machine Shop, Culman, Ala. EPA Contract No. CPA 70-82, Task Order 2,
1972.
19. Environ. Engineering, Inc., American Beryllium Co., Machine Shop,
Sarasota, Fla. EPA Contract No. CPA 70-82, Task Order 2, 1972.
20. Environmental Engineering Industries, Southeastern Injection
Molding - Be Foundry, Gaffney, South Carolina. EPA Contract No.
CPA 70-82, Task Order 2, 1972.
21. U.S. Environmental Protection Agency: Background Information -
Proposed National Emission Standards for Hazardous Air Pollutants
(Asbestos, Beryllium, Mercury). Research Triangle Park, N.C.,
Environmental Protection Agency, December 1971 (APTD-0753).
22. American Conference of Governmental Industrial Hygienists: Industrial
Ventilation - A Manual of Recommended Practice, Lansing, Michigan,
American Conference of Governmental Industrial Hygienists, 5 Ed, 1958.
23. U.S. Environmental Protection Agency: Comprehensive Study of
Specified Air Pollution Sources to Assess the Economic Impact
of Emission Standards (Asbestos, Beryllium, Mercury). Research
Triangle Park, N.C., Research Triangle Institute, Vol. II, EPA
Contract No. 68-02-0088, August 1972.
65a
-------
' '
MERCURY
The following information augments that given in the preamble
to the promulgated regulations.
Health Effects
34
Vapors of elemental mercury are rapidly ' and almost completely
absorbed via Inhalation. Inhaled mercury vapors rapidly leave the lungs
and gradually concentrate in other tissues. •'
After exposure to elemental mercury vapors, central nervous system
(CNS) effects predominate, with tremor and nonspecific neurasthenic
symptoms; renal damage may occur also. '
The differences in toxicity among the various forms of mercury
are explained to a great extent by differences in their metabolism.
To react chemically with proteins and other molecules in the living
organism, elemental mercury must undergo oxidation to the mercurous
TT ++ 8
(Hg« ) or mercuric (Hg ) ion, and oxidation of most of the vapor
probably takes place soon after absorption from the lungs, inside
6 8
the red blood cells; ' a small amount of elemental mercury that
persists in the blood, however, plays an important role in the
4 9 10
distribution of mercury to the brain after exposure. ' • After
exposure to the vapor, mercury 1s eliminated in the Inorganic
form, mainly as mercurous and mercuric salts, and those complexes
in which mercuric ions can form reversible bonds to tissue ligands;
animal (rat) data show the excretion to follow two (to three) consecutive
exponential curves of Increasing half-life, and clearly, the slowest
component, involving some 70% of the dose after brief exposure
66
-------
(0.5-5 hours) to radioactive vapor, and characterized by a half-
time of 20 days, would play a predominant role in determining the
o
cumulative body burden in clinically exposed animals. The
accumulated body burden of mercury approaches a steady state in
such animals after approximately 60 days of repeated exposures, and
the best available evidence suggests that humans attain a steady
state level after approximately between six and eighteen months of
exposure. Further interpretation of half-lives is difficult, in
7 8
view of the time-related redistribution within the body ' i.e., an
uneven distribution among and within organs, combined with a slow
excretion from, for example, the CNS and the kidneys. The data
collectively indicate a risk of accumulation in critical systems upon
7 8
prolonged exposure, ' giving rise, for example, to a potential for
o
selective brain damage.
There exist few epidemiological data which provide scientifically
satisfactory information about detailed dose-response relationships
in man, even for a single mercury compound; this fact, however, is
not unique for mercury, and there are, moreover, some data available
for mercury vapor inhalation that make it possible to assess
risks to some extent. Experience with mercury vapor comes almost
exclusively from animal experiments and industrial exposures. Prolonged
3
exposure in an industrial environment to about 0.1 mg Hg/m involves
a definite risk of mercury intoxication. It is not possible, however,
67
-------
to state a no-effect concentration since recent studies in the U.S.
12
chlor-alkali industry as well as some industrial data from the
U.S.S.R. indicate that exposures as low as 0.01-0.05 mg Hg/m *
can produce certain subtle, reversible effects. Animal data from
the U.S.S.R. indicate that still lower concentrations may produce
certain deleterious effects, i.e., changes in conditioned reflexes
have been reported even at concentrations in the air of 0.002-0.005
3
mg Hg/m when rats were exposed for several months; this work,
however, has not yet been reproduced in other laboratories.
Elemental mercury has been shown to be carcinogenic (only at
13
deposition sites, after intraperitoneal injection into rats),
whereas inorganic mercury compounds have not been so implicated.
The latter are subject to conversion to methylmercury compounds by
14-17
microorganisms. Methylmercury compounds are considered to
be by far the most hazardous mercury compounds, particularly via
the ingestion of fish in which they have been concentrated through the
7 18
food chain. * Methylmercury is more readily transferred across
the placenta! barrier than is mercuric chloride or phenyl mercuric
18
acetate.
*The current U.S. Threshold Limit Value is 0.05 mg Hg/m The World Health
Organization23 recently established a "provisional tolerable weekly intake" of
0.3 mg of total mercury per person, of which no more than 0.2 mg should be
present as methylmercury, CH3Hg+ (expressed as mercury).
68
-------
Without knowledge of the accumulation rate of mercury in different
parts of the CNS, the effects of continuous long-term exposure, and
of the nature of particularly sensitive groups, it is not possible to
estimate the concentrations to which the given industrial concentrations
would correspond in general community exposures. Considering only
differences in exposure over a one-year period (365 vs. 225 days, and
3 3
a lung ventilation rate of 20 m /day vs. 10 m /work day) would yield an
approximately threefold reduction; this means that a concentration
3 21
in industry of 50 pg Hg/m (the present U.S. TLV) would correspond
3
to a concentration in the general population of about 15 pg/m . At
3
a lung ventilation rate of 20 m /day and an absorption of 80%, this
corresponds to a daily absorption of about 250 pg. Occupational1y-
derived threshold limit values and maximum allowable concentrations
do not take into account the extremes of youth, age and disease
encountered in the general population.
In order to determine the level of mercury in the ambiont air
that does not impair health, the airborne burden must be considered
in conjunction with the contribution of mercury from water and food.
An analysis of the Japanese epidemics by the Swedish Commission on
Evaluating the Toxicity of Mercury in Fish' led that group to
conclude that an adult sensitive to methylmercury would be poisoned
by an intake of about 4 ug/kg body weight/day. Application of a
safety factor of 10 yielded an acceptable exposure of about 0.4 pg/kg
body weight/day, or 30 pg/day for a 70 kg man. It was felt by this
expert group that application of this safety factor provided
69
-------
satisfactory protection against poisoning of the fetus, genetic lesions,
and poisoning of children.
In view of the present limited knowledge as to effects of Inhaled
mercury vapor 1n the general population, and to best assure the requisite
20
"ample margin of safety to protect the public health," the Environmental
Protection Agency 1s adopting the prudent approach of considering exposures to
methylmercury (diet) and mercury vapor (air) to be equivalent and additive.
Diets containing fish contaminated at or exceeding the present FDA limit of
0.5 yg/g would lead to intakes in excess of 30 ug/day; however, it has been
estimated that from average diets, over a considerable period, mercury intakes
22
of 10 yg/day could be expected. Thus the average mercury intake from air
would have to be limited to 20 yq/day 1f the average total intake is to be
3
restricted to 30 yg/day. Assuming inhalation of 20 m air/day, the air
3
could contain an average daily concentration of no more than 1 yg Hg/m .
3
The ambient air level of 1.0 yg/m (daily average) is considered by
EPA to be sufficient to protect public health with an ample margin
of safety from the effects of atmospheric mercury. This level was
used as a guideline in establishing the mercury emission standard.
Development of the Standard
The basic approach used to develop a standard for mercury was
essentially the same as that used for beryllium. First, an ambient
level sufficient to protect public health from the effects of mercury
was identified and then allowable emissions were derived from the ambient
level by using meteorological procedures. The mercury standard was,
70
-------
therefore, developed with the intention of regulating those sources
that have the potential to emit mercury in a manner that could cause
the ambient concentration guideline to be exceeded.
EPA conducted a characterization study of mercury emission sources
to determine which sources should be regulated. The study included
24 25
contracts ' to develop information on mercury emissions and
communications with pollution control equipment vendors, industrial
representatives, trade associations, and pollution control
experts. Further, visits were made to representative plants which
had been identified to be sources of mercury emissions. Several plants
were tested for mercury emissions and the results of these tests
are presented in Table 4.
An emission inventory developed by EPA as a result of this study
is presented in Table 5. The sources of mercury emissions can be
placed in two general categories, those with emissions containing
high concentrations of mercury where a gas stream has been in intimate
contact with mercury, and those with emissions where mercury is included
only in trace quantities or is a contaminant and is emitted in low
concentration gas streams. Mercury cell chlor-alkali plants, primary
mercury extraction plants, and secondary mercury plants fit the first
category, whereas power plants, nonferrous smelters, consumptive uses
of paints, and waste disposal fit into the second category- From
EPA's investigation into mercury sources requiring regulation, it was
found that mercury emissions from the second category would not, even
assuming restrictive dispersion conditions and uncontrolled emissions,
71
-------
Table 4.
Emission Testing of Mercury Sources
A. Mercury Cell Chior-Alkali Plants
Plant Capacity Emission Rate
Date Tested T Cl2/Day g/24-hour period
July 1971 160 4560* complete plant26
Aug. 1971 180 2740 process streams2
00
Jan. 1972 400 5150 process streams
on
Feb. 1972 300 3030* complete plant"
B. Mercury Extraction Plants
Plant Capacity Emission Rate
Date Tested T Ore/Day g/24-hour period
July 1971 200 53.37030
Feb. 1972 35 489131
Feb. 1972 90 754832
*The cell room emissions were measured only at two of the chlor-
al kali plants.
72
-------
Table 5.
Emissions of Mercury to the Atmosphere - United States Inventory*
Emissions (Short Tons)
1968
Mining 2.6
Processing 100.6
**Pr1mary Mercury 55.0
Secondary Mercury 0.5
Nonferrous: Copper 31.0
Z1nc 9.7
Lead 4.4
Reprocessing 3.4
Paint 0.8
Electrical Apparatus 2.6
Consumptive Uses 532.1
Paint 215.0
Agricultural 18.8
Pharmaceuticals 2.6
**E1ectrolyt1c Chlorine 185.4
(mercury cell)
Instruments 2.6
Dental Preparations 1.2
General Laboratory Use 4.8
Other 3.0
Coal-Power Plants 57.5
-Other 34.5
011-Power Plants 3.4
Incineration and 139.2
Other Disposal
Incineration 10.8
Sewage and Sludge 4.4
Other 124.0
TOTAL 777.9
*Does not Include estimates of crustal mercury emissions.
**Sources covered by the mercury emission standard (NESHAPS).
73
-------
3
exceed 1.0 ug mercury/m on a dally basis; therefore, they were not
covered by the proposed standard. Chior-alkali plants, primary mercury
extraction plants, and secondary mercury plants were thoroughly
investigated since these plants were indicated to be capable of
exceeding the ambient mercury guideline. Although the mercury
concentration of gas streams from secondary mercury plants is high,
the volumes generated in the processes used in this industry are low
and result in emissions that will not cause the ambient guideline to
be exceeded. As a result, this source category was excluded from the
standard. The information obtained through EPA studies indicated
that mercury cell chlor-alakli plants and mercury extraction plants
could under certain circumstances cause guideline levels to be
exceeded and, therefore, were the only source categories regulated by
the proposed standard.
An emission rate of 2300 grams per 24-hour period was calculated
to be the maximum emission allowable in order to protect the ambient
3
guideline concentration of 1.0 yg/m . Restrictive assumptions were
employed in order to be reasonably confident that the calculated maximum
emission rate would not result in a daily ambient concentration in
3
excess of 1.0 yg mercury/m under realistically possible circumstances.
The assumptions and equations used to make the dispersion estimates
33
are given in the background information report published at the time
the standards were proposed. The diffusion model assumed essentially
ground level emissions vented from a single stack. The standard proposed
to regulate mercury emissions to protect public health was therefore
74
-------
established at 2300 grams per 24-hour period and applied to the emissions
from mercury cell chlor-alkall plants and primary mercury extraction
plants.
The proposed mercury standard was reviewed by several governmental
and expert advisory groups prior to being proposed In the
Federal Register on December 7, 1971.
Evaluation of Comments
All of the comments received during the comment period were
evaluated, and the proposed standard was revised to reflect this
evaluation. The revised standard was reviewed by several
advisory groups before final promulgation. The following is an
evaluation of the major comments and the resulting action by
EPA:
1. Some comments argued that the sources covered by the proposed
standard contribute only a small percentage of the total mercury
emissions in the United States and that the standard should apply
equally to all sources of mercury emissions. The proposed
standard was intended to protect the public health from the
Inhalation effects of mercury. EPA recognizes that mercury
and Its compounds constitute a multimedia contamination
problem, i.e., evidence exists that all man-made uses of
mercury alter Its natural distribution in the environment; that
such uses may cause or hasten additional deposits into water over and
above those occurring naturally, thereby building up environment
concentrations; and that mercury levels accumulate in the aquatic
75
-------
biota with the result that potentially dangerous residue levels
may be reached 1n foods consumed by man and animals. Current data
on the environmental transport of mercury, however, do not
permit a clear assessment of the effect of mercury emissions
*
Into the atmosphere on the mercury content 1n the aquatic and terrestrial
environments. Results of ongoing research will determine 1f there 1s a
need for more comprehensive control of mercury emissions Into the air.
The promulgated standard 1s Intended to protect the public health from
the effects of Inhaled mercury.
Only two source categories (mercury cell chlor-alkall plants and primary
mercury plants) have been determined, as noted above, to be capable
of emitting mercury 1n a manner that may exceed the Inhalation health
3
effects limit of 1.0 yg/m. The selection of the two categories
covered by the mercury standard was based on emissions Inventories
and meteorological conditions of all currently known sources of atmospheric
mercury emissions. Other sources which emit mercury to the
3
atmosphere do not cause 1.0 yg/m level to be exceeded. A large
coal fired power plant having a capacity of 1000 megawatts, a
500 foot stack, and a mercury content 1n the coal o'f 0.4 ppm 1s
calculated to emit 3700 grams of mercury per day. In order for
3
such a plant to cause the 1.0 yg/m ambient level to be exceeded,
1t would have to emit 360,000 grams of mercury per day assuming
76
-------
poor dispersion conditions. The above example 1s an extreme
case and does not typify an average situation. The mercury
content of domestic coal ranges up to 0.5 ppm and averages
0.2 ppm.
2. The mercury ore processing Industry commented that enforcement
of the proposed standard would result 1n the complete closing of their
Industry. This 1s an economic Issue and 1s discussed 1n the section
of this report which discusses the economic Impact of the mercury
standard.
The mercury ore processing plants have the capability of causing
3
dally ambient mercury concentrations 1n excess of 1.0 yg/m . Section 112
of the Act states that "The Administrator shall establish any such
standard at the level which 1n Ms Judgment provides an ample margin of
safety to protect the public health from such hazardous air pollutants."
No mention 1s made 1n Section 112 concerning the consideration of economics
1n developing a standard. This has been Interpreted to mean that economics
1s not a major consideration when the public health 1s at risk. Consequently,
the standard regulating mercury emissions from mercury ore processing plants
has been promulgated.
3. Some comments argued that compliance with the existing
Occupational Safety and Health Administration (OSHA) regulation or the
Threshold Limit Value (TLV) guideline for mercury should be used to
enforce the standard for the cell room, with a reasonable portion
of a total plant's mercury emissions being assigned as the cell room
emissions. The proposed standard required the cell room
77
-------
emissions to be measured by a source test method provided 1n Appendix B
to the standard (Method 2). Source testing by EPA has shown that the
application of this source test method 1s difficult and only
limited data have been obtained using this method. Little Information,
therefore, 1s available concerning the accuracy and workability of the
proposed sampling method.
Many chlor-alkall plant cell rooms present severe source testing
problems due to their design and construction. A major problem 1s
that the volumetric flow rate can not be accurately measured due to
cell room configuration. In most Installations, cell room air 1s
discharged through roof ventilators; however, several cell rooms
are vented through the bottom floor, and one chlor-alkall plant does
not have an enclosed cell room. Because of the cell rooms' large volume
(300 ft x 150 ft x 40 ft for example), the large number of ventilation
openings, and variations in the ventilation methods, the ventilation
flow cannot be accurately measured by the proposed sampling method.
EPA does have a proven method to sample emissions from a stack.
The cell rooms can be designed and modified so that the stack
sampling method can be used, but the cost of modifying an existing
cell room so that room air is vented through stacks suitable for
testing by the stack sampling method would be very large ajid no mercury
control would be achieved by this expenditure. Further, there are no
current control methods which are capable of removing mercury from large
volumes of air having low concentrations of mercury. The only way EPA
has found to limit the mercury emissions from cell rooms is by implementin|
78
-------
certain design, maintenance, and housekeeping practices. A 11st of
these practices 1s available from EPA upon request.
Revising the standard to require only that the cell room be
1n compliance with the Occupational Safety and Health Administration
(OSHA) concentration guideline could seriously compromise the intent
of the standard since the occupational exposure guideline applies
to the working environment. Complying with the OSHA regulation
can be accomplished by increasing the ventilation rate of the
cell room; this ventilation air can be exhausted to the atmosphere
without treatment to remove mercury and would not result in any
decrease in mercury emissions.
Considering the above information, the standard was revised
to allow owners and operators the option of either modifying the
cell room so that a stack sampling method can be used or complying
with approved maintenance and housekeeping practices that will
minimize mercury emissions from the CH" room.
Source test data and calculations Indicate that when such
maintenance and housekeeping practices are used, 1300 grams per day
1s a reasonable estimate of emissions from the cell room. Therefore,
when this option is chosen, an emission of 1300 grams per day will
be assigned to the cell room. This permits emissions of not more
than 1000 grams per day from the hydrogen and end box ventilation
streams combined. Compliance of a source with the standard will be
79
-------
determined by the reference method in Appendix B of the standard
or an approved equivalent or alternative method. Under the house-
keeping and maintenance practices option, the determination of
compliance of the cell room emission will be based on the use of
EPA-approved practices.
The following list of housekeeping and maintenance practices
will reduce the mercury vapor concentration in the ventilation effluent
from cell rooms. This list is subject to revision as more effective
practices become available.
a. Chlorine cells and end-box covers should be installed,
operated, and maintained in a manner to minimize leakage
of mercury and mercury-contaminated materials.
b. Daily inspection should be made by operating personnel
to detect leaks, and immediate steps to stop the leaks
should be taken.
c. High housekeeping standards should be enforced, and
any spills of mercury should be promptly cleaned up either
mechanically or chemically or by other appropriate means.
Each cell room facility should have available and should
employ a well-defined procedure for handling these situations.
d. Floor seams should be smoothed over to minimize depressions
and to facilitate washing down of the floors.
e. All floors should be maintained in good condition, free of
cracking and spall ing, and should be regularly inspected,
cleaned, and to the extent practical, chemically decontaminated.
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f. Gaskets on denuders and hydrogen piping should be maintained
1n good condition. Dally Inspection should be made to
detect hydrogen leaks and prompt corrective action taken.
Covers on decomposers, end-boxes, and mercury pump tanks
should be well maintained and kept closed at all times
except when operation requires opening.
g. Precautions should be taken to avoid all mercury spills
when changing graphite grids or balls 1n horizontal
decomposers or graphite packing In vertical decomposers.
Mercury-contaminated graphite should be stored in closed
containers or under water or chemically treated solutions
until it is processed for reuse or disposed.
h. Where submerged pumps are used for recycling mercury
from the decomposer to the Inlet of the chlorine cell, the
mercury should be covered with an aqueous layer maintained
at a temperature below its boiling point.
1. Each submerged pump should have a vapor outlet with a
connection to the end-box ventilation system. The connection
should be under a slight negative pressure so that all vapors
flow into the end-box ventilation system.
j. Unless vapor tight covers are provided, end-boxes of
both inlet and outlet ends of chlorine cells should be
maintained under an aqueous layer maintained at a
temperature below Its boiling point.
k. End-boxes of cells should either be maintained under a
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negative pressure by a ventilation system or should be
equipped with fixed covers which are leak tight. The
ventilation system or end-box covers should be maintained
in good condition.
1. Any drips from hydrogen seal pots and compressor seals
should be collected and confined for processing to remove
mercury, and these drips should not be allowed to run
on the floor or In open trenches.
m. Solids and liquids collected from back-flushing the filter
used for alkali metal hydroxide should be collected in an
enclosed system.
n. Impure amalgam removed from cells and mercury recovered
from process systems should be stored in an enclosed system.
o. Brine should not be purged to the cell room floor. Headers
or trenches should be provided when it is necessary to purge
brine from the process. Purged brine should be returned
to the system or sent to a treating system to remove its
mercury content.
p. A portable tank should be used to collect any mercury
spills during maintenance procedures.
q. Good maintenance practice should be followed when cleaning
chlorine cells. All cells when cleaned should have any
mercury surface covered continuously with an aqueous
medium. When the cells are disassembled for overhaul
maintenance, the bed plate should be either decontaminated
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chemically or thoroughly flushed with water.
r. Brine, alkali metal hydroxide, and water-wash process
lines and pumps should be maintained in good condition,
and leaks should be minimized. Leaks should be corrected
promptly, and in the interim, the leaks should be collected
in suitable containers rather than allowed to spill on
floor areas.
The apportionment of the mercury emission from the cell room was
derived based on the following data and assumptions:
a. EPA has source tested two cell rooms and the emissions and
plant data are presented below:
Date of Rate
Test (Tons Cl2/day)
Feb. 1972
July 1971
300
190
Ventilation Rate
(CFM)
290,000
330,000
Emissions
g/24 hours
152029
98026
b. The capacity of a large mercury cell chlor-alkali plant is of
the order 500 Tons CK/day.
c. The average cell room ventilation volume assumed for a
500 T Cl2/day plant is 630,000 CFM (based on data given above).
d. The concentration of the ventilation gas stream is assumed to
3
be 50 yg/m , the OSHA regulation (time weighed 8 hr average).
Based on the above data and assumptions, a mercury emission
rate of 1285 grams/day was calculated. The emission rate apportioned
to all cell rooms was rounded off to 1300 grams/day and will be assigned
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to a cell room of any size if the housekeeping and maintenance
practices are followed.
4. Some comments argued that variations in the meteorlogical
conditions of specific locations and the production capacity of
individual plants should be considered in the standard. This
comment was considered and rejected because such a standard could
be extremely difficult to administer under the time requirements
of the Act and it would not be considered a "national emission
standard". The procedure used to develop the proposed emission
limit of 2300 grams per day is discussed in this report under
"Development of the Standard". It is estimated that at least
1 to 2 years of study at each source would be necessary to obtain
the required meteorological data to develop a standard for each
source based on the specific meteorological conditions of that
source. This approach is costly and would require a lag time which
is inconsistent with the requirements of the Act; additionally,
Section 112 of the Act directs the Administrator to prescribe
national emission standards.
A proposed alternative that is consistent with being a national
standard and which would avoid the problem of choosing a set of
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meteorological conditions would be to prescribe the standard 1n
the form of an allowable ambient air concentration and measure
compliance by ambient air sampling. This concept Is allowed 1n
the beryllium standard for sources that have three years of
measured air quality data which demonstrates that the beryllium
ambient guideline will be met in the future. Similar ambient data
1s not available for mercury sources. In fact, a sampling method
3
to accurately measure mercury levels of 1.0 pg/m 1s not presently
available; therefore, this alternative could not be used.
The question of allowing a proportional increase in the emission
limit for plants of large capacity is essentially a question of
economics versus health considerations. The larger plants will
find it more difficult to meet the 2300 grams per day limit, but
an Increase 1n the emission limit could result in the ambient
3
mercury concentration exceeding 1.0 yg/m .
After considering the above comments and alternatives, the
mercury standard was not revised. The promulgated standard provides
the maximum assurance that no source will emit mercury in sufficient
o
quantity to cause the ambient concentration to exceed 1.0 ug/m and,
in addition, is a national emission standard whereas most of the other
alternatives are not.
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5. Some comments argued that the standard should not be set
without considering demonstrated control technology for mercury.
Section 112 of the Act does not Indicate that technology for
emission control be considered before a standard 1s promulgated
The major consideration 1n developing a hazardous pollutant
standard 1s protection of the public health.
Technology to control emissions of mercury 1s available but has
not been applied to the primary mercury Industry 1n the United States.
A foreign mercury extraction plant which 1s well controlled and 1s
approximately three times larger 1n capacity than the largest plant 1n
38
the United States, has reported emissions of 450 grams per day from
this plant.
Information obtained from equipment vendors, Industrial
sources, plant operators, and public hearings Indicate that the
standard can be achieved in the mercury cell chlor-alkali plants with
existing control technology. The larger plants will require more
efficient control equipment to comply with the standard since their
emissions are generally greater; however, available Information
Indicates that the standard 1s achievable even for the largest plant.
Emissions from the hydrogen and end-box ventilation system of the
largest plant can be controlled to less than 1000 grams per day with
existing technology. Other than good housekeeping and maintenance
practices, there are no control techniques yet available to remove
mercury from the cell room air. The cell room air can be limited to
an estimated emission of 1300 grams per 24-hour period by use of good
housekeeping and maintenance practices.
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Environmental Impact
A mercury emission Inventory for the United States in 1971
is given in Table 6. To determine the impact of the standard
on reducing the mercury emissions from the affected source
categories, a comparison of emissions before and after the
implementation of the standard can be made. Assuming that the
affected facilities are emitting 2300 grams of mercury per 24-hour
period, the emissions from the primary mercury extraction plants will
be reduced from 33.5 tons of mercury in 1971 to 5.5 tons annually, and
electrolytic chlorine plant emissions will be reduced from 150 tons
of mercury in 1971 to 26.9 tons annually. Thus, the mercury standard
will have a substantial impact on reducing emissions from the
regulated sources. The emission reduction that will be achieved in the
affected sources after the standard is implemented represents about 22%
of the total 1971 U.S. emissions.
The control of mercury emissions required to comply with the
standard for both existing and new sources can generate control
system wastes that can potentially cause considerable environmental
impacts if not properly treated. However, methods are available to treat
or dispose of these wastes; therefore, the atmospheric mercury
emission standard will have only a minor adverse impact in other areas
of environmental concern.
The simplest control for mercury emissions to the atmosphere
is cooling to condense the mercury. Cooling can be indirect
or direct. In indirect cooling, the mercury condenses and is retained
87
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Table 6.
Emissions of Mercury in the United States by Source Category*
Category
Mining
Processing
Reprocessing
Consumptive
Incineration and
Other Disposal
Group
Mercury and Non-Ferrous
**Primary Mercury
Secondary Mercury
Non-Ferrous: Copper
Zinc
Lead
Paint
Electrical
Paint
Agricultural
Pharmaceuticals
**Electrolytic Chlorine
(mercury cell)
Instruments
Dental Preparations
Other
Coal - Power Plants
Other
Oil
Municipal
Sewage Sludge
Other
Emissions in Short Tons
T97T
2.5
33.5
0.5
35.0
11.0
5.0
0.8
2.6
229.0
8.1
4.2
150.0
2.6
0.9
6.9
59,
31,
10.
3
8
2
10.8
4.4
77.5
686.6
After Implementation
of Standard (Annual)
5.5
26.9
*Does not include estimates of crustal mercury emissions.
**Covered by the mercury emission standard (NESHAPS).
-------
for recycle or sale. In direct cooling, e.g. water scrubbing, the
water 1s usually redrculated after using centrifugal or gravitational
separation to remove the mercury. However, some additional treatment
1s eventually required to clean the water. In most cases, the
water used for air pollution control can be treated 1n facilities
currently utilized to prevent mercury discharges Into the water.
A widely used advanced control technique for partlculate mercury
removal 1s the mist eliminator. Residues 1n these devices are removed
by gravity and washing with a recycle liquid. Another advanced
control method 1s chemical scrubbing. In such a system, components
of the scrubbing liquor react chemically with mercury to form mercury
compounds that are subsequently recovered from the solution by various
methods. The scrubbing solution 1s recycled but a bleed stream
from the scrubber system is generally necessitated and requires
additional treatment to remove mercury. Mercury removal methods from
liquid streams are available and can be used to treat bleed streams.
The use of adsorption beds is a highly efficient advanced control
method for removing mercury from gas streams. Two primary types are
available: (1) chemically treated activated carbon beds and
(2) molecular sieves. The use of activated carbon produces a solid
waste that requires ultimate disposal since no acceptable method of
completely regenerating the spent carbon is currently available; however,
little environmental contamination results because this waste is properly
disposed of by the sources in segregated dumps. Ideally, most of the mercury
collected can be reclaimed by retorting the spent carbon, but this usually destroys
89
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the carbon structure and necessitates disposal of the decomposed
carbon that contains small amounts of residual mercury. This waste
can be disposed of with little environmental Impact 1n appropriate
dumping sites. The use of regenerative molecular sieves does not
Involve as great a solid waste disposal problem because of the
sieve's much longer bed life and because retorting to remove the
mercury prior to disposal of the bed 1s not required.
In general, control methods required to control mercury emissions
to levels within the emission standard will produce waste products
that may require disposal; however, appropriate disposal methods are
available and the adverse environmental Impact caused by the standard
will be minor.
Economic Impact
Although the standard was not based on economic considerations,
O/l
EPA 1s aware of its economic impact and considers it to be reasonable
under the circumstances. Because mercury is an international commodity,
world prices determine the fortunes of the U.S. domestic mercury mining
industry. Historically, mercury prices fluctuate greatly in response to
small changes in demand or supply. The metal is on the strategic
and critical materials list and is subject to stockpiling by the
General Services Administration.
Domestic mercury mines are considered high-cost producers
in relation to foreign producers. For comparative purposes,
U.S. ore averages about 5 pounds of mercury per ton, whereas
Spanish and Italian ores average, respectively, about 50 and 15
90
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pounds of mercury per ton. Marginal prices required for domestic
production range from $360 to $400 per flask for underground
operations and from $270 to $300 for open-pit operations.
Due to a decline in demand for mercury and a subsequent
world overproduction, the price of mercury decreased from $404
per 76-pound flask in 1969 to a low of $145/flask in April 1972.
As a result, the number of U.S. primary mercury ore processing
plants in operation declined from 109 in 1969 to fewer than 10 in
April 1972. The price of mercury has increased to $320/flask
in March 1973 due in part to more effective European marketing practices
and an international devaluation of the U.S. dollar. This increase,
however, has not been sufficient to cause the domestic industry to
reopen the mines that were closed. Currently only 6 or 7 primary mercury
extraction plants remain in operation.
The effects of international trade and stockpiling upon the
domestic mercury mining industry can be shown by the following
1968 statistics from the Bureau of Mines:
Source Supplies (76# Flasks)
T9SST
U.S. Mines 28,874
Metal Imports, Net 16,374
Secondary Metal Recovery 13,670
GSA and AEC Releases 20.710
TOTAL 80,628
Based on these data, domestic mines contributed 36 percent of the
U.S. supply available for consumption and industrial stocks at a
time when the price was high (approximately $535). Preliminary
91
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statistics released by the Bureau of Mines show U.S. mine production
declining to 6,296 flasks in 1972. Net imports increased to
28,778 flasks, and the metal recovered from secondary mercury
operations has remained fairly constant and was 12,598 flasks in 1972.
Demand for mercury is concentrated in the chlorine-caustic
production industry, electrical products manufacturing (batteries,
lamps, apparatus, wiring devices), and paints and allied products.
Total industrial consumption in 1968 was 75,422 flasks; and in 1971,
it was 52,475 flasks. It is used in the chlorine-caustic industry
as a cathode in mercury-amalgam cells for the electrolysis of
sodium chloride brines. The increased use of diaphragm cells
in place of mercury cells, as well as the use of more efficient mercury
cells, has been the recent trend in the chlorine-caustic industry.
One significant factor is the emphasis on restricting mercury
discharges into water. As a result, consumptive use of mercury for
this particular application may be trending downward. A drop in
consumption of mercury for cells from 17,000 flasks in 1968 to
15,000 flasks in 1970 to 12,260 in 1971 suggests this.
A domestic mercury mine processing 100 tons of ore per day will
require an investment of approximately $108,000 in control devices
to meet the standard. This amounts to 27 to 36 percent of the
capital invested in processing equipment. The annualized cost of
$32,000 will amount to about 4.5 percent of sales, based on a current
sales price of $320 per flask.
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The value of additional recoverable mercury will partially
offset the control costs. Based on the current depressed market,
the net control costs will have to be absorbed by the producers,
possibly forcing shutdown of some roasters. Those affected will
be the marginal direct-fired ore roasters that have no controls.
No Impact 1s seen for the retort operations because these are probably
already meeting the standard.
Some 16 companies operate 29 domestic mercury cell chlor-alkall
plants. The total chlor-alkall Industry Is comprised of 66 plants, which
Includes 37 diaphragm-cell plants. The mercury cell chlorine process
accounts for about 25 percent of the U.S. production of chlorine and
caustic.
The capital investment required to control a 100-ton-per-
day mercury cell chlorine plant within the standard is about $160,000
for the process gas streams. This assumes that cell room good
housekeeping practices are 1n effect. The original plant investment
for such a plant is approximately $10 million; therefore, the
required control cost for this size plant is about 1.6 percent of the
original investment. The annualized cost for controls in
this case 1s approximately $48,000. The annual sales for this
operation will yield an estimated $5.3 million in chlorine and caustic
products, and the annual1zed cost will amount to 1 percent of sales.
The future of the chlorine-caustic industry appears healthy.
Demand for chlorine is expected to grow at an annual rate of 6 percent
projected from 1971. Demand for caustic soda will grow at
least at the same rate as the demand for chlorine, and perhaps faster.
93
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Prices for chlorine and sodium hydroxide have been rising steadily through
the sixties into 1971. Based on these trends, the cost of control
will be passed forward to the consumer. Use of these two basic
commodities is so diverse that any price increases will be well
dispersed through all manufacturing activities. High-grade caustic,
which can be produced by mercury cell plants at lower cost than by
diaphragm cell plants, will be needed in those market areas serving
the textile and plastics industries. This should keep those competitive
mercury cell plants operating in spite of increased air and water
pollution abatement costs.
The older, marginal mercury cell plants may be closed, probably
to be replaced by diaphragm-cell plants. If this occurs, the
decline in mercury usage for the chlorine-caustic industry will
accentuate the depressed conditions in the domestic primary mercury
production industry.
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Mercury Vapors in Man. Ind. Med. Surg., 34^, 580-584, 1965.
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14. Wood, J.M. F.S. Kennedy, and C.G. Rosen: Synthesis of
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«.- -' «• _ •.- '-*» .i>
15. Jensen, S., and A. Jerneldv: Biological Methylation of Mercury in
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T. Ukita: Chemical Methylation of Inorganic Mercury with Methyl-
cobalamin, a Vitamin B12 Analog. Science, 172, 1248-1249, 1971.
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27. Roy F. Weston, Inc., BASF Wyandotte Mercury Chlor-Alkali Plant,
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Clara Quicksilver Co., New Almaden, California. EPA Contract
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ft 0. P. O. 1973 - 746-770 / 4172 _ _
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