United States        Office of Prevention,        EPA 744-R-00-010
Environmental Protection    Pesticides and            August 2000
Agency          Toxic Substances (7401)         www.epa.gov
Sampling and Analysis of
Consumer Garden
Products That Contain
Vermiculite

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                                     FOREWORD

     EPA'S INVESTIGATION OF ASBESTOS-CONTAMINATED VERMICULITE

       The Environmental Protection Agency has conducted sampling  of vermiculite products,
primarily those used in gardening, to determine if products currently on the market contain asbestos,
and if so, whether consumers are at risk from using these products.  To evaluate the risk posed by
compounds such as asbestos, EPA needs to determine if the contaminant is present in certain
products and also whether people come in contact with sufficient quantities to cause harm. Asbestos
poses a risk to people if fibers become airborne and are inhaled into the lungs.  As described in more
detail below, and  in the accompanying reports, the results of this investigation indicate  that the
potential exposure to  asbestos from  vermiculite  products poses only a minimal health risk to
consumers, although workers may face more serious risks.

       Vermiculite is produced from mined ore and is used in agricultural and horticultural products
as well as in insulation and construction applications.   As a  first step in  the process, the  Agency
purchased and began testing a limited number of vermiculite products available in garden stores in
the Seattle area to determine if they were contaminated with asbestos. Sixteen products were tested
using widely-recognized standard protocols and asbestos was detected in five of them.  However,
only three of these contained enough asbestos to allow EPA to quantify the percentage of asbestos
reliably.

       To determine whether the asbestos fibers in these three products could become airborne and
present a potential exposure hazard during use, EPA's Seattle office placed the products into a glove
box, a small, enclosed  metal box with  gloves,  and handled them as they would during normal use.
EPA collected  and analyzed air samples, and determined that one of the products tested  generated
relatively high levels of asbestos.   This finding prompted the Seattle office to recommend that
consumers refrain from using that particular vermiculite  chemical packaging material. This product
is apparently no longer available to consumers at garden stores.

       EPA then  decided to expand  the scope of its analysis,  to include additional vermiculite
products available nationally, and to calculate the risk posed in cases where airborne asbestos fibers
were detected during product handling. The Agency, through its expert contractors, purchased and
analyzed 38 products from around the country and detected asbestos in 17 of them.  Of these, only
five contained quantifiable levels  of  asbestos.  EPA scientists, along with  the contractors,  then
conducted two simulated consumer use scenarios. One simulation was performed indoors in a "still
air" environment (a 10'xlO'xlO' enclosure) in an attempt to represent consumer use in a small garage
or greenhouse. The other simulation was performed outside in open air.

       As described in the attached report, there is a lot of variability in the observed results.  In
some cases, one sample of a product indicated the presence of asbestos while another did not.  This
variability is likely due to a number of factors including the following: (1) the asbestos content of the
vermiculite products appears to be very close to the technological limit of detection, so one  test
might detect the presence of asbestos while a second one would not;  (2) only a very small portion
(0.01 grams) of each product is actually viewed under the microscope, although individual bags may

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contain up to several cubic meters;  (3) the bagged product is not homogeneous; (4) different
processing facilities use different dust removal techniques; (5) there are differences in the asbestos
content of vermiculite ore from different mines; and (6) asbestos content varies throughout the
vermiculite deposits in each mine.

       The results of this investigation indicate that consumers face only a minimal health risk from
using vermiculite products at home or in their gardens. Vermiculite may, however,  present more
serious risks in an occupational setting, where the duration and frequency of exposures are likely to
be significantly greater. EPA is concerned about potential occupational exposures and has provided
this report to OSHA to assist that agency in evaluating the hazards to workers from vermiculite.

       To further reduce the low risk associated with the occasional use of vermiculite products
during gardening activities, EPA recommends that consumers:

•      Use vermiculite outdoors or in a well-ventilated area.
       Avoid creating dust by keeping vermiculite damp during use.
•      Avoid bringing dust into the home on clothing.

       Although EPA does not endorse the use of any particular product, consumers may choose to
use:

       Premixed potting soils, which ordinarily contain more moisture and less vermiculite than pure
       vermiculite products and are less likely to generate dust.
       Soil amendment materials other than vermiculite,  such as peat, sawdust, perlite, or bark.

       The following  reports describe the sampling and analysis of vermiculite products conducted
by EPA.  The first attachment is the report of the sampling conducted by EPA's Seattle office.  The
second is the report of the national sampling performed for EPA by its contractor, Versar, Inc.

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REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
                         July 26, 2000
            U.S. Environmental Protection Agency
             Region 10, Office of Environmental Assessment
                 Investigation and Engineering Unit
                          Seattle, WA
                Jed Januch and Keven McDermott
                         Investigators

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                         ACKNOWLEDGMENTS
       We received tremendous support and assistance from many of our co-workers at EPA.
We would like to thank the following EPA Region 10 staff who contributed significantly to the
quality of the Region  10 Investigation of Asbestos in Vermiculite: Lorraine Edmond, M.S.,
David Frank, Ph.D., Richard Mednick, J.D., David Terpening, Marion "Doc" Thompson, Michael
Watson, Ph.D., Philip Wong, P.E., and Bruce Woods, Ph.D.  We sincerely appreciate the
contributions of Robert Jordan, Ph.D., EPA headquarters, who provided technical assistance.

       We would also like to thank Susan Davis, Washington State Department of Ecology, and
John Harris,  MPH, and his staff at Lab/Cor,  Inc. for analyzing our samples.  We greatly
appreciate the efforts of Janine Rees,  Washington State Department of Labor and Industries, who
helped design the air monitoring protocols used in the investigation.

       Our special thanks to Rene Fuentes,  P.E., EPA Region 10, Phillip Peters, MSPH,
Washington  State Department of Labor and Industries, and Christopher Weis, Ph.D., EPA
Region 8, for their peer review of the Region 10 Investigation of Asbestos in Vermiculite report.
Their technical expertise and attention to detail was invaluable in crafting our final report.

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                       TABLE OF CONTENTS



EXECUTIVE SUMMARY


INTRODUCTION


PHASE I

      Properties of Vermiculite
      Properties of Asbestos
      Summary of Interviews


PHASE II

      Bulk Samples of Vermiculite Products
      Summary of Analysis of Bulk Samples


PHASE III

      Collection of Air Monitoring Samples
      Summary of Analysis of Air Monitoring Samples


CONCLUSIONS


REFERENCES

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
                          EXECUTIVE SUMMARY

       In January 2000 the Environmental Protection Agency Region 10 office in Seattle,
Washington, began testing a limited number of lawn and garden products that contain vermiculite
to see if these products were contaminated with asbestos. The investigation was prompted by
calls from citizens who became concerned after reading a series of articles in the Seattle
Post-Intelligencer about asbestos contaminated vermiculite.  Many callers specifically asked if
vermiculite products currently sold in the Seattle area contained asbestos, and if consumers could
be exposed to asbestos when using these products.

       Sixteen different products containing vermiculite were purchased at Seattle area retail
stores. The products selected were available either regionally or nationally. Samples from the
products were analyzed using two different types of microscopes. Five of the products were
contaminated with asbestos.

       Three of the five products that contain measurable amounts of asbestos underwent further
testing. EPA investigators worked with these products in a confined area to simulate how a
typical consumer might use them, while air monitoring samples were taken. This was done to
determine whether asbestos present in the vermiculite could become airborne during use and
possibly expose the consumer to asbestos. One of the three asbestos-contaminated products
tested by Region 10 released asbestos fibers into the air.  The other two products tested did not.

       The results of the EPA Region 10 investigation show some vermiculite products currently
on the market contain asbestos. The amount and types of asbestos found in the vermiculite
products tested by Region 10 varies.  Because consumers have no way of knowing which
vermiculite products contain asbestos and which do not, EPA Region 10 recommends that
consumers follow basic precautions to reduce potential exposure to asbestos when handling
vermiculite.

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

                                INTRODUCTION

       Vermiculite is the name of a mineral that has been mined commercially in the United
States since the early 1920s.  Vermiculite is often found with other minerals including various
forms of asbestos. There are four active Vermiculite mines in the United States.  A fifth mine in
Libby, Montana, closed in  1990, but ore may have been shipped from the mine until 1992.1

       The Libby mine, formerly owned and operated by the W.R. Grace and Company, was
known to contain deposits  of fibrous tremolite asbestos.  Between 1980 and 1991 there were
several studies conducted for or by the Environmental Protection Agency dealing with sampling
and analysis of vermiculite, the potential for exposure to asbestos through consumer and
occupational use of vermiculite, and possible health effects associated with exposure to asbestos-
contaminated vermiculite.  These studies indicated that other vermiculite mines in the United
States may also be contaminated with asbestos.2

       In November 1999  the Seattle Post-Intelligencer published a detailed series  of articles
about the vermiculite mine in Libby, Montana, and the miners and their families who died or
became ill from exposure to asbestos in the vermiculite ore.3  As a result of these articles EPA
Region 10 received numerous calls from citizens who feared they might have been exposed to
asbestos while working with vermiculite or from having it as insulation in their homes.  Many
callers specifically asked if vermiculite from the Libby mine is still being sold, whether the
vermiculite insulation in their homes presents a health hazard, and whether vermiculite from other
mines that is currently sold is also contaminated with asbestos.

       These calls were referred to the Investigation and Engineering Unit (TEU) of the Office of
Environmental Assessment. IEU investigators routinely receive tips and calls from  citizens with
environmental concerns or complaints, and conduct follow-up investigations. Because of the
nature and volume of calls, the IEU began an investigation to see if vermiculite products  currently
sold in the Seattle area contain asbestos and, if so, could the asbestos present in those products
become airborne during use.

       The investigation had three distinct phases.  In Phase I, investigators  gathered information
about vermiculite by reviewing available literature and conducting interviews. This information
was used to help design the sampling and analytical protocols used in subsequent phases. In
        U.S. Geological Survey, Vermiculite Minerals Yearbook, 1990. Michael J. Potter
       2 See references 5,8,9, and 10
       ' Andrew Schneider. Senior National Correspondent. (November 18, 1999). "Uncivil Action: A town left
       to die", Seattle Post-Intelligencer, p. 1 Section A

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

Phase n, investigators purchased sixteen different vermiculite products, took samples from each
product, and had the samples analyzed to see if asbestos was present.  Those products that were
found to contain measurable amounts of asbestos went through additional testing.  In Phase in,
investigators simulated the use of the contaminated products in a contained area while taking air
monitoring samples, and had those samples analyzed to see if asbestos present in the bulk material
became airborne during use.

                                      PHASE I

       During Phase I geologists with the Region 10 Office of Environmental Assessment
assisted IEU investigators in identifying historical and technical literature about  vermiculite mines
and potential for asbestos contamination at those mines. The documents reviewed by IEU
investigators are listed in the references section of this report.  Region 10 geologists are also
investigating the feasibility of using various analytical methods to trace vermiculite in consumer
products to the mines from which it originated.

PROPERTIES OF VERMICULITE

       Vermiculite is defined as a hydrated magnesium-aluminum-iron sheet silicate mineral of
various compositions.4  After vermiculite ore has been mined and crushed, it is sized and sorted,
at which point it becomes known as vermiculite concentrate. The concentrate is shipped to
processing plants, where it is  expanded or exfoliated by heating it in a furnace to temperatures
ranging between  1,600 to 2,000 degrees Fahrenheit.5  After exfoliation its appearance is similar to
a small, brown, accordion-shaped granule.

       Vermiculite is resistant to combustion.  Un-exfoliated vermiculite is used in various
manufacturing processes including gypsum wallboard, paper products, coatings and cinder blocks.
Exfoliated vermiculite is absorbent and lightweight. It is used in  fireproofmg, insulation, as a
carrier for agricultural chemicals, as an ingredient in lawn and garden products,  as a packaging
material and as an underlayment for swimming pools.

       Vermiculite deposits are found in  similar geologic settings around the world. Many
contain asbestiform minerals as contaminants. There are four active vermiculite mines in the
United States.  Two are located in the Enoree district of South Carolina, one in Louisa  County
Virginia, and one in Dillon, Montana. Previous geological studies, cited in references 3, 4, and 5
of this report, have established that all four of these mines contain asbestiform minerals.
       4 Vermiculite. Bureau of Mines Bulletin #675, 1985

       5 Vermiculite Association, http://venniciilite.org/aboiitventiiciilite.htm (2/9/00)

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

PROPERTIES OF ASBESTOS

       Asbestos is the name given to six different types of fibrous minerals that occur naturally in
the environment.6 The technical names for the six types of asbestos are listed in the Code of
Federal Regulations.7 Asbestos minerals are divided into two major groups - serpentine and
amphibole, which differ from each other both physically and chemically.8 The minerals in both
groups are made up of fibers that vary in length and diameter.  The amphibole group includes
fibrous actinolite and tremolite, which are commonly associated with vermiculite as naturally
occurring contaminants.

       Asbestos has been mined for use in many types of manufactured products, including
roofing and flooring materials, cement board, brake and transmission components, gaskets, pipe
insulation, and heat-resistant fabrics.  In these manufactured products asbestos is deliberately
added as an ingredient.

       Adverse health effects associated with exposure to asbestos have been known for many
years.  During the twentieth century the link between asbestos exposure and chronic respiratory
disease has been clearly established. Inhalation of asbestos fibers has been shown to cause
asbestosis, and can lead to increased risk of lung cancer and mesothelioma.9

       The Environmental Protection Agency and the Occupational Safety and Health
Administration are the two primary federal agencies that have promulgated regulations designed
to reduce potential exposure to asbestos in the environment and in the workplace.  Additional
regulations have also been developed by state and local governments  for the same purpose.

SUMMARY OF INTERVIEWS

       Since the media coverage about asbestos in vermiculite began in November 1999, EPA
Region 10 has received dozens of calls from citizens around the country, who were concerned
that they might have been exposed to asbestos while working with vermiculite products. Calls
came from hobby and professional gardeners, a hospital technician who uses vermiculite in
prosthetic devices for children, several laboratory workers, people who installed vermiculite
       6 lexicological Profile for Asbestos, ATSDR, Atlanta, GA

       7 40 CFR Part 61 Subpart M section 61.141 "Asbestos means the asbestiform varieties of serpentine
       (chrysotile) riebeckite (crocidolite), cummingtonite-grunerite, anthophyllite, and actinolite-tremolite."

       8 Asbestos NESHAP Inspection and Safety Procedures Workshop, Student Manual, APTI Course, Second
       Edition (Revised 1999)

       9 lexicological Profile for Asbestos, ATSDR, Atlanta, GA

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

insulation in their attics, construction workers who used vermiculite, and former employees of
vermiculite expansion plants. Many of the callers were from the Pacific Northwest, but some
were from as far away as Florida, Tennessee, and Michigan.  Callers described how they used
vermiculite and discussed their specific health concerns. The information collected from the
callers was important to help understand how vermiculite is processed and how individuals handle
products that contain vermiculite. A summary of the information provided by these callers is
included in Appendix 1 of this report.

                                     PHASE II

       Phase n of this investigation was designed to identify vermiculite products available to
consumers through retail outlets in the Seattle metropolitan area, and to determine if the products
selected for analysis are contaminated with asbestos. This was a limited study that looked at a
relatively small number of products. The study was not statistically based.  The information
collected in Phase II was intended to help determine which products warranted further testing in
Phase IE, and to provide the rationale for future statistically based studies.

BULK SAMPLES OF VERMICULITE PRODUCTS

       IEU investigators visited nine retail stores in the Seattle metropolitan area that sell lawn
and garden products. Sixteen different vermiculite products were selected from store shelves and
purchased.  The selection was based on available products. There was no attempt made to target
specific brands or manufacturers. Seven of the products contained vermiculite as the primary
ingredient.  The nine other products were potting soils that contained vermiculite as well as other
ingredients.  One of the sixteen products selected was Zonolite Chemical Packaging Vermiculite,
which while labeled for use  as a packaging material, was offered for sale to consumers in two
different retail stores for home gardening use.

       Prior to taking samples from the sixteen products, IEU investigators examined the
different analytical methods used to analyze bulk materials for asbestos content. After
consultation with Region 10 quality assurance staff and the microscopists who would later analyze
the samples, IEU investigators made the decision to analyze bulk samples using a bulk test
method for determination of asbestos in building materials.10

       The sixteen vermiculite products were delivered under chain of custody to the Manchester
Environmental Laboratory (MEL), located in Port Orchard, Washington, where they were
sampled under a fume hood to prevent possible release of asbestos fibers.  The samples were
       10 Method for the Determination of Asbestos in Bulk Building Materials, EPA600-R-93-116. Research
       Triangle Institute, July 1993

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

analyzed at MEL using stereo microscopic examination to determine homogeneity and preliminary
fiber identification. Polarized light microscopy (PLM) was used to determine the optical
properties of fibers and provide qualitative identification of suspect fibers. Samples were also
analyzed at Lab/Cor, Inc. in Seattle, WA, using transmission electron microscopy (TEM) to
positively identify and quantify the amount and type of asbestos present in the samples.

       Three different groups of samples were taken from the sixteen products.  MEL analyzed
the first and second set of samples as rinsed residues. MEL did not analyze a third set of samples.
Lab/Cor, Inc. analyzed the first and second set of samples it received as dust or particulate.  The
third set of samples sent to Lab/Cor, Inc. were analyzed as rinsed residues. The technique of
preparing rinsed residue samples for analysis is described in the following section of this report.

       The first group of samples were taken using an EPA technique for sampling dry products
in bags.11 These samples were intended to be representative or typical of the vermiculite product
in the containers (bags). For this group of samples a hollow plastic tube approximately one inch
in diameter was inserted diagonally through a hole in each bag, and cross sections of the contents
were drawn out of the plastic tubes into new clean 4-ounce glass jars. For larger bags a stainless
steel tube was used to remove the vermiculite from the bag. The jars containing the vermiculite
products were labeled with  laboratory sample numbers and EPA custody seals were placed over
the lids of the containers. The samples were handled under standard chain of custody and
submitted for analysis. One set from the first group of samples was sent to MEL for analysis, the
other set was sent to Lab/Cor, Inc. Both MEL and Lab/Cor, Inc. received a quality assurance
duplicate of two of the sixteen products.  The bags of product from which the samples were taken
were marked with laboratory sample numbers and stored in a locked sample custody area at
MEL.

       The second group of bulk samples was taken from three of the vermiculite products
(Whitney Farms Vermiculite, Zonolite Chemical Packaging Vermiculite, and Therm-O-Rock
Vermiculite) that were shown to be contaminated with asbestos during analysis of the first group
of samples. For this group  of samples approximately one to two quarts of vermiculite were taken
from the bottom of the bag  after it had been moderately shaken. The vermiculite was separated
through a series of USA Standard Testing Sieves (size No. 10 and No.3 5) so a sample of the fine
material at the bottom of the bag could be segregated from the larger particles of vermiculite.
The fines were collected in  a pan at the bottom of the lower sieve and transferred into new, clean
2-ounce glass jars. Duplicate samples from the three products were delivered to both the MEL
and Lab/Cor, Inc. under standard chain of custody and submitted for analysis.  Quality assurance
samples in the form of field duplicates were collected for two of the products.  Cole's Cactus Mix
was not included in this group because other components of the mix made it difficult to sift.
       11 Pesticide Product Enforcement Manual 1994 Chapter on Sampling

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

       The technique used for the second group of samples was designed to isolate and analyze
the fines that accumulate in the bottom of the bag.  This was done to see if asbestos detected in a
bag of vermiculite was evenly distributed throughout the bag or was present in higher
concentrations in the lower fractions of the bag. These samples were not intended to be
representative of the contents of the bag as a whole.

       A third set of samples was prepared by MEL for Lab/Cor, Inc. MEL split the rinsed
residue samples from group two, which consisted of samples taken previously from Whitney
Farms Vermiculite, Zonolite Chemical Packaging Vermiculite, and Therm-O-Rock Vermiculite.
This set of samples was analyzed by Lab/Cor, Inc. using TEM.

Bulk Sample Preparation and Analysis performed by the Manchester Environmental
Laboratory12

       MEL analyzed bulk samples using a rinsed residue technique intended to isolate and
identify asbestos in vermiculite.  To prepare the rinsed residue, a 40 ml sub-sample of vermiculite
was placed into a beaker.  The vermiculite was rinsed with  80 ml of deionized water in an attempt
to wash any loose asbestos fibers from the vermiculite matrix.  After the vermiculite floated to the
surface, 7 ml of water was extracted from the bottom of the beaker using a syringe and was
injected into a crucible.  The crucible was covered and  placed in a drying oven at 68° centigrade
for two to three days until all the water had evaporated. The residue that remained in the bottom
of the crucible was then scraped out and placed onto a microscope slide and a drop of 1.605
refractive index oil was added.  Any remaining residue  was scraped into a small vial for possible
future use.

       Using a Nikon Opti-Phot Pol microscope at 400X magnification, the sample was  scanned
for the presence of fibers with an aspect ratio greater than five to one (5:1).  Cleavage fragments
were not counted as fibers because many are too small  to see and positively identify using PLM.
Straight, needle-like fibers that were identified  as possible actinolite/tremolite fibers were checked
for diagnostic optical properties such as angle of extinction, sign of elongation,  and central stop
dispersion staining. If asbestos was found, a determination of "PNQ" (Present Not Quantified) or
"TRACE" (a trace of the subject parameter was present) was reported.  Rinsed residues  of
positive samples were sent to Lab/Cor, Inc. for confirmation using TEM analysis.
       12 Susan E. Davis, laboratory technician - microscopist, Washington Department of Ecology7

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REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
      Actinolite fiber in Zonolite Chemical Packaging Vermiculite viewed by PLM13
            Tremolite fiber in Whitney Farms Vermiculite viewed by PLM
                                                            14
    13
      Sample number 54205. Fiber is 20 to 22 microns in length
    14
      Sample number 54203. Fiber is 10 to 15 microns in length

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
                                                                 15
Bulk Sample Preparation and Analysis performed by Lab/Cor, Inc.

       For each sample of vermiculite collected by IEU investigators, Lab/Cor, Inc. took
sub-samples from at least three randomly selected areas within that sample. The sub-samples
were weighed (Raw Material Weight) on an analytical balance (0.1 milligram sensitivity), ashed in
a muffle furnace at 480° Centigrade to remove the organic component, and weighed again (After
Ash  Weight). After a brief dissolution of the acid soluble component in concentrated hydrochloric
acid, the suspension was immediately diluted in about 20 ml of 0.2 micron (urn) - filtered
deionized water, and filtered through a dry pre- weighed 0.1 micron poly-carbonate (PC) filter.
After drying, the filter was weighed again (After Hydrolysis Weight) and processed using a
preparation technique described in a draft EPA report entitled "Methodology of the Measurement
of Airborne Asbestos by Electron Microscopy".16

       The samples were coated with a thin film of carbon in a vacuum evaporator. After
dissolution of the filter debris in l-methyl-2-pyrrolidinone, the sample was placed on a 200 mesh
copper TEM grid and examined under a Philips 410 transmission electron microscope  equipped
with energy dispersive x-ray spectroscopy (EDAX PV9800 X-ray analyzer).  Samples were
scanned at magnification of approximately 500X using an accelerating voltage of 100KV. The
magnification was increased to 10,OOOX to identify any smaller asbestos fibrils (a small, slender
fiber) that might be present.

       TEM analysis was used for confirmation of particulate morphology as viewed at high
magnification. Electron diffraction was used to identify mineral structure and energy dispersive
spectroscopy (EDS) was used to provide chemical composition of particulates. After
confirmation of the principal mineral type by diffraction and EDS, a visual estimate of the
concentration of asbestos relative to non-asbestos was determined. Fibers of any length with an
aspect ratio of at least 5:1 and proper chemistry were counted as asbestiform regulated mineral
types. Cleavage fragments may have been identified as asbestiform regulated mineral fibers in this
analysis.

       The first PLM analysis of samples taken from bags  of four products, Scotts Vermiculite,
Whitney Farms Vermiculite, Zonolite Chemical Packaging Vermiculite,  and Therm-O-Rock
Vermiculite, revealed traces of asbestos. The initial TEM analysis of two duplicate samples
obtained from a bag of Zonolite Chemical Packaging Vermiculite  revealed the product contained
0.56% and 0.47% asbestos.  Analysis of a sample obtained  from the  bag of Coles Cactus Mix
contained 0.45% asbestos. The types of asbestos detected by using both PLM and TEM belong
       13 John Harris, LAB/COR, Inc., Seattle, Washington

       16 Yamate, G.. S.C. Agarwall, R.D. Gibbons. ITT Res
       of Airborne Asbestos by Electron Microscopy." Draft report, US EPA Contract 68-02-3266, July 1984
16 Yamate, G.. S.C. Agarwall, R.D. Gibbons. ITT Research Institute. "Methodology of the Measurement

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

to the amphibole group and were reported specifically as either tremolite or actinolite. Copies of
the results of PLM analysis of bulk samples from the MEL are included in Attachment 1. Copies
of the results of TEM analysis of bulk samples by Lab/Cor, Inc. are included in Attachment 2.

       The second set of samples taken from material that had settled to the bottom of the bags
of Zonolite Chemical Packaging Vermiculite and Therm-O-Rock Vermiculite revealed a higher
concentration of asbestos than the initial samples taken from the upper parts of the same bags.
Using TEM analysis the sifted samples of Zonolite Chemical Packaging Vermiculite contained
1.88% asbestos, the sample of Therm-O-Rock Vermiculite contained 0.33% asbestos.

       The rinsed residues of Zonolite Chemical Packaging Vermiculite and Therm-O-Rock
Vermiculite were analyzed using both PLM and  TEM.  Tremolite fibers were identified by PLM,
but were not quantified due to limitations of magnification.  These  same residues were sent to
Lab/Cor, Inc. for TEM analysis. Analysis of the residue sample of Therm-O-Rock Vermiculite
using TEM revealed 0.30% asbestos.  Analysis of duplicate quality assurance samples of Zonolite
Chemical Packaging Vermiculite using TEM revealed 0.10% and 2.79% asbestos.  This illustrates
the apparent variability in concentrations of asbestos that can exist in splits of the same sample.

ORIGIN OF ASBESTOS CONTAMINATED VERMICULITE PRODUCTS

       Zonolite Chemical Packaging Vermiculite was produced from ore from the W.R. Grace
mine in Libby, Montana, which closed in  1990.17 Therm-O-Rock West obtains vermiculite ore
from the W.R. Grace mine in Enoree,  S.C., and from a mine in South Africa, and processes the
ore into the finished product sold as Therm-O-Rock Vermiculite.18 L&L Nursery Supply, Inc.,
which formulates Cole's Cactus Mix,  uses Therm-O-Rock Vermiculite in its products that contain
vermiculite.19

SUMMARY OF ANALYSIS OF  BULK SAMPLES

       Sixteen vermiculite products currently available for purchase by consumers in the Seattle
metropolitan area were examined for asbestos content using two different types of microscopic
analysis, PLM and TEM. Three products contained measurable amounts of asbestos using TEM
analysis: Zonolite Chemical Packaging Vermiculite, Therm-O-Rock Vermiculite, and  Cole's
Cactus Mix. Four of the sixteen products sampled contained trace amounts of asbestos using
PLM analysis: Zonolite Chemical Packaging Vermiculite, Therm-O-Rock Vermiculite, Scott's
       17 Telephone conversation with William Corcoran, W.R. Grace and Company. April 4. 2000

        Telephone conversation with Ron Dobkin, owner, Therm-O-Rock West, February 24, 2000

       19 Interview with Dan Froli, general manager. L&L Nursery Supply, Inc., Fife. WA. February 18. 2000

                                          10

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

Vermiculite, and Whitney Farms Vermiculite. Asbestos was observed in Zonolite Chemical
Packaging Vermiculite and Therm-O-Rock Vermiculite using both PLM and TEM. The
analytical results for bulk samples are summarized in Table  1 on the following page.

       The Region 10 investigation showed that bulk samples taken from vermiculite are not
homogeneous.  Concentrations of asbestos in vermiculite vary between products and within
samples taken from the same product. The asbestos may also stratify  and concentrate on the
bottom of the bags of vermiculite during shipping, storage, and handling.  Sampling methods and
sample preparation can affect whether asbestos is found and what concentration is measured.
                                    CHEMICAL
                                   PACKAGING
      Products that contain measurable quantities of asbestos when analyzed by TEM
            Tne
                   ot CaMama hee enacted legMattc
nty known aa Proportion «e. wHch
            requfree that peraons be infarroed of any potential expoeure to
            carcinogens by me State. As a result. nundnadB of conwnonly used consumer products
            now carry Prop. 66 warning labeta. Construction products such as limestane, Portland
            oamont and gravel are atoo aukjaot to taiiatnj under Protx 85  In order to comply wNh
            current mtarproMtona and poaaJbte future addMuiia to ttw State's ReMng. the fotowtng
            «MrnJno * orowtded:
                                     WARNING
                            TMe product
                            to tfia 9lata of
   Warning statement on the back of a bag of Zonolite Chemical Packaging Vermiculite

-------
 REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

                            TABLE 1
PRODUCTS

Shultz Vermiculite, 8 qt.
Professional Jiffy Mix
Potting Soil, 8qt.
Sam's Choice Professional Potting
Soil, 10 Ib.
Black Gold Vermiculite, 12 qt.
Therm-O-Rock, 4 cubic ft.
Scotts Vermiculite, 8 qt.
Whitney Farms Vermiculite, 4 qt.
Black Gold Seedling Mix
Country Cottage Professional Seed
Starter, 8 qt.
Zonolite Chemical Packaging
Vermiculite, 19 Ib.
Scotts Progro Professional
Potting Mix, 25 qt.
Coles Vermiculite
Coles African Violet Mix, 4 qt.
Coles Cactus Mix, 4 qt.
Coles Lighthouse Plant Mix, 8 qt.
Schultz Seed Starter
Zonolite (bag #2)
SAMPLE #

54202
54208
54209
54200
54207
54204
54203
54216
54215
54205
54206- QA
54217
54201
54213
54214
54210
54211
54212- QA
104200
PLM
Group 1
ND
ND
ND
ND
Trace
Trace
Trace
ND
ND
Trace
Trace
ND
ND
ND
ND
ND
PNQ
ND

PLM
Group 2
Sifted Residue




ND

ND


PNQ






ND
TEM
Group 1
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.56%
0.47%
ND
ND
ND
0.45%
ND
ND
ND

TEM
Group 2
Sifted




0.33%

ND


1.88%






ND
TEM
Group 3
Sifted Residue




0.30%

ND


0.10%
2.79%
ND






ND    none detected
PNQ   present but not quantified
QA    quality assurance
                               12

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

                                     PHASE III

       Once the analysis of bulk samples identified which vermiculite products contained
asbestos, the next step was to determine if the asbestos in the vermiculite could become airborne
during use and present a potential exposure hazard for individuals who work with the asbestos-
contaminated vermiculite. Multiple tests were conducted using the three vermiculite products
that had been found to contain measurable quantities of asbestos as determined by TEM analysis.
Each product was subjected to simulated use that was typical of how a consumer might handle the
product. Air monitoring samples were taken during the simulations.

       All analytical  data presented in the air monitoring section of this report was generated by
Lab/Cor, Inc., which is accredited through the National Voluntary Laboratory Accreditation
Program (NVLAP) administered by the Department of Commerce under the National Institute of
Standards and Technology (NIST).20  NVLAP accreditation certifies that the laboratory has met
an established level of competence. It does not guarantee the accuracy of the analytical results.

COLLECTION OF AIR MONITORING SAMPLES

       To determine what activities would be simulated, IEU investigators considered
information provided by citizens reporting how they used various products, the purpose for which
the product was intended, and a study conducted by the W.R. Grace and Company that was
provided to the Consumer Product Safety Commission on April 1,  1980.21 A copy of the letter
from E. S. Wood, Executive Vice President  of W. R. Grace & Co. Industrial Chemicals Group to
the United States Consumer Product Safety  Commission with attached report entitled User
Exposure to Fibrous Tremolite in Vermiculite Consumer Products dated April 1, 1980 is included
in Attachment 3.

       There are several protocols that can be used for analyzing air samples to determine the
number of asbestos fibers present in a volume of air. IEU investigators conducted a literature
search to become familiar with various analytical methods.  The final decision on what
methodologies to use for analysis of air samples taken during Phase III was based on consultation
with an industrial hygienist from the Washington State Department of Labor and Industries,
Region 10 quality assurance staff, and the analysts at Lab/Cor, Inc.
       20 NVLAP criteria are published in the Code of Federal Regulations (CFR, Title 15. Part 285)

       21 Letter from E. S. Wood, Executive Vice President of W. R. Grace & Co. Industrial Chemicals Group to
       the United States Consumer Product Safety Commission with attached report entitled User Exposure to
       Fibrous Tremolite in Vermiculite Consumer Products dated April 1, 1980

                                           13

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

       The primary method selected for analyzing air monitoring samples taken during Phase III
is the National Institute of Occupational Safety and Health (NIOSH) method 740222 which is used
to determine levels of asbestos in ambient air in the workplace. For comparison, a second method
was selected which is used to monitor levels of asbestos in schools under the Asbestos Hazards
Emergency Response Act (AHERA). The AHERA method23 is described in the Code of Federal
Regulations (CFR).  Both methods are used to analyze for asbestos fibers or structures that
become captured in air filters that are connected to air monitoring pumps. The air monitoring is
conducted for a set period of time while pumps draw a predetermined volume of air through the
filters.  After successful sampling and analysis, the number of fibers per cubic centimeter of air can
be determined.  A comparison of the two methods is shown in Table 2.
                                     TABLE 2
               Comparison of NIOSH method 7402 and AHERA method
Method
NIOSH 7402
AHERA
Filter Size
0.45 to 1.2 urn
< 0.45 urn
Volume of Air
0.5 to 16 liters per
minute
> 1 liter per minute
Counting Rules
> 5.0 um in length
> 3 : 1 aspect ratio
> 0.5 um in length
> 5:1 aspect ratio
       In Phase III IEU investigators simulated the use of Coles Cactus Mix as a potting soil, the
use of Zonolite Chemical Packaging Vermiculite and Therm-O-Rock Vermiculite in preparation
of a potting soil, and the use of Zonolite Chemical Packaging Vermiculite in packing laboratory
samples.  The Zonolite Chemical Packaging Vermiculite was tested as a component of potting soil
because EPA observed this product being sold at two Seattle area stores that sell retail garden
supplies.

       The simulated use of vermiculite products was conducted in a work space inside a
stainless steel Kewaunee Scientific Equipment (KSE) glove box. The workplace dimensions were
approximately 4 feet long by 3 feet high with a depth of 21 inches at the top and 27 inches at the
bottom. The glove box is equipped with a front glass viewing panel and fluorescent lighting
allowing observation of the work area.
       22 Asbestos by TEM, NIOSH Manual of Analytical Methods, Fourth Edition, 8/15/94

       23 Asbestos-Containing Materials in Schools, 40 CFR Part 763, sub-part E

                                          14

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
     Kewaunee Scientific Equipment glove box equipped with air-monitoring cassettes

       The product use simulations and air sampling took place between February 15, 2000, and
April 14, 2000. In some of the product use simulations the air filters became overloaded with
dust and particulate matter during air monitoring. Because of this overloading, the analytical
methods used for samples collected under the NIOSH 7402 and AHERA protocols had to be
modified to include indirect sample preparation as outlined in the "Methodology of the
Measurement of Airborne Asbestos by Electron Microscopy."24

       This modification has the potential to disrupt and fragment fibers, possibly resulting in a
higher number of structures or fibers per cubic centimeter than were originally present.  It was
understood that the indirect sample preparation could affect the fiber count. However, during the
initial stages of the investigation, it was essential to determine whether asbestos had been released
into the air. Precise quantification would be determined later through adjustment of the duration
of sampling and the flow rate of the air monitoring equipment.

       During project simulations based on the NIOSH method 7402 protocol, the ambient air
over the work space was monitored with two calibrated Gilian Hi Flow pumps attached with
Tygon tubing to 25 mm Zefon air monitoring cassettes with 0.8 pm mixed cellulose ester (MCE)
filters.  The air monitoring cassettes were suspended inside the glove box approximately 18 inches
above the surface of the work area to simulate the breathing zone of an average person. Air
samples were collected during simulations at durations between 15 and 30 minutes, with the
pumps  set to draw approximately 1 to 3 liters of air per minute. The different durations and flow
       24
         See footnote 16
                                          15

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

rates are allowed by the NIOSH method 7402 to provide optimum loading of the filter cassettes.
To adjust the sampling duration, some of the air filters used during monitoring at the different
durations and flow rates were viewed under PLM to determine if the filters were overloaded.

       For tests using the AHERA protocol, the ambient air inside the glove box was monitored
using two calibrated Allegro Industries High Volume Sampling Pumps attached with Tygon
tubing to 25 mm Zefon air monitoring cassettes with 0.45 jam MCE filters. Air samples were
collected during simulations for 100-minute durations with the pumps set to draw approximately
11 liters of air per minute.

       Pumps were calibrated with either a Gilian "Buck" Calibrator or a Gilian  "Gilibrator"
calibration device.  The flow rate for each pump  was recorded before and after each sample was
collected.  The average of before and after values reported to the laboratory was written on the
labels placed on the air monitoring cassettes and  documented on the chain of custody forms.

       Prior to conducting project simulations, a work space background sample was collected
between testing of each different product to determine if the work area was contaminated with
particulate or asbestos fibers from the previous test. Also, quality control samples of the air
monitoring cassettes and field blanks taken outside the glove box were obtained  for quality
assurance. A high efficiency particulate arrestance (HEPA) vacuum and damp cloth was used to
clean the work space in the glove box between tests to remove any possible asbestos fibers
between tests involving different products.

       The activity that simulated potting plants  involved emptying a container of soil into a
plastic tub and manipulating the soil to break up clods. The soil was placed in 10 plastic 4- inch
pots at several intervals.  Next the pots were emptied back into the plastic tub and the work space
was cleaned by sweeping loose spilled soil into a pre-cleaned dust pan and placing it back into the
plastic tub.  This simulation was run three times for 30 minutes and once for 100 minutes.

       To simulate the preparation of potting soil, LEU investigators mixed 50% vermiculite and
50% peat moss. Bulk samples of the peat moss were analyzed and determined not to contain
detectable asbestos fibers. The remainder of this simulation was  similar to the previous simulation
of potting plants.  This simulation was run two times for 30 minutes and once for 100 minutes
using the Zonolite Chemical Packaging Vermiculite, and three times for 15 minutes using Therm-
O-Rock Vermiculite.

       Vermiculite is used by laboratories around the country to pack chemicals and hazardous
material samples for shipping.  The vermiculite cushions jars to keep them from breaking and
absorbs spillage if the containers leak during shipping. To simulate packing laboratory samples,
four 8-ounce glass jars were placed into a stainless  steel pan and  covered with vermiculite. This
simulation was repeated for durations of 30, 20, and 15 minutes.

                                          16

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
Sample preparation and Analysis performed by Lab/Cor, Inc.2'

       For the NIOSH method 7402 using TEM, samples were collapsed with acetone, and
etched in a low temperature plasma etcher to remove the top surface of the filter and other
organics. The samples were coated at high vacuum with a thin layer of carbon, placed on 200
mesh copper grids and allowed to dissolve in acetone until cleared of filter debris.  The 200 mesh
copper TEM grids were examined under a Philips 410 transmission electron microscope equipped
with EDS. Air samples were scanned at magnification of approximately 990X using an
accelerating voltage of 100KV. The magnification was increased to 10,OOOX for structure sizing.
The NIOSH method 7402 counts  structures or fibers if they are greater than 0.25 |om in diameter
with a minimum aspect (length to width) ratio of 3:1 and a length greater than 5.0 jam.
                         |S1K«
                         i

                         i
                         •

                         1
                                                          s
                                                          5
                                                         8.C
                                                    10eV/ch  R  EDRX

              EDS Spectra used to verify the elemental composition of an actinolite fiber
             collected during simulated use of Zonolite Chemical Packaging Vermiculite

       An indirect analytical technique was applied to overloaded samples collected using
NIOSH and AHERA protocols.  The analysis was conducted in accordance with the draft method
done under contract 68-02-3266 for EPA, July 1984 entitled "Methodology of the Measurement
of Airborne Asbestos by Electron Microscopy."26
       25 John Harris, LAB/COR, Inc., Seattle, Washington
       26 See footnote 16
                                          17

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

       The sample filters were removed from sampling cassettes and placed into clean sonication
dishes. After washing out each cassette cowl with particle-free, deionized water, the supernatant
fluid was combined with each filter, placed in a sonication dish, and gently sonicated to release the
particulate from the filter.  After brief sonication, aliquots were drawn from the supernate and
filtered onto 0.22 (im MCE filters. Samples were coated at high vacuum with a thin layer of
carbon, placed on 200 mesh copper grids, and allowed to dissolve in acetone until cleared of filter
debris. The 200 mesh copper TEM grids were examined under a Philips 410 transmission
electron microscope equipped with EDS. Air samples were analyzed at a screen magnification of
approximately 17,62 IX using an accelerating voltage of 100KV.  The sizing of grid openings was
performed on the microscope at a magnification of approximately 550X. Counting rules for the
draft method were modified to match the AHERA counting rules more closely.  This method
allows structures greater than 0.5 jam in length with substantial parallel sides and an aspect ratio
of 5:1 to be counted.

       Before any air monitoring samples were taken using vermiculite products, quality
assurance, quality control and work area background samples were collected and analyzed. None
of these samples showed the presence of asbestos. This was an important part of the air
monitoring procedure because it showed the work area and the filters used were free of asbestos
to begin with, and there no cross contamination of the work area occurred when switching from
one product to another.

       No asbestos fibers were detected when air samples collected during the simulated use of
Coles Cactus Mix and Therm-O-Rock Vermiculite were analyzed. Using the indirect method of
analysis, asbestos was detected in air samples collected when Zonolite Chemical Packaging
Vermiculite was used to simulate the preparation and use of potting soil and for sample packing.

       Subsequent air monitoring samples were taken when Zonolite Chemical Packaging
Vermiculite was used to simulate packing samples.  The flow rates and sample times were
reduced to avoid overloading the filters and allow for direct analysis under the NIOSH 7402
protocol.  These air samples were run for 15 to 20 minutes at flow rates of 1 to 2 liters per minute
and were repeated four times. The results of analysis ranged from 0.16 to 0.95 asbestos fibers  per
cubic centimeter of air.  Complete results and supporting data for the air monitoring portion of
this project are included in Attachment 4.
                                          18

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

SUMMARY OF ANALYSIS OF AIR MONITORING SAMPLES

       Three products were subjected to air monitoring during simulated use in a confined area.
Two of the products, Cole's Cactus Mix and Therm-O-Rock Vermiculite, did not release
airborne asbestos fibers during simulated use. The third product, Zonolite Chemical Packaging
Vermiculite, did release airborne asbestos fibers during simulated use and therefore presents a
potential for exposure to asbestos.  Tables 3 and 4 summarize the results of analyses of air
monitoring samples taken while simulating use of Zonolite Chemical Packaging Vermiculite in
preparing and using potting soil and for packing samples.

       Because of this potential for exposure to asbestos, EPA Region 10 advised consumers not
to use Zonolite Chemical Packaging Vermiculite until further statistically based testing could be
performed. EPA Region 10 also advised consumers to follow  three basic precautions when
working with products that contain vermiculite in order to reduce potential exposure to asbestos:
1) use vermiculite outdoors; 2) keep vermiculite damp to avoid generating dust; 3) avoid bringing
dust from clothing into the home.
                                CONCLUSIONS

       Five vermiculite products tested during the Region 10 investigation contained asbestos.

       One asbestos-contaminated vermiculite product tested by Region 10 released airborne
       asbestos fibers when subjected to simulated use.

       Consumers have no way of knowing which vermiculite products are contaminated with
       asbestos and which are not.

       Analysis of asbestos-contaminated vermiculite products revealed a wide degree of
       variability in the amount and types of asbestos present in the samples.

       The variability of analytical results demonstrates a need for additional statistically based
       studies using more sensitive sampling and analytical methods.
                                          19

-------
REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE
   Actinolite fibers in Zonolite Chemical Packaging Vermiculite viewed by SEM27
    Tremolite fiber in Zonolite Chemical Packaging Vermiculite viewed by SEM
    27
      Scanning electron microscope
                                 20

-------
 REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

                              TABLE 3
ANALYTICAL METHOD:
PRODUCT:
Methodology of the Measurement of Airborne Asbestos
by Electron Microscopy, (draft method)

Zonolite Chemical Packaging Vermiculite
Sample #
74216
74217
104201
104202
104205
104206
104209
104210
Date
2/16/2000
2/16/2000
3/7/2000
3/7/2000
3/7/2000
3/7/2000
3/8/2000
3/8/2000
Description
Potting Soil Preparation - AHERA Protocol
Pump #3, 1 1.0 liters/minute for 100 minutes, Indirect analysis.
Pump #4, 1 1 .0 liters/minute for 100 minutes, Indirect analysis.
Potting Soil Prep - NIOSH 7402 Protocol
Pump #1,2.8 liters/minute for 30 minutes, Indirect analysis
Pump #5, 2.8 liters/minute for 30 minutes. Indirect analysis
Pump #1,2.8 liters/minute for 30 minutes, Indirect analysis
Pump #5, 2.8 liters/minute for 30 minutes. Indirect analysis
Sample Packaging Simulation - NIOSH 7402 Protocol
Pump #1, 2.9 liters/minute for 30 minutes. Indirect analysis
Pump #5, 2.9 liters/minute for 30 minutes, Indirect analysis
Results of Analysis
0.847 structures per cc
0.564 structures per cc
0.202 structures per cc
0.373 structures per cc
0.380 structures per cc
0.080 structures per cc
6.960 structures per cc
8. 170 structures per cc
cc = cubic centimeter
                                 21

-------
 REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE



                           TABLE 4
ANALYTICAL METHOD:
NIOSH 7402
PRODUCT:
Zonolite Chemical Packaging Vermiculite
Sample #
154000
154001
154002
154003
154008
154009
154010
154011
Date
4/1 1/2000
4/1 1/2000
4/1 1/2000
4/1 1/2000
4/13/2000
4/13/2000
4/13/2000
4/13/2000
Description
Sample Packing Simulation
Pump #5, 2.0 liters/minute for 20 minutes, direct analysis.
Pump #1, 1.5 liters/minute for 20 minutes, direct analysis
Pump #1, 1.5 liters/minute for 15 minutes, direct analysis
Pump #5, 2.0 liters/minute for 15 minutes, direct analysis
Pump #1, 1.0 liters/minute for 15 minutes, direct analysis
Pump #5, 1.0 liters/minute for 15 minutes, direct analysis
Pump #1, 1.0 liters/minute for 15 minutes, direct analysis
Pump #5, 1.0 liters/minute for 15 minutes, direct analysis
Results of Analysis
0.344 fibers per cc
0.352 fibers per cc
0.342 fibers per cc
0.160 fibers per cc
0.702 fibers per cc
0.477 fibers per cc
0.249 fibers per cc
0.948 fibers per cc
cc = cubic centimeter
                              22

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

                                REFERENCES

1) Bank (1980) Asbestiform and/or Fibrous Minerals in Mines. Mills and Quarries.  Prepared for
U.S. Department of Labor, Mine Safety and Health Administration.  MSHA/IR-1 111.

2) Boltin, (1989) "Analysis for Asbestiform Amphiboles in Vermiculite Ore", Microscope.
Carshalton Beeches, England.

3) Hunter, Charles E. Vermiculite of the Southeastern States. Symposium on Mineral Resources
of the Southeastern United States. University of Tennessee Press.  (1950). Pages 120-127.

4) Moatamed, Lockey, and Parry, (1985) "Fiber Contamination of Vermiculites: A  Potential
Occupational and Environmental Health Hazard", Academic Press. Inc.

5) Midwest Research Institute, Kansas City, MO. (1982) Collection. Analysis and
Characterization of Vermiculite Samples for Fiber Content and Asbestos Contamination.
Prepared for U.S. Environmental Protection Agency, EPA Report Number EPA 0717.

6) North and Chandler, (1953) Vermiculite.  Prepared for U.S. Department of the Interior,
Bureau of Mines. Information circular 7668.

7) U.S. Department of Health and Human Services, (2000) Toxicological Profile for Asbestos.
Public Health Service, Agency for Toxic Substances and Disease Registry, Atlanta,  GA.

8) U.S. Environmental Protection Agency, (1980) Priority Review Level 1 - Asbestos-
Contaminated Vermiculite. Assessment Division, Office of Testing and Evaluation, Office of
Pesticides and Toxic Substances, Washington, D.C.

9) U.S. Environmental Protection Agency. (1991) Health Assessment Document for Vermiculite.
Office of Research and Development, Washington, D.C. EPA Report Number EPA/600/8-91/037

10) U.S. Environmental Protection Agency.  (1985) Exposure Assessment for Asbestos-
Contaminated Vermiculite. Prepared for U.S. Environmental Protection Agency by Versar, Inc.,
Springfield, VA. EPA Report Number EPA/560/5-85-013

11) U.S. Geological Survey, (1990), Vermiculite Minerals Yearbook. Potter. Michael J.

12) W.R. Grace and Company, Cambridge, MA. (1980), Memorandum to Consumer Product
Safety Commission dated  April 1, 1980.
                                         23

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  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

                                    Appendix 1


                               Summary of Interviews

       A registered nurse from Tennessee said vermiculite is used routinely in southern states as
an underlayment for swimming pools.  She recently watched a crew install a pool in her backyard,
and noticed they were coated with vermiculite dust. None of the workers wore respiratory
protection.  The dust drifted into her home and got onto her furniture.  She said she intended to
take samples of the dust, and had already purchased a HEPA filtered vacuum cleaner to eliminate
dust that might be contaminated with asbestos.

       A technician from a local children's hospital was has used vermiculite for years to make
orthotics and prosthetic devices.  She was concerned because the material safety data sheet from
the manufacturer clearly stated the vermiculite came from the W.R. Grace and Company mine in
Libby, Montana. The technician surmised that asbestos from the Libby vermiculite could have
contaminated the work area where children are fitted for prosthetics and where employees spend
much of their time working.

       A laboratory assistant from a local community college said she routinely unpacks
chemicals that arrive packed in vermiculite. This vermiculite is then saved in large bins for use in
the school's greenhouses.  She was concerned that young college-age students could be exposed
to asbestos from vermiculite both  in the laboratory  and in greenhouses.

       The owner of a preschool in Michigan called to ask for guidance in sampling vermiculite
attic insulation.  The caller said he and his wife had operated a preschool out of the building for
twenty years, and he was upset to  learn that young children attending his school might have been
exposed to asbestos in the vermiculite. He subsequently took samples of the insulation and
reported asbestos ranging from non-detect to 4% by weight using TEM analysis.

       An employee from the EPA Region 10 laboratory reported that samples of hazardous
materials and new chemicals arrive at the lab packed in vermiculite.  He was worried that
employees at the lab could be exposed to asbestos while unpacking samples and chemicals.  The
Region 10 lab subsequently decided to use alternative packaging materials when shipping, and to
specify that incoming shipments not be packed in vermiculite.

       An industrial hygienist with a city park district said the district uses large quantities of
vermiculite in greenhouses. He said he intended to take air monitoring samples while greenhouse
workers were using vermiculite to see  if there was any measurable exposure to asbestos.
                                          24

-------
  REGION 10 INVESTIGATION OF ASBESTOS IN VERMICULITE

       Two men who formerly worked in vermiculite exfoliation plants in the northwest called to
provide details about the manufacturing process. One said he suffers significant impaired lung
function and has been diagnosed with asbestosis.  The other provided a report of a recent chest
x-ray showing early signs of asbestos related disease.

       An employee of a large manufacturing facility in the Seattle area reported the company
made a decision around 1980 to stop accepting supplies or equipment shipped in vermiculite
because of the likelihood that the vermiculite was contaminated with asbestos.  The company
decided vermiculite presented a health hazard to employees and was a "right to know" issue.

       The EPA National Enforcement Investigations Center laboratory stopped using
vermiculite to ship hazardous materials nearly twenty years ago in part because of the potential
for asbestos contamination in vermiculite. Lab personnel were also concerned about the potential
for vermiculite to aerosolize and  spread contaminants into the air.

       A large military facility in the Seattle area reported using vermiculite for many years to
pack hazardous materials for shipment.  Because of concern the employees may have been
exposed to asbestos when handling vermiculite, the employees of the shipping department were
enrolled in the medical monitoring program.

       Two different contractors at a nuclear facility in the northwest reported using large
quantities of vermiculite in handling and shipping hazardous materials.  Industrial hygienists from
both companies are conducting their own inquiries to determine if employees who work with
vermiculite have been or are being  exposed to asbestos.

       A resident of Libby, Montana, learned that Region 10 was investigating asbestos
contamination in vermiculite. On a trip to Seattle he brought samples of rocks from the mine to
for Region  10 scientists to analyze. His father and two brothers had worked at the mine, he had
not.  His father died of asbestosis.  His two brothers have both been diagnosed with asbestosis.
Analysis of the rock sample by the  Manchester Environmental Laboratory using PLM showed the
sample was 80% tremolite asbestos by weight.28 A copy of the results of analysis follow this
appendix.
         MEL sample analysis report for sample identified as Libby #1 collected 5/17/00

                                           25

-------
• ,•: ii"
   : • .-
  .Manchester Environmental Laboratory
           by Parameter for Project ATD-276A
     t Code:
Projwt N a mo;
Project Officer: .
Acrouiit Code:
      Description:
ATO-276A
VERMlCULITf MINKS
KATHV JOHNSON
(JOOIBIOP90I02E
1-1BBYS1
Collected;       5/17/00
Matrix:         Solid
Sample Number; 00210760
Type:           Reg sample
Parameter
Mctlrnl
Prep Method
Anslytes







*
Bulk Asbestos Analysis

* 200003
•200006
•200007
'200013
*200CK>5
•'200010
•20*011
'2000 1 2
•100003

Actinolite
Amosite
Anthophytiite
Ceilutosc
ChryscHile
Crocsdcluc
Glass Fiber
Mineral Wool
Tremolite
                                                          Result
                                                                                _0jfr
                                                          so
                                                                                 UND
                                                                                 UND
                                                                                 UND
                                                                                 UND
                                                                                 UND
                                                                                 uxn
                                                                                 UNO
                                                                                 L'N'D
                                                                 UC210760
                                           26

-------
Attachment 1

-------
 Remark
 Codes

 PNQ
UND

TRACE

NAF
                                     Remark Codes
                                          for
                   Manchester Environmental Laboratory- Generated Data

                                ASBESTO^ANALYSIS
             Definition
                                                  " **
                                                                              result
The subject parameter was analyzed for but was undetected.

A trace of the subject parameter was present.

The subject parameter was not analyzed for.

-------
                    .Manchester Environmental Laboratory
                    Combined I-'inal Report for Project FSD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
1-SD-045A
RLTAIL HOVIP. & GAR1JHN Cl-.NTrKs
JLD JANUCH
0001B10P40101C
BLACK GOLD VERMICULITL    1 2OT
Collected:       1/31/00
Matrix:         Solid
Sample Number:  00054200
T.vpe:           Reg sample
GEN
Parameter
Method :
Prep Method:
Analytes :









Bulk Asbestos


* 200009
*200006
'200007
* 2 000 13
'200005
'200010
•20001 1
"200012
'200008
	 t
Analysis


Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotilc
C'rocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                          Result
                                                   Units
                                                                                 UNO
                                                                                 UNO
                                                                                 PNQ
                                                                                 UNO
                                                                                 UNO
                                                                                 PNQ
                                                                                 L'ND
                                                                                 UND

-------
                     Manchester  Environmental Laboratory
                     Combined  Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-CU5A
     RHTAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     COLES VERMICUL1TE      12QT
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054201
                                              Reg sample
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analytes    :
                                                             Result
                                                           Units
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
* 200010
*200011
*200012
*20000S
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                                                     UNO
                                                                                     UND
                                                                                     UND
                                                                                     PNQ
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                     00054201

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     SCHULTZ VERMICUUTE   8QT
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054202
                              Type:           Reg sample
                                                              Result
                                                            Units
                                                           Qlfr
GEN
  Parameter  :
  Method     :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
"200010
'200011
* 200012
*20000S
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Woo!
Tremolite
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       PNQ
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                       01)054:02 Ki-» sample

-------
                    Manchester Environmental Laboratory
                   Combined Final Report for Project ESD-045A
1'rojcct Code:
Project Name:
Project Officer:
Account Code:
Station Description:
ESD-045A
RETAIL HOME & GARDEN CENTERS
JED JANUCH
0001B10P40101C
WHITNEY FARMS VERMICULITE    4QT
Collected:       1/31/00
Matrix-:         Solid
Sample Number:  00054203
Type:           Reg sample
GEN
Parameter :
Method :
Prep Method:
Analytes









Bulk Asbestos


*200009
* 200006
"200007
*200013
'200005
*200010
"20001 1
* 2000 12
-20000S

Analysis


Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wo-'
Tremolite
                                                         Result
                                                   Units
                                                                                UNO
                                                                                UNO
                                                                                UNO
                                                                                UND
                                                                                UNO
                                                                                UND
                                                                                UND
                                                                                UND
                                                                                TRACE
                                                                OOOS.i:o3 k,.u sample

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-0-45A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     SCOTTS VERMICULITE    QT
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054204
                              Type:            Reg sample
                                                              Result
                                                           Units
                                                                                      Qlfr
GEN
  Parameter  :
  Method     :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
"200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremoliie
UNO
UNO
UNO
UNO
UNO
UNO
UNO
UNO
TRACE
                                                                      0005420.4 Re- sample

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOiME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     ZONOL1TE VERMICULITE   19LB
Collected:        1/31/00
Matrix:          Solid
Sample Number:  00054205
Type:           Reg sample
                                                              Result
                                                           Ur
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analvtes    :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*2000I1
*200012
*200008
                           Actinolite
                           Amosite
                           Anthophyllite
                           Cellulose
                           Chrysotile
                           Crocidolite
                           Glass Fiber
                           Mineral Wool
                           Tremolite
                            UNO
                            UNO
                            UNO
                            UND
                            UNO
                            UND
                            UND
                            UND
                            TRACE
                                                                     0005-4205 Re<

-------
5/ 5/00
       Manchester Environmental Laboratory
                                                       \j
       Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     ZONOLITE VERiMICULITE    19LB
                              Collected:       1/31/00
                              Matrix:         Solid
                              Sample Number:  00054206
                              Type:           Reg sample
                                                              Result
                                                            Units
                                                                                       Mfr
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*20000S
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotiie
Crocidolite
Glass Fiber
Mineral Wool
Trernolite
                                                                                      UNO
                                                                                      UNO
                                                                                      UNO
                                                                                      UNO
                                                                                      UNO
                                                                                      LTND
                                                                                      UNO
                                                                                      UNO
                                                                                      TRACE
                                                                      00054206 Reg sample

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     THERMO ROCK  4 CUBIC FT
Collected:        1/31/00
Matrix:          Solid
Sample Number:  00054207
Type:           Reg sample
                                                              Result
                                                           Units
                                                                                      Olfr
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analvtes    :
Bulk Asbestos Analysis
"200009
*200006
"200007
*200013
"200005
"200010
*200011
*200012
*200008
                           Actinolite
                           Amosite
                           Anthophyllite
                           Cellulose
                           Chrysotile
                           Crocidolite
                           Glass Fiber
                           Mineral Wool
                           Tremolite
                             UND
                             UNO
                             UND
                             UND
                             UND
                             UND
                             UND
                             UND
                             TRACE
                                                                     00054207 Reg sample

-------
                   Manchester Environmental Laboratory
                   Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
F.SD-045A
RETAIL HOME & GARDEN CENTERS
JED JANUCH
0001B10P40101C
PROF. JIFFY MIX    8QT
Collected:        1/31/00
Matrix:         Solid
Sample Number:  0005420S
Type:           Reg sample
                                                         Result
GEN
Parameter :
Method :
Prep Method:
Analytes :









Bulk Asbestos


*200009
*200006
*200007
*200013
*200005
*200010
"200011
*200012
* 200008

Analysis


Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite




UNO
UND
UND
PNQ
UND
UND
UND
UND
UND
                                                                (K105420S

-------
                     Manchester Environmental Laboratory
                     (  ombined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     SAMS COICE POTTING SOIL    10LB
Collected:        1/31 00
Matrix:          Solid
Sample Number:  00054209
Type:           Reg sample
                                                              Result
                                                            Units
                                                                                      01 fr
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analvtes    :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*20000S
                            Actinolite
                            Amosite
                            Anthophyllite
                            Cellulose
                            Chrysotile
                            Crocidolite
                            Glass Fiber
                            Mineral Woo!
                            Tremolite
                             UNO
                             LTND
                             LTND
                             UND
                             UNO
                             UND
                             UND
                             UND
                             UND

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JEDJANUCH
     0001B10P40101C
     COLES HOUSE PLANT MIX   8QT
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054210
                              Type:            Reg sample
                                                              Result
                                                           Units
                                                                                      Olfr
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                                                      UNO
                                                                                      UNO
                                                                                      UNO
                                                                                      PNQ
                                                                                      UNO
                                                                                      UNO
                                                                                      UNO
                                                                                      UTs'D
                                                                                      UNO
                                                                     0005-1210 K

-------
                     Manchester Environmental Laboratory
                    Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     SCHULTZ SEED STARTER  5.4 LB
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054211
                              Type:            Reg sample
                                                             Result
                                                           Units
                                                                                     Qlfr
GEN
  Parameter  :
  Method    :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                                                     PNQ
                                                                                     UNO
                                                                                     UNO
                                                                                     UNO
                                                                                     UNO
                                                                                     UND
                                                                                     UNO
                                                                                     UNO
                                                                                     UNO
                                                                     0005421 I  Re
                                                                             \c
-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JEDJANUCH
     0001 B10P40I CMC
     SCHULTZ SEED STARTER 5.4 LB
                              Collected:       1/31/00
                              Matrix:         Solid
                              Sample Number: 00054212
                              Type:           Reg sample
                                                              Result
                                                            Units
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analytes    :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
'200012
*20000S
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                                                      UNO
                                                                                      UNO
                                                                                      UNO
                                                                                      PNQ
                                                                                      UNO
                                                                                      LTND
                                                                                      LTND
                                                                                      UNO
                                                                                      UNO
                                                                      0005-4212 Re» snmpli-

-------
                    Manchester Environmental Laboratory
                   Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:.
Account Code:
Station Description:
ESD-045A
RETAIL HOME & GARDEN CENTERS
JED JANUCH  .
0001B10P40101C
COLES AFRJCAN VIOLOET MIX 4 QT
Collected:       1/31/00
Matrix:         Solid
Sample Number:  00054213
Type:           Reg sample
GEN
Parameter :
Method :
Prep Method:
Analytes :









Bulk Asbestos

*200009
*200006
*200007
*200013
*200005
*200010
*200011
* 2000 12
"200008

Analysis

Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                         Result
                                                  Units
                                                                               UND
                                                                               UNO
                                                                               UND
                                                                               PNQ
                                                                               UND
                                                                               UND
                                                                               UND
                                                                               UND
                                                                               UND
                                                               00054213 ReU sample

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JEDJANUCH
     0001B10P40101C
     COLES CACTUS MIX  4QT
Collected:        1/31/00
Matrix:          Solid
Sample Number:  0005-1214
Type:           Reg sample
                                                              Result
                                                           Units
                                                                                      Olfr
GEN
  Parameter
  Method     :
  Prep Method:
  Analvtes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*2000ll
*200012
*20000S
                            Actinolite
                            Amosite
                            Anthophyllite
                            Cellulose
                            Chrysotile
                            Crocidolite
                            Glass Fiber
                            Mineral Wool
                            Tremolite
                            UNO
                            UNO
                            UNO
                            PNQ
                            UNO
                            I'ND
                            I'ND
                            LND
                            L'ND

-------
                   Manchester Environmental Laboratory
                   Combined Final Report for Project KSD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
ESD-045A
RETAIL HOME & GARDEN CENTERS
JED JANUCH
0001B10P40101C
Collected:
Matrix:
Solid
Sample Number: 000542
Station Description:  COUNTRY COTTAGE SEED STARTER  8QT
                                                    Type:
GEN
Parameter :
Method :
Prep Method:
Analytes :









Bulk Asbestos


*200Q09
*20QOQ6
*200007
*200013
*200005
*200010
*200011
*200012
*200008

Analysis


Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite




UND
UND
UND
PNQ
UNO
UND
UND
UND
I "vn

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     BLANK GOLD SEEDLING MIX   16QT
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054216
                              T ype:            Reg sample
                                                              Result
                                                           Units
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analytes    :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                                                     LTND
                                                                                     UNO
                                                                                     UND
                                                                                     PNQ
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                     0(1054: K, Ku- snmplc

-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001B10P40101C
     SCOTTS PROGRO  25QT
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054217
                              Type:           Reg sample
                                                             Result
                                                            Units
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analytes    :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral Wool
Tremolite
                                                                                     UND
                                                                                     UNO
                                                                                     UND
                                                                                     PNQ
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                     00054

-------
5/ VOO
9:59:37
       Manchester Environmental  Laboratory
       Combined Final Report  for  Project KSD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JANUCH
     0001BIOP40101C
     WHITNEY FARMS VERMICUL1TE - FRED MEYER
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054218
                              T>'pe:           Reg sample
GEiN
  Parameter  :
  Method     :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
                                                              Result
                                                            Units
*200009
*200006
*200007
*200013
*'200005
*200010
*200011
*200012
*200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolite
Glass Fiber
Mineral \Vool
Trernolite
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       UNO
                                                                                       LiN'D
                                                                                       UNO
                                                                      00054218 Re

-------
                     .Manchester Environmental Laboratory
                    Combined Final Report for Project  ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-0-5A
     RETAIL IIOMF. A: GARDEN CENTERS
     JED JANL'CH
     0001B10P40101C
     ZONOLITE - BL'RDIC
                              Collected:        1/31/00
                              Matrix:          Solid
                              Sample Number:  00054219
                              Type:            Reg sample
                                                              Result
                                                            Units
                                                          Olfr
GEN
  Parameter   :
  Method     :
  Prep Method:
  Analvtes   :
Bulk Asbestos Analvsis
*200009
*200006
'200007
* 200013
* 200005
*200010
"20001 1
* 200012
-20000S
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotiie
Crocido'i'e
Glass Fiber
Mineral Vv'ool
Tremohle
                                                                                      UND
                                                                                      UND
                                                                                      UND
                                                                                      UND
                                                                                      UND
                                                                                      UND
                                                                                      UND
                                                                                      UND
                                                                                      PNQ
                                                                      (111054: 1') Ri'^ s:iniplo

-------
                   Manchester Environmental Laboratory
                   Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
ESD-U45A
RETAIL HOME 
-------
                     Manchester Environmental Laboratory
                     Combined Final Report for Project ESD-045A
Project Code:
Project Name:
Project Officer:
Account Code:
Station Description:
     ESD-045A
     RETAIL HOME & GARDEN CENTERS
     JED JAN'UCH
     0001B10P40101C
     ZONOLITE - CHUBBY & TUBBY
                              Collected:        3/ 7/00
                              Matrix:          Solid
                              Sample Number:  00104200
                              Type:           Reg sample
GEN
  Parameter  :
  Method    :
  Prep Method:
  Analytes   :
Bulk Asbestos Analysis
*200009
*200006
*200007
*200013
*200005
*200010
*200011
*200012
*200008
Actinolite
Amosite
Anthophyllite
Cellulose
Chrysotile
Crocidolile
Gl-ass Fiber
Mineral Woo;
Tremolite
                                                                                     UND
                                                                                     UNO
                                                                                     UND
                                                                                     PNQ
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND
                                                                                     UND

-------
Attachment 2

-------
                                                                      Lab/Cor, Inc.
                                                        A Professional Service Corporation in the Northwest
              Report Number: 000 109
                                                                                                                       Report Date: May 25, 2000
                        Client Information
              Project Name:  Retail Home and Garden
                            Centers
              Project No.:    HSD-045 A
              P.O. No.:      OYOI07NASX-
                                                                    Tracking Information
    Login:       Feb 3, 2000    By: DJ
    Reviewed:    Feb 11, 2000   By:)\\
    Final Review: May 25, 2000  Bv: TMM
                                                           Analysis Information
Sample Type:   Bulk
Analysis Type:  Semi-Quantitative
Reference No.:  EPA/600/R-93/1 1 6
              68-02-3266
                                          Transmission
                 FINAL TABLE
Electron Microscopy - Semi-Quantitative - Bulk Sample Analysis
Sample No.
000 10')- 01
000109-02
000109-03
000109-04
000 IQy -05
000109-06
000109-07
000109-08
000109-09
Client
Sample No.
54200
54201
54202
54203
54204
54205
54206
54207
54208
Description
Black Gold Vermiculite / 12 Ol /
Carpinito Bros.
Cole's Vermiculite / 12 Qt./ Eagles
(Lowes)
Scholtz Vermiculite / 8 Qt./ Wallmart
Whitney Farms / 14 Qt./ Fred Meyers
Scotts Vermiculite / 8 Qt./ Wallmart
Zonolite Vermiculite / 19 Lb./ Burdie
Feeds Inc.
Zonolite Vermiculite / 19 Lb./ Burdie
•eeds Inc.
Therm-ORock Verm /4 Cu. Ft./
Carpinito Bros.
Prf. Jiffy Mix / 8 Qt./ Wallmart
Regulated
Asbestiform
Mineral Type
None Detected
None Detected
None Detected
None Detected
None Detected
Actinolite
Actinolite
None Detected
None Detected
Weight
Percent





0.56
0.47


Other Components
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Weight
Percent
25.00
40.58
34.42
1.32
47.53
51.15
0.00
46.84
53.16
0.68
45.27
54.05
0.19
84.45
15.36
1.46
42.98
55.00
2.05
51.17
46.31
5.49
60.14
34.37
51.40
27.54
21.06
Prepped
By
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
Prep
Date(s)
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
Analyst
GG
GG
GG
GG
GG
GG
GG
GG
GG
Analysis
Date
02/08/00
02/09/00
02/08/00
02/08/00
02/09/00
02/09/00
02/09/00
02/09/00
02/08/00
OOOI0902.bul

-------
                                                       Lab/Cor, Inc.
                                         A Professional Service Corporation in the Northwest
Report Niunher: 000109
Report Date: May 25, 2000
Client Information
Project Name: Retail Home and Garden
Centers
Project No.: i:SD-045 A
P.O. No.: OYOI07NASX


Tracking Information
Login: Feb 3, 2000 By: DJ
Reviewed: Feb 1 1 , 2000 By: JH
Final Review: May 25, 2000 By: TMM

Analysis Information
Sample Type: Bulk
Analysis Type: Semi-Quantitative
Reference No. : EPA/600/R-93/ 1 1 6
68-02-3266
                                                         FINAL TABLE
                            Transmission Electron Microscopy - Semi-Quantitative - Bulk Sample Analysis
Lab/Cor
Sample No.
000109-10
000109-1 1
000109-12
000109 13
ouuioy-14
000109-15
000109-16
000109-17
000109-18
Client
Sample No.
54209
54210
54211
54212
54213
54214
54215
54216
54217
Description
Sams Choice Prf Potting Mix / 1 0 Lb./
Wallmart
Coles light House Plant Mix / 8 Qt./
Eagle
Schultz Seed Starter / 5 4 Lb / Eagles
Schultz Seed Starter / 6 4 Lb./ Eagles
Coles African Violet Mix / 4 Qt./ Eagles
Coles Cactus Mix / 4 Qt./ Eagles
Country Cottage Prf. Seed Starter / 8
Qt./ Oriental Garden Center
3lack Gold seedling Mix / 16 Qt./ Fred
Meyers
Scotts Pro Grow Professional Potting
Mix / 25 Qt./ Home Depot
Regulated
Asbestiform
Mineral Type
None Detected
None Detected
None Delected
None Detected
None Detected
Actinolite
None Detected
None Detected
None Detected
Weight
Percent





0.45



Other Components
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Noncjsbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Weight
Percent
34.06
21.69
44.25
36.12
23.70
40.18
43.30
43.02
13.68
28.57
45.90
25.53
44.59
13.51
41.90
17.42
37.64
44.49
44.94
23.42
31.64
65.54
11.49
22 97
49.12
38.35
12 53
Prepped
By
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
DW
Prep
Date(s)
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
02/04/00
02/07/00
Analyst
GG
GG
GG
GG
GG
GG
GG
GG
GG
Analysis
Date
02/09/00
02/09/00
02/09/00
02/10/00
02/10/00
02/07/00
02/07/00
02/10/00
02/07/00

-------
                                                                       Lab/Cor, Inc.
                                                         A Professional Service Corporation in the Northwest
                                                                                                                         Report Dale: May JS, 2000
                        Client Information
               I'm/eel Ntiitic: Retail Home and Garden
                            Centers
               /'mji-ct Nn. •   HSD-045 A
               /'. O. No .     OYUI07NASX
                                                                     Tracking Information
LoKin:        Feb 3, 2000    By: DJ
Reviewed:    Feb 1 1, 2000   #v: JH
Final Review: May 25, 2000  liy: TMM
                                                        Analysis Information
Sample Type:    Bulk
Analysis Type:   Semi-Quantitative
Reference No.:   nPA/6()0/R-cJ3/l 1 0
               68-02-3266
                                                                         FINAL TABLE
                                           Transmission Electron Microscopy - Semi-Quantitative - Bulk Sample Analysis
Sample No.

0001 OP- 20
Client
Sample No

0005421 1A
Description
Zonohle Vermiculite / 19 Lb ./ Burdie
Feeds Inc (QC Replicate)
Schultz Seed Starter / 5 4 Lb / Eagles
(QC Replicate)
Regulated
Asbestiform
Mineral Type
None Detected
None Detecled
Weight
Percent


Other Components
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Weight
Percent
8.88
4379
47 33
53.77
17.92
28.31
Propped
By
DW
DW
DW
DW
Prep
Date(s)
02/04/00
02/09/00
02/04/00
02/09/00
Analyst
GG
GG
Analysis
Date
02/10/00
02/10/00
OOOI0902.bul

-------
    Lab/Cor
   Sample No.
    000224-01
    000224-02
   000224-03
   000224-04
                                                                      Lab/Cor, Inc.
                                                        A Professional Service Corporation in the Northwest
              Report Number: 000224
                                                                                                                        Report Date: May 25, 2000
                        Client Information
              Project Name:  Vermiculite -Commercial
                            Product
              Project No.:    ESD-045A
              P. O. No.:     0001B10P40101C
                                                                     Tracking Information
Login:        Mar 10, 2000   By:  DJ
Reviewed:    Mar 23, 2000   By:  JH
Final Review: May 25, 2000   By:  TMM
                                                       Analysis Information
Sample Type:   Bulk
Analysis Type:   Semi-Quantitative
Reference No.:   EPA/600/R-93/116
               68-02-3266
                                                                        FINAL TABLE
                                          Transmission Electron Microscopy - Semi-Quantitative - Bulk Sample Analysis
Client
Sample No.
54203
54205
54207
— 	
104200
Description
Whitney Farms Vermiculite - Fred Meyer
Zonolite - Burdic Feed
Thermo Rock - Carpihito Bros.
Zonolite Chubby & Tubby
Asbestiform
Regulated Mineral
Type
None Detected
Actinolite
Tremolite
Total
Actinolite
None Detected
Weight
Percent

0.94
0.94
1.88
0.33

Other Components
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubtes
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Weight
Percent
3.24
61.36
35.40
4.53
1.21
92.38
2.06
65.02
32.59
2.12
0.91
96.97
Propped
By
DW
DW
DW
DW
Prep
Date(s)
03/1 3/00
03/1 3/00
03/1 3/00
03/1 3/00
Analyst
JH
JH
JH
JH
Analysis
Date
03/22/00
03/22/00
03/23/00
03/23/00
O0022400.bul

-------
                                                                    Lab/Cor, Inc.
                                                      A Professional Service Corporation in the .Vort Invest
             Report Number: 000233
Report Date: June 1, 200(1
Client Information
Project Name: Retail
Homc&Garden/MEL
Project No.: Not Available
P.O. No.: Not Available

Tracking Information
Login: Mar 13, 2000 By: Mil
Reviewed: Mar 27, 2000 By: Ji I
Final Review: Jun 1,2000 By: TMM

Analysis Information
Stun/ jlc Type: Bulk
Analysis Type: Semi-Quantitative
Re je re nee No. : EP A/600/R-9 3/ 1 1 6
68-02-3266
                                                                      FINAL TABLE
                                        Transmission Electron Microscopy - Semi-Quantitative- Bulk Sample Analysis
Lab/Cor
Sample No.
ryj02'J3-U1

030233-02

000233-03

000233-04

000233-05

000233-06

000233-07

Client
Sample No.
54203

54204

54205

54206

54207

80772

80773

Description
Whitney Farms Residue

Scotts Residue

Zonolite Residue

Zonolite Residue

ThermoRock

#3 Residue

#4 Residue

Asbestiform
Regulated Mineral
Type
None Detected

None Detected

Tremolite

Tremolite

Actinolite

Tremolite

Tremolite

Weight
Percent




0.10

2.79

0.30

0.24

0.64

Other Components
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Organics
Acid Solubles
Other Nonasbestos
Weight
Percent
9.09
7273
18.18
2.50
87.50
10.00
256
92.31
5 03
0.00
72.09
25.12
2.17
67.39
30.14
28.57
47.62
23.57
8.00
28.00
63.36
Propped
By
DW

DW

DW

DW

DW

DW

DW

Prep
Date(s)
03/1 4/00

03/1 4/00

03/1 4/00

03/14/00

03/14/00

03/14/00

03/1 4/00

Analyst
JH

JH

JH

JH

JH

JH

JH

Analysis
Date
03/26/00

03/26/00

03/26/00

03/26/00

03/26/00

03/26/00

03/26/00

O0023300.bul

-------
Attachment 3

-------
                                    12/29/99  17:04;  Jei£ax_3709 ; Page 2
                                               InduJtiiol Chcmlcab Group
                                               W.fc. Grocn i Co.
                                               62 V^/hifCemofc
                                               (SIT) 87^-1-100
                                       April 1,  1980  '
Hr- Dale Ray
Consumer Product Safety Coomission
Economic Program. Analysis Division!                       ;
S.OOE 656-B .     -^- ..'•.......'                 '     ' ."
Washington, B.C. 20207          '                      '   * '   •

Dear Mr. Xay:

     This will  confirm our conference call of  March 12, 1980
in which we reviewed with you  the  results of testing performed
by the Construct ion'Products'Division of W. R.  Grace & Co to
deternu'ne  the extent  of  asbest i Form  tremolite  fiber  release
associated with use of Grace vermiculite in consuxner products ,
During  our  conversation.,  you  requested  that  we set  out the
details of  Grace's  fiber  exposure  test methodology and c-est
results and  indicate  the nature  of  Grace's  fiber  reduction
efforts.
     As  you  know,  tremolite  is  a Cramp. mineral  cone aminant
which  is associated  with vermiculite  and  which Grace has
been  acceapting  to reduce  to  Che  maximum extent  feasible.
Since  1970,  Grace  has invested  over  §15  million  to extract
worchless oaterials and  conC .anin an ts  and   to reduce  airborne
fiber  exposure  in  its  vertoiculite  mining,  milling and
expanding operations.   A  substantial  pare  of this investment;
was  associated  wich  the construction by  Grace  of  a new
vertaiculite  mill at  its  Libby,  Montana mine which  uses wet
screening and  other wet ore beneficiat ion  processes  designed
to  reduce  the  asbestifortn  tremolite  contaminant:  associated
wich vermiculite.
                               che new mill,  in  early  1975
      Following  startup of
Ccace  took  further  steps to  reduce  tr emol i te  con t araina't i ou
by  repoving  and  disposing  of  selected  fines  which  have   a
higher level  of  contamination,  thereby reducing Che level of
contaroinacion in its  finished  ore  concentrate.   Since that
r. i rae ,  changes  have  been-roade in  the  exfoliacionprocess
equipment used  at  Grace's verraiculite expanding plants which

-------
Sent by:
          Mr.  Dale Ray
- 2  -
A D c i 1  1
          process  Grace vermiculite  ore for  use in  both  consumer  and
          industrial  products.    These  changes  provided  for  further
          screening,  separation,  and  removal  of both  fines  and  the
          heavier  unexpanded residual  high density  material following
          exfoliation  both  of  which  may contain  a higher  level  of
          asbes r. i f or m  tremolite  contamination Chan  Che  finished
          produce.   By use  of  bag  hodses and other  dust  filtration
          equipment,  including  an  air  elutriation  step,   additional
          reduction  of the ttetnolite  fiber  cant aminaCion of expanded
          vermiculite  end product is accomplished,

                 Grace  has  taken the  further  step  of developing a
          binding agent  for its  Zonolite(^)   Attic  Insulation product
          and  has recently started up  equipment at all  its expanding.
          plants to apply  this  binder  CO Attic  Insulation  to further
          reduce dust  and  exposure  to... asbest i form  fibers during   the
          use  of this  product.

                As a  tesulc of these  reductions in asbestiform  tremolite
          contamination,  we  believe- that  consumer  products  containing
          vermiculite  .and  .sold  'by Gracfe do  not  generate  unreasonable
          risks  foe users.   This has  been  verified by Grace's Fiber
          exposure  Cests  of consumer  ptoducts containing expanded
          Grace  vetmiculiCe ore.   All  measurements  were made by.  the
          NIOSH-approved  technique  as set   forth   in  40 CFR Section
          1910-1001,  paragraphs  CO  2nd  ( f) , ' uc il i z ing the  membrane^
          filter  method   at  400-450  X  (magnification)   (A  millimeter
          objective) with  phase contrast illumination.   The results of
          these tests  were  as follows;
                     Produc t

                Terra - Lite(R)  Vermiculite
                Redi-Eartb
-------
Sent by.
    1
             Mr.  Dale Ray                 -  3 -            April  1,  1980


                   The only  Grace - produc t whose use resulted  in a decectable
             fiber exposure  was,  Attiic Insulation and, then, ac low levels
             only during  installation-  .Tests indicate no residual  fiber
             release following  inscall ation.   Since  this  produce  is
             unliVely  to  be used  more than  two  or  three times during  an
             entire  lifetime  and,  then,  only  for  exposure  times  which
             would  not  be expected  to exceed two  hours  in any one  case,
             the  lifetime  dosage  is  several  orders of  magnitude  lower
             Ch-an any  promulgated  government  standard applicable  to
             cremolice  fiber exposure.

                   Grace  Is continuing  to  exert  its  best  efforts  co
             further  reduce  the  asbestiform  tremolite  contamination
             associated  with  its vermiculite  products  to  the maximum
             extent  feasible,   For  example,- beginning  xo  Hay of  this
             year  a  new cock  and  tremolite removal  circuit should  be
             operational at the  Libby mill.  This  circuit  is expected_to
             reduce   the  level  of  tremolite contamination  in fine  size
             vermiculice ore  by  501-   Additional research  is underway Co
             develop a  similar  circuit  for  reduction of  tremolite con-
             taminatioh  in" the  coarser si'zes of  vermiculite  ore  used for
             Zonolite Aceic Insulation.   One promising separation technique
              is slot screening which,  if  successful,  could reduce Ctemolite
             contamination  in  the  coarse  ore   concencrace  by over  50*.

                   We -are .rapidly, approaching,  a  point .of.  diminishing
             return since the  amount  of asbestiform treoioliCe contaminant
              in  the  vertniculite ore  presently  shipped to the exfoliating
              plants  averages  only -0-51  on  a  dry  weight  basis.   tor
              expanded  vermiculite  products,  the level  ot  contaminant  i.
              00Pavera&e  at  or  below the lowest level of  reliable ^Cecta-
             bility, 0.21 on  a  dry  weight basis.   Accordingly, the  5U*.
              reduction Grace  expects  to  achieve in  .the  fine ores  by  May
              and, ultimately,  the coarse ore sizes is a  reduction  from  an
              already very low  contaminant  level.  With  tnis  background,  i v,
              is  cleat  to us that  the task  of further reducing the  remaining
              residual   contamination  in  unexpended  ore  and  expanded
              vertniculite products will  show a  rapidly escalaCin£  cose  .in
              relation  to the  benefits derived.

-------
                                      12/29-99 I/: Oi;  M£flJL_S709 ; Page 5/17
Mr.  Dale  Ray                 - 4 _             April  1,  1980
     We  truEC  that  this  infarmacicm will  he useful  to you
in  connection  with  cbe  CPSC's  evaluation  of  the asbestos
coritamina tion issue.


                                 Very  truly yours,



                                 E. S. Wood
                                 Executive  Vice  Pcesideoc

-------
                                                    JeiD?A_r- 709 : r a c,; C
                                                        .ftrule.,*. A

             USER EXPOSURE TO FIBROUS TREHQL1TE
              ITT VER.HfcUrnT~CQ^S[JHER PRODUCT'S"

                          TEST J3ATA
                       \ .

 I .   TEST  PROTOCOL

 A.   Horticultural Products

      1.   Consumer Use  of Tetra-Lite(R) VerjaicruI^Ce (a)

         Ca)  _Mix and  fill pots  to simulate consumer  preparation

 of  a  mi*  of  505. peat moss and  501 Terra-Lite 'vermiculite by

 scooping  equal volumes  of materials, out of separate  packages

 and  depositing on work  surface.   Hand mix to reasonable

 uniformity  and fill  fifteen (15) 4" diameter flower  pocs in

 15  minutes.-  Press down-to firm-up the sosl co hold  the plane.

      After  8 days the  15 pots  were brought into  tha  work

 area  where  three separate procedures ware performed.   Fiber

 counts were  taken during each  of these threa procedures.

 Five  pots were used  for  each of  the three procedures.

       (b) Knock Out  and  Disposal-- To simulate the  consumer

 u)ho  does  not  intend  to  reuse the soil.  Invert the  pot and

 roD  on che  working surface so  Chac Che soil drops  out.

 Brush  che mound of soil  off the  bench into a disposal

 container.   Take a paper towel  and wipe inside of  pot  so

 that  is is clean for reuse and  dispose of the paper  towel.

 In  this procedure,  contents of  five pots will be. disposed of

during the  15  minute test period.

       (c) Knock Out  and  Reuse  for  Pocting Other  Plants -

Simulate  a consumer  who  will reuse the potting soil.   R^p

one  on workbench by  hand and break up che lump of  soil no

-------
u-^'ta  it  sinilar to its  original free-flowing condition.




Repeat  Chis  five times.   Combine all soil into one  pile;




Chen  proceed to r^fi 11 N po t s  by scooping the material  back  in




and tamping' it  down.   In  Chis 15 minuce rest procedure,  five



pocs  will  be filled.




      (d) Krnp£k_Chjt and  Blend with New Porting. Soil  -  Simulate




a consumer  who  will blend old wich new potting soil.   Rap




pot on  workbench by band  and break up the lump of soil co




make  it  similar Co its  original free-flowing condician.




Repeat  procedure five  times.  Obtain additional potting  soil




LO match Che volume of  the dried soil.  Place new soil on




Lop -of  the  old  soil-and mix  together by hand.  Use  chis  mix




co fill  pocs.   During  this 15 minute test procedure,  10  pocs



are filled.




2 .   Consumer  Use of _Re_d_i-E_ar th (R) Pocting Soil ^ ^ ^




      (a)  Same  procedure  as  1 (a), exc ept; s ubs t i t UL e  premised




Redi-eavth  for  Terra-Lite Vermiculite as the soil medium.




      (b)  Sane  procedure  as  1 (b).




      (c)  Same  procedure  as  1 (c).




      (d)  Same  procedure  as  1 (d).




B.   Consumer  Use of Lightweight Fercilizec




      1.  Cane-r al




      A  five  building  ap^rcoienc corr.pltix was selsctod  as  r h a




test   site.    With over  100,000 sq.  ft- of grass area,  Che




site   allowed  aic  sacpling while fertilising over an  extended




peri od of C i crie .

-------
                                                        _#709;=3c;e 8/17





the spreader hopper  and fertilizing,  and  the Other maintaining
1 o £ sheets,  time  and purap calibrations.




2 •  Application  of: Li^hj^gJiKht Lawn
     Two sampling pumps with  filter  cassettes located  in  the




left and right breaching zones  were  worn by the applicator




during the  s ampl ing / f e r t i 1 i z ing period.  The applicator




filled the  spreader hopper  to within 2" of the top  and




refilled when the hopper was  approximately 3/Achs empty.




Using  a  new Model 35 Scotts spreader with guide markets,  the




applicator  spread thirteen (13) hags of lawn  fertilizer  at




che  normal  coverage  application rate (5000  ft2/bag).




C.   Consumer  Installation  of Vermiculi te Attic  Insulation




1 .   Gener al



       Veronculite Attic  Insulation  is  generally  purchased  in




quantities  of  10  -  100  bags  per home to "retrofit" or "add




 to"  exist.ing  insulsticn in ^n  existing home.   Seldom-  is



 vermiculite  Acc:C  Insulation  installed in  new construction.




 To determine  consuaei  exposucR  to tcemolite fibers, ihe




 tollowing  series  of tests  by  hoKc owners  was intended to




 indicate actual e*posi:res  under  a variety  of conditions.




 2 .  Area E ngjjn_£e£ i n g Sam^pJ^e^




       Engineering aaaiples  were taken  as follows:



       (a)  Prior ro installing vcrmiculite Attic  Insulation,




 monitor attic space for 5  -  6 hours.



       (b)  Approximately cwo  months  after installing  insulation,




 oonitor attic space for 5 -  6 hours.

-------
                                         -~'2^/9i; 17:0';;   Jel£ax_#709 ; Page 9/1
       Each  test  home utilized  40 - 70 bags  (3 cubic  feet

 each) of vecDuculite Attic  Insulation.  The installer  was

 monitored  during the placement  of insulation.

       Initially,  place 15  -  20 bags in the attic.  The

 installer  poured all" bags and "leveled insulation  with  a

 wooden hand screed  or one with  a  handle r.o push insularion

 back  into  roof  eaves.   Additional bags were brought  to the

 attic in lots of  15  - 20 bags as  required.
 NOTES:
      (a) Terra-Lite  vermicullte  is  composed of expanded #3
     iculjce ore from  either Libby,  Montana or Enoree, South
Carolina.

      (b) Redi-Ear-ch  is  a  potting soil  cons'iscine of a
mixture of SOZ-pfrac moss  and 50* expanded  {3 wermiculice ore
from either Libby, Montana or Enoree,  South  Carolina with
plant  nutrients added.

      (c)  Lightweight  fertilizer utilizes expanded ^ veruiicu-
lite ore from either  Libby,  Montana or Enoree,  South Carolina,

      (d)  Attic  Insulation  is composed-of expanded ^1 or #2
vermiculite ore available  only from Libby, Montana.

      (e)  Po.ol Cushion which  was not tested utilizes  expanded
/3 vermiculite  ore from either  Libby,  Montana or  Enoree
Sourh  Carolina.                                           '

-------
                                                17:0';:  Jet£ax_JT''09 ; P?.ge 9/17

                                                      in a  Home
       Each  test  home utilized  40 - 70 bags  (3 cubic  feet

 each) of veruuculite Attic  Insulacion.  The installer  was

 monitored  during the placement  of insulation.

       Initially,  place 15 -  20 bags in the antic.  The

 installer  poured all" bags and "leveled insulation with  a

 wooden hand screed  or one with  a  handle ro push insularion

 back  into  roof  eaves.   Additional bags were brought  to the

 attic in lots of  15  - 20 bags as  required.
 NOTES;
«etm,
 (a)  Terra-Lite vermicull te is composed  of expanded #3
,cul>te ore from either Libb   Mont
                         ther Libby,  Montana or Enoree, South


      (b)  Redi-Earth  is  a  poctinc soil  cons'isc ing of a
mixture of 50^ peat moss  and 50i expanded  #3 wermiculice ore
from etcher Libby, Montana or Enoree,  South Carolina with
plant  nutrients added.


      (c)  Lightweight  fertilizer utilizes expanded ^ veruiicu-
lice ore  from  either  Libby,  Montana or Enoree,  South Carolina

      (d)  Attic  Insulation  is, composed-of expanded rl or S2
vermiculite Ore available  only from Libby,  Montana.

      (e)  Po.ol  Cushion which  was not tested  utilizes  expanded
/3 vermiculite  ore from either  Libby,  Montana or  Enoree
South  Carolina.                                           '

-------
RESULTS  (See
1)
                         PERSONNEL AVE.
                         EXPOSURE  (£/cc)
                                          M£aA_?'70Q : Fag e 10/17
                                                                     PERSONNEL TWA
A. HORTICULTURAL ^ODUCTS (see^>toCe 2) ^- Carolina
1 . Consumer Use ($£ Terra-Lite Vertniculite
Ca) Mix and F^T-l Pots ' <^Q Tg
(b) Knock Out x**^ Disposal ^ ^
(c) Knock Out *^J Reuse ^rn ]_/,
(d) feock OtJt Axf*J Blend ^ ^_/(
2 ConsLiner Use /v.f. Red i- Earth
(a) Mix and Fil^?0^ <-Q ^Q
(b) Knock Out x*^ Disposal <^i.Vt
Cc) Knock Out &f~d Reuse . «m 1/1
(d) Knock Out 3^ Blend <0.14
B. LICHPVEIGHT FEK^LIZER
1. Application o/ -Lightweight Fertilizer
With Mont.*03 derive^T uermiculita
C. Hone Inscallac its* of Vermiculite Attic Insulacioo
1. Eripineer inf /-^rea Samples
Type ^°- Fiber Concentration
Hems . Home aaK£ . . Attic
Be tore
F . Colonel 55 0.03 (see note A)
N Cape 30 HO TEST -
S lUnch 64 
After (see note 3)
<0.01

-------
  Home
           Hccne
   P       Colonial

   N       Cape

   S       Ranch

   W       Colonial
                                        12/29/99 17:06;  Jfij£o>L_?;7C9 : Page

                                        l Exposure Cf/ccJ)
                                                   TWA (see noce 5)

                                                   Q.649
                                                   0.529

                                                   0.436
NOTES:

      1.   The symbol <  (less  Chan)  indicates no  fibers were
observed  in the counted  fields.   As a measure of "test
precision,  results are reported  Co be less than the  value
representea by one fiber
the  observed fields.
                           4	.  ~~^ "~ —* •^•-.••j** U-IJOli  t-i/C  VOJUUt-
                           if  such had been detected  in one of
      According to NIOSH  reports,  che limit of  reliable
deteccaility for chis tesc  procedure is 0.5  f/cc  exposure
and  0.1  f/cc TWA.  Values below 0.5 f/cc exposure and 0.1
f/cc  TVA. are not judged  as  detectable.
                       horitculCura 1 products wa
using  products made from  both  Libby,  Montana
South  Carolina ore.  The  Grace  vermiculite
making Accic  Insulation
      2.   Each test of horitculCura 1 products was  repeated
                                               ore  and  Enoree
                                             are  used  in
                         originates  from the Libby, Montana
mine  as does  the ore purchased  by  0.  M,  "  . .. - -
in its  lightweight lawn fertilizer.--
                                          ScoCC &  Sons  for  use
      3.   In  addition to results  tabulated, two  additional
tests  indicate no fibers detected  in attics  insulated  with
vermiculite  loose fill in one  case six hours and  in  another
c^se  approximately nine years  after installation.

      it.   In  all home attics  tested, vermiculite Attic
Insulation was added as a retrofit insulation over existing
glass, mineral wool or cellulose  insulation.  In  home  "F",°a
fiber  was observed in the counted  fields prior  to pouring
vermiculite  Attic Insulation.  Although lengCh  and aspect
ratio  fell uithin che fiber  definition, ic is believed to be
airborne glass fiber from existing insulation.  There  was no
•jermiculite  Actic Tnsulajrion  in  Che" attic when  Chis  pcejob
sainple was taken.
                          - 6  -

-------
Sent by:
          e*o^     rn  calculacinS the time-weighted  average  (TVA)

          that thJ !«rC£nSiT" u^ng ^CiC Illation,  ft  is  assumed
          for two hours  ?°    wo?k. »" c»>e actic pouring Attic  Insulation
          Cor two hours  in one eight-hour work day.  -Results  ir C   1
          xnd,cate no  further exposures after i ns ta llaC ion   iL     '

          tnIulCl??Q;X?°Sl:'):f-a"d rlSk associ^ed with Che  use  of Attic
          Insulation is  infinites Smally small compared  to industrial

                                                                S
                iaif
          twice an a lifetime)  compared to a permitted  industrial

          rh?ou^LrP C°  2J/CC dUrin8 eaCh e?ght-hour  iork  da"
          throughout a working  lifetime.   Therefore, comparison of
          TWAs  between a  rare and- nonrouc ine e^posura  In  the  case of
          Atcic Insulation  and  the OSHA industrial standard  of 2 f/cc
          vastly overstates the potential ha2atd involved  in  Ehe use
          or Attic Insulacion.

-------
Attachment 4

-------
               Report Number: 000146
                                                                     Lab/Cor, Inc.
                                                        A Professional Service Corporation in the Northwest
                                                                                                                       Report Date: May 25, 2000
                         Client Information
               Project Name: EPA Region 10
                             Vermiculite Project
               Project No.:    Not Available
               P.O. No.:     OY0107NASX
               Sample Type:   Air
Tracking Information
Login:
Prep:
Verified:
Reviewed:
Final Review:
Feb 17,2000
Feb 18, 2000
Feb 18, 2000
Feb 2 1,2000
May 25, 2000
By: GG
By: DW
By: DW
By: JH
By: TMM
                                                                                                                  AnaJysis Information
Analysis Type:     NIOSH
Reference No.:     7402
Min. Aspect Ratio: 3:1
Min. Length:      5 |im
Min. Width:       0.25 urn
FINAL TABLE
Transmission Electron Microscopy - NIOSH - Air Sample Analysis
Description
[ 	
Pump #1 Flowrate 2.85 l/m 30 mi
#1
— • 	 	 	
Pump #5 Flowrate 2.85 l/m 30 min
#2
	 • 	 . 	
Pump #1 Flowrate 2.8 l/m 30 min
FJ
	
Pump #5 Flowrate 2.8 l/m 30 min
#4
	
3ump #1 Flowrate 2.8 l/m 30 min
o
	 • 	 	 	
Pump #5 Flowrate 2.8 l/m 30 min
#6
	 — 	 : 	
Fiber Type
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
Concen-
tration
(struc/cc)
<0.022
<0.022
<0.022
<0.022
<0.022
<0.022
0.023
0.023
<0.023
_
O.023
0.068
0.068
•
O.023
0.023
0.023
O.023
0.046
0.046

96% Confidence
Interval
(struc/cc)
— 	 	 — _ —
0-0.083
0-0.083
0 - 0.083
	
0-0.083
0-0.083
0 - 0.083
	 • 	 	 	
0-0.084
0-0.084
0 - 0.084
	 • 	
0-0.084
0.014-0.200
0.014 - 0.200
	 	 — • 	
0-0.084
0.001 -0.127
0.001 - 0.127
~" 	 ' — • 	
0-0.084
0.006-0.164
0.006 - 0.164
	 • 	
Struc.
Count
0
0
0
0
0
0
0
0
0
0
3
3
0
1
1
0
2
2
Opt. Vis
Asb.
Fibs. (%)
NA

NA
NA
0
0
0
Analytical
Sens.
(struc/cc)
0.022
0.022
0.023
0.023
0.023
0.023
Volume
(liters)
85.5
85.5
84.0
840
84.0
84.0
( Number
of Grid
Openings
20
20
20
20
20
20
Filter
Area
(mm2)
385
385
385
385
385
385
Area
Analyzes
(mm2)
0.2013
0.2013
0.2013
0.2013
0.2013
0.2013
Analyst
GG
GG
GG
GG
GG
GG
Analysts
Date
2/18/00
2/18/00
2/18/00
2/18/00
2/18/00
2/18/00
     No, APp,,caW, For san.p.es ,„
    of asbestos to
areas.
        ribers
                                                 „
0001 460 l.tem
                                                                                                                                  NIOSH im
                                                                                                                                          as

-------
                                                                     Lab/Cor, Inc.
                                                        A Professional Service Corporation in the Northwest
              Report Number: 000146
                                                                                                                      Report Date: May 25, 2000
                        Client Information
               Project Name: EPA Region 10
                            Vermiculite Project
               Project No.:   Not Available
               P.O. No.:     OY0107NASX
               Sample Type:  Air
                                                                    Tracking Information
Login:        Feb 17, 2000   By:  GG
Prep:        Feb 18, 2000   By:  DW
Verified:      Feb 18, 2000   By:  DW
Reviewed:     Feb 21,2000   By:  JH
Final Review:  May 25, 2000   By:  TMM
                                                                                                                 Analysis Information
Analysis Type:     NIOSH
Reference No.:     7402
Min. Aspect Ratio: 3:1
Min. Length:      5 um
Min. Width:       0.25 urn
r "
Lab/Cor
Sample No
000146-07
Test
000146-08
Test
000146-09
Test
000146-10
Test
000146-11
Test
000146-12
Test
FINAL TABLE
Transmission Electron Microscopy - NIOSH Air Sample Analysis
Client
Sample No.
00074206
00074207
00074208
^— — ^ ^___ __ __
00074209
"
00074210

Description
Pump #1 Flowrate 2.8 l/m 30 min
#7
Pump #5 Flowrate 2.8 l/m 30 min
#8
	 • 	 	 	 . 	
Blank 1
	 	 	 	 	 .
Blank 2
~ 	 • 	 	 	 	 — • 	
QC 1
	 	 	
QC 2

Fiber Type
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
Concen-
tration
(struc/cc)
<0.023
<0.023
<0.023
<0.023
0.023
0.023
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
95% Confidenc
Interval
(struc/cc)
0-0.084
0-0.084
0 - 0.084
0-0.084
0.001 -0.127
0.001 -0.127
NA- NA
NA- NA
NA-NA
NA- NA
NA- NA
NA-NA
NA-NA
NA- NA
NA-NA
NA-NA
NA-NA
NA-NA
Struc
Coun
0
0
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0

Opt. Vis
Asb.
Fibs. (%
NA

0
NA
NA
NA
NA
«^™^^^— ^™,
Analytical
Sens.
(struc/cc)
0.023
0.023
NA
NA
NA
NA
«^w^^«^mw
Volume
(liters)
84.0
84.0





Number
of Grid
Openings
20
20
20
20
20
20

Filter
Area
(rreri2)
385
385
385
385
385
385

Area
Analyzes
(mni2)
0.2013
0.2013
0.2013
0.2013
0.2013
0.2013

Analyst
GG
GG
GG
GG
GG
GG

Analysis
Date
2/21/00
2/21/00
2/21/00
2/21/00
2/21/00
2/21/00

                     as a 2Z; l^^^^^^^^^^;^^^ " - «•« - — * MOSH .00 s—s
NA - No, Apptabte For samples in which no fiber »pes a. found, percenage values do no, apply.
NOTE: These counting rules are intended to coincide with NIOSH 7400
       TEM airborne analysis methods (AHERA, EPA - Yamate)      counting ""^ and do not measure smaller asbestos fiber populations below 5.0 um lengths as would other
00014601.tern

-------
             Report Number: 000147
                                                                Lab/Cor, Inc.
                                                    A Professional Service Corporation in the Northwest

Client Information
Project Name: EPA Region 10
Venniculite Project
Project No.: Not Available
P. O. No.: OY0107NASX
Sample Type: Air

>
i\<-yvii LJUIK. IvidiLU LL, /UUl
Tracking Infom.at.nn 	 Ana|ysis ,nformation
P0g'"' Ft!™ By:GG Analyse Type: Mod.ficd EPA-II
Prep: Feb 18, 2000 By: DW Reference No.: 68-02-3266
Verified: Feb 18, 2000 By: ^ ' M^n. Aspect Ratio- 51
Reviewed: Feb 21, 2000 By: m Min. Length: 0.5 urn
tonal Review: 'Mat 22,2m By: m Min. Width: NA
Lab Filter Area: 221 mm2



FINAL TABLE
Transmission Electron Microscopy - Modified EPA-II (Direct and Indirect) - Air Sample Analysis
Lab/Cor
Sample No
000147-01
Direct
000147-02
Direct
000147-03
Direct
000147-04
Direct
000147-05
Indirect
000147-06
Indirect
000147-07
Blank
Client
Sample No.
00074212
00074213
00074214
00074215
00074216
00074217
00074218
Description
Pump #3 Flowrate 11.1 l/m 100
mins #9
Pump #4 Flowrate 11.15t/m 100
mins #10
Pump #3 Flowrate 1 1 .0 l/m 100
mins #11
Pump #4 Flowrate 1 1 .0 l/m 1 00
mins #12
Pump #4 Flowrate 11 .1 l/m 100
mins #13

Pump #4 Flowrate 11.1 l/m 100
mins #1 4

Blank #1

Fiber Type
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= Sum
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
Density
(s/mm2)
0
0
13.8
0
0
0
0
0
0
0
0
13.8
4139.4
1993.1
1533.1
2769.6
1226.5
766.6
Concen-
tration
(struc/cc)
<0.005
<0.005
0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.005
0.847
0.408
0.314
0.564
0.251
0.157
95% Confidence
Interval
(struc/cc)
0 -0.018
0- 0.018
0.000 - 0.027
0 -0.018
0- 0.018
0-0.018
0-0.018
0-0.018
0-0.018
0 -0.018
0-0.018
0.000-0.027
0.527- 1.166
0.217-0.697
0.150-0.577
0.335-0.892
0.108-0.494
0.051 - 0.366
Struc.
Count
0
0
1
0
0
0
0
0
0
0
0
1
27
13
10
18
8
5
Analytical
Sens.
(struc/cc)
0.005

0.005
0.005
0.005
0.031
0.031
Volume
(liters)
1110.0
1115.0
1100.0
1100.0
1110.0
1110.0
Number
of Grid
Openings
5
5
5
5
10
10
Dilution
Factor



22.2
22.2
NOT ANALYZED
Area
Analyzed
(mm2)
0.0725
0.0725
0.0725
0.0725
0.1449
0.1449
1 	
Analyst
GG
GG
GG
GG
JH
JH
T~ 	 ~™
Analysis
Date
T 	 1
2/21/00
2/21/00
2/21/00
2/21/00
3/21/00
3/21/00

00014705.tern

-------
                                                                    Lab/Cor,  Inc.
                                                       A Professional Service Corporation in the Northwest
              Report Number: 000147
                        Client Information
               Project Name:  EPA Region 10
                            Vermiculite Project
               Project No.:    Not Available
               P. O. No.:     OYOI07NASX
               Sample Type:   Air
Tracking Information
Login:
Prep:
Verified:
Reviewed:
Final Review:
Feb 17, 2000
Feb 18, 2000
Feb 18, 2000
Feb 2 1,2000
Mar 22, 2000
By: GG
By: DW
By: DW
By: JH
By: JH
                                                                                                                    Report Date: March 22, 2000
                                                                                                                 Analysis Information
Analysis Type:     Modified EPA-II
Reference No.:     68 - 02 - 3266
Min. Aspect Ratio: 5:1
Min. Length:      0.5 ujn
Min. Width:   NA
Lab Filter Area:    227mm2
                                                                       FINAL TABLE
                                 Transmission Electron Microscopy - Modified EPA-II (Direct and Indirect) - Air Sample Analysis
LaWCor
Sample No.
000147-08
Blank
000147-09
QC

Client
Sample No.
00074219

74220


Description
Blank #2

QC


Fiber Type
TOTAL ASBESTOS
ASBESTOS >= 5 pm
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 pm
NON-ASBESTOS

Density Concert- 95% Confidence
(s/mmZ) tration Interval
(struc/cc) (struc/cc)

N 0

N 0

Struc.
Count
=s=^=:anA
T

T

Analytical
Sens.
(struc/cc)

A N i

A N /

Volume
(liters)

<\ L

\ L
• ^— — •
Number
of Grid
Openings
H 1 • 1 II 1
Y Z E

Y Z E

Dilution Area
Factor Analyzed
fmm2)

D

D

Analyst Analysis
' Date
1 '




00014705. tcm

-------
                                                                   Lab/Cor, Inc.
                                                      A Professional Service Corporation in the North-west
              Report Number: 000225
              Report Date: June 3, 2000
                        Client Information
              Project Name: Venniculite Air Samples
              Project No.:   ESD-045A
              P. 0. No.:     0001B10P40101C
              Sample Type:  Air
Tracking Information
Login:
Prep:
Verified:
Reviewed:
Final Review:
Mar 10, 2000
Mar 14, 2000
Mar 14, 2000
Mar 26, 2000
Jun 3, 2000
By: DJ
By: DW
By: DW
By: JH
By: TMM
         Analysis Information
Analysis Type:     EPA-II
Reference No.:     68-02-3266
Min. Aspect Ratio: 5:1
Min. Length:      0.5 (im
Min. Width:       NA
                                                                       FINAL TABLE
                                               Transmission Electron Microscopy - EPA-II - Air Sample Analysis
Lab/Cor
Sample No
000225-01
Indirect
000225-02
Indirect
000225-03
Direct
000225-04
Direct
000225-05
Indirect
000225-06
Indirect
000225-07
Direct
000225-08
Direct
Client
Sample No.
00104201
00104202
00104203
00104204
00104205
00104206
00104207
00104208
Description
Pump#1
Pump #5
Field Blank
QC Unopened
Dump #1
Pump #5

Background Pump #1

ackground Pump #5

Fiber Type
TOTAL ASBESTOS
ASBESTOS >= Sum
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 pm
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5 urn
NON-ASBESTOS
Density
(s/mm2)
73.6
64.4
27.6
138.0
92.0
55.2
0
0
0
0
0
0
138.0
138.0
965.9
27.6
27.6
64.4
0
0
0
0
0
13.8
Concen-
tration
(struc/cc)
0.202
0.177
0.076
0.373
0.249
0.149
<3.055
<3.055
<3.055
<2.829
<2.829
<2.829
0.380
0.380
2.658
0.080
0.080
0.187
<0.031
O.031
<0.031
<0.031
O.031
0.061
95% Confidence
Interval
(struc/cc)
0.087 - 0.399
0.071 - 0.365
0.016-0.222
0.209 -0.615
0.119-0.457
0.055 - 0.325
0- 11.273
0-11 .273
0-11 .273
0 - 10.439
0- 10.439
0- 10.439
0.010-2.115
0.010-2.115
1 .067 - 5.475
0.017-0.235
0.017-0.235
0.075 - 0.386
0-0.116
0-0.116
0-0 116
0-0.113
0-0.113
0.007 - 0.220
Struc.
Count
8
7
3
15
10
6
0
0
0
0
0
0
1
1
7
3
, 3
7
0
0
0
0
0
2
Analytical
Sens.
(struc/cc)
0.025

0.025
3.055
2.829
0.380
0.027
0.031
0.031
Volume
(liters)
82.5
84.0
1.0
1.0
82.5
78.0
87.0
87.0
Number
of Grid
Openings
10
10
9
10
10
10
10
10
Filter
Area
(mm2)
385
385
385
385
385
385
385
385
Area
Analyzec
(mm2)
0.1449
0.1449
0.1260
0.1361
0.1449
0.1449
0.1405
0.1449
Analys
JH
JH
JH
JH
JH
JH
JH
JH
Analysis
Date
3/25/00
3/25/00
3/25/00
3/25/00
3/25/00
3/25/00
3/25/00
3/25/00
00(122501.10111

-------
                                                                  Lab/Cor, Inc.
                                                      A Professional Sen/ice Corporation in the Northwest
             Report Number: 000225
              Report Date: June 3, 2000
                       Client Information
              Project Name: Venniculitc Air Samples
              Project No.:   ESD-045A
              P.O. No.:    0001B10P40101C
              Sample Type:  Air
Tracking Information
Login:
Prep:
Verified:
Reviewed:
Final Review:
Mar 10,2000
Mar 14, 2000
Mar 14, 2000
Mar 26, 2000
Jim 3, 2000
By: DJ
By: DW
By: DW
By: JR
By: TMM
        Analysis Information
Analysis Type:     EPA-II
Reference No.:     68 - 02 - 3266
Min. Aspect Ratio:  5:1
Min. Length:       0.5 jim
Min. Width:       NA
                                                                      FINAL TABLE
                                              Transmission Electron Microscopy - EPA-II - Air Sample Analysis
Lab/Cor
Sample No.
000225-09
Indirect
000225-10
Indirect
000225-11
Direct
000225-12
Direct
Client
Sample No.
00104209
00104210
00104211
00104212
Description
Pump#1
Pump #5
Field Blank
QC Blank Unopened
Fiber Type
TOTAL ASBESTOS
ASBESTOS >=5 pm
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >=5 pm
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5pm
NON-ASBESTOS
TOTAL ASBESTOS
ASBESTOS >= 5pm
NON-ASBESTOS
Density
(s/mm2)
2621.6
1103.8
1103.8
3131.3
854.0
1281.0
0
0
0
0
o •
0
Concen-
tration
(struc/cc)
6.960
2.931
2.931
8.170
2.228
3.342
<2.656
<2.656
<2.656
<2.656
<2.656
<2.656
95% Confidence
Interval
(struc/cc)
4.191 - 10.869
1.264-5.773
1 .264 - 5.773
4.756-11.584
0.817-4.850
1.530-6.321
0-9.801
0-9.801
0 - 9.801
0 - 9.801
0 - 9.801
0 - 9.801
Struc.
Count
19
8
8
22
6
9
0
0
0
0
0
0
Analytical
Sens.
(struc/cc)
0.366
0.371
2.656
2.656
Volume
(liters)
85.5
87.0
1.0
1.0
Number
of Grid
Openings
10
10
10
10
Filter
Area
(mm2)
385
385
385
385
Area
Analyzed
(mm2)
0.1449
0.1405
0.1449
0.1449
Analyst
JH
JH
JH
JH
Analysis
Date
3/25/00
3/26/OQ
3/25/00
3/25/00
00022501.tern

-------
                                                                     Lab/Cor, Inc.
                                                        A Professional Service Corporation in the Northwest
             Report Number: 000370
                                                                                                                         Report Date: June 6, 2000
                        Client Information
              Project Name:  Vermiculite Project
              Project No.:    Not Available
              P. O. No.:      OY0107NASX
              Sample Type:   Air
                                                                     Tracking Information
Login:       Apr 14, 2000   By: BAR
Prep:        Apr 17, 2000   By: DW
Verified:      Apr 17, 2000   By: DW
Reviewed:    Apr 20, 2000   By: JH
Final Review: Jun 6, 2000     By: JH
                                                       Analysis Information
Analysis Type:    N1OSH
Reference No.:    7402
Min. Aspect Ratio: 3:1
Min. Length:      5 urn
Min. Width:       0.25 urn
                                                                        FINAL TABLE
                                                Transmission Electron Microscopy - NIOSH - Air Sample Analysis
Lab/Cor
Sample No.
000370-01
Test
000370-02
Test
000370--03
Test
OO0370-04
Test
000370-05
Test
000370-O6
Test
Client
Sample No.
00154012

00154013

00154014

00154015

00154016

00154019

Description
Work Area Background

Work Area Background

QC Unopened

Field Blank

Field Blank

Dump 1

Fiber Type
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
1 	
ASBESTOS
NON-ASBESTOS
TOTAL
Concen-
tration
<0.029
0.088
0.088
O.031
0.031
0.031
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.063
0.508
0.508
96% Confidence
Interval
0-0.109
0.018-0.258
0.018-0.268
0-0.114
0.001 -0.172
0.001 -0.172
NA-NA
NA- NA
NA-NA
NA- NA
NA- NA
NA-NA
NA-NA
NA-NA
NA-NA
0-0.234
0.219-1.001
0.219 - 1.001
Struc.
Count
0
3
3
0
1
1
0
2
2
0
0
0
0
1
1
0
8
8
Opt. Vis.
Asb.
0

0

0

NA

0

0
'
Analytical
Sens.
0.029

0.031

NA

NA

NA

0.063

Volume
(liters)
32.5

31.0







15.1

Number
of Grid
40

40

40

40

40

40

Finer
Area
385

385

385

385

385

385

Area
Analyzed
0.4026

0.4026

0.4026

0.4026

0.3927

0.4026

Analyst
JH

JH

JH

JH

JH

JH

Analysis
Date
4/19/00

4/19/00

4/19/00

4/19/00

4/19/00

4/20AJO

       ""md«!?£ uAs^as°a facTr iff ^' ^ ^^ ™S "^ ^^ ** rePresentative fractl°" of ^sios to total fibers as defined by NIOSH 7400 standards
       and can be used as a factor to determine asbestos concentrations from PCM counts in similar sampling areas.
NA - Not Applicable. For samples in which no fiber types are found, percentage values do not apply.

                                                                                                                         > below 5.
00037002.tern

-------
                                                             Lab/Cor, Inc.
                                                  A Professional Sennce Corporation in the Northwest
            Report Number: 000370
                                                                                                            Report Date: June 6, 2000
Client Information
Project Name: Venniculite Projeci
Project No.: Not Available
P.O. No.: OY0107NASX
Sample Tvpe: Air

Tracking Information
Login: Apr 14, 2000 By: BAR
Prep: Apr 17, 2000 By: DW
Verified: Apr 17, 2000 By: DW
Reviewed: Apr 20, 2000 By: JH
Final Review: Jun 6, 2000 By: JH

Analysis Information
Analysis Type: N1OSH
Reference No.: 7402
Mm. Aspect Ratio: 3: 1
Mm. Length: 5 um
Mm. Width: 0.25 um
                                                                 FINAL TABLE
                                          Transmission Electron Microscopy - NIOSH - Air Sample Analysis
Lab/Cor
Sample No
000370-07
Test
000370-08
Test
000370-09
Test
000370-10
Test
000370-11
Test
000370-12
Test
Client
Sample No.
00154018
00154020
00154021
00154022
00154023
00154000
Description
Pump 5
Pump 5
Pump 1
Pump 5
Pump 1

Pump 5

Fiber Type
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
Concen-
tration
(struc/cc)
<0.060
0.480
0.480
O.060
0.482
0.432
<0.064
0.701
0.701
O.060
0.780
0.780
O.064
0.702
0.702
0.344
1.569
1.913
96% Confidence
Interval
(struc/cc)
0-0.221
0.207 - 0.946
0.207 - 0.946
0 - 0.222
0.208 - 0.949
0.208 - 0.949
0 - 0.235
0.350-1.253
0.350 - 1.253
0-0.221
0.415- 1.334
0.415 - 1.334
0 - 0.235
0.350-1.256
0.350 - 1.266
0.158-0.651
1 .089 - 2.049
1.383 - 2.444
Struc
Count
0
8
8
0
8
8
0
11
11
0
13
13
0
11
11
9
41
60
Opt. Vis
Asb.
Fibs. (%
0
0
0
0
0
18
Analytica
Sens.
(struc/cc)
0.060
0060
0.064
0.060
0.064
0.038
Volume
(liters)
15.9
15.9
15.0
15.9
15.0
40.0
Number
of Grid
40
40
40
40
40
25
Filter
Area
385
385
385
385
385
385
Area
Analyzed
0.4026
0,4026
0.4026
0.4026
0.4026
0.2516
Analyst
JH
JH
JH
JH
JH
JH
Analysis
Date
4/20/00
4/20/00
4/20/00
4/20/00
4/20/00
4/20/00
% Optically Visible Asbestos Fibers = (#Asbestos / #Total Fibers). This number indicates the representative fraction of asbestos to total fibers as defined by NIOSH 7400 standards
       and can be used as a factor to determine asbestos concentrations from PCM counts in similar sampling areas.
NA - Not Applicable. For samples in which no fiber types are found, percentage values do not apply.

NOTE:  ™^£Z?££?<££££t IVTl"7400 COUMi"8 ^es ffid do "*
00037002.tem

-------
                                                                     Lab/Cor,  Inc.
                                                        A Professional Service Corporation in the Northwest
             Report Number: 000370
               Report Date: June 6, 2000
                       Client Information
              Project Name: Vermiculite Project
              Project No.:   Not Available
              P.O. No.:     OY0107NASX
              Sample Type:  Air
Tracking Information
Login:
Prep:
Verified:
Reviewed:
Final Review:
Apr 14, 2000
Apr 17, 2000
Apr 17, 2000
Apr 20, 2000
Jun 6, 2000
By: BAR
By: DW
By: DW
By: JH
By: JH
         Analysis Information
Analysis Type:
Reference No.:
NIOSH
7402
Min. Aspect Ratio:  3 : 1
Mm. Length:
Min. Width:
                                                                                                                             0.25
                                                                         FINAL TABLE
                                                Transmission Electron Microscopy - NIOSH - Air Sample Analysis
Lab/Cor
Sample No.
000370-13
Test
000370-14
Test
000370-15
Test
000370-16
Test
000370-17
Test
000370-18
Test
Client
Sample No.
00154001
00154002
00154003
00154006
00154007
00154008
Description
Pump 1
Pump 1
Pump 5
Field Blank opened 2 sec.
QC Unopened
Pump 1
Fiber Type
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
Concen-
tration
(struc/cc)
0.352
1.056
1.408
0.342
1.710
2.052
0.160
1.055
1.215
NA
NA
NA
NA
NA
NA
0.702
2.233
2.935
96% Confidence
Interval
(struc/cc)
0.176-0.630
0.696-1.416
0.992 - 1.824
0.148-0.674
1.180-2.240
1.472 - 2.633
0.052 - 0.373
0.695- 1.415
0.829 - 1.601
NA-NA
NA-NA
NA-NA
NA- NA
NA- NA
NA-NA
0.350-1.256
1 .493 - 2.973
2.087 - 3.784
Struc.
Count
11
33
44
8
40
48
5
33
38
0
2
2
0
2
2
11
35
46
Opt. Vis.
Asb.
Fibs. (%)
25
17
13
0
0
24
Analytical
Sens.
(struc/cc)
0.032
0.043
0.032
NA
NA
0.064
Volume
(liters)
29.9
22.4
29.9


15.0
Number
of Grid
Openings
40
40
40
40
40
40
Filter
Area
(mm?)
385
385
385
385
385
385
Area
Analyzed
(mm2)
0.4026
0.4026
04026
0.4026
0.4026
0.4026
Analyst
JH
JH
JH
JH
JH
JH
Analysis
Date
4/18/00
4/21/00
4/22/00
4/24/00
4/23/00
4/23/00
% Optically Visible Asbestos Fibers = (#Asbestos / #Total Fibers). This number indicates the representative fraction of asbestos to total fibers as defined by NIOSH 7400 standards
        and can be used as a factor to determine asbestos concentrations from PCM counts in similar sampling areas.
NA - Not Applicable. For samples in which no fiber types are found, percentage values do not apply.

NOTE:  These counting rules are intended to coincide with NIOSH 7400 counting rules and do not measure smaller asbestos fiber populations below 5.0 urn lengths as would other
        TEM airborne  analysis methods (AHERA, EPA - Yamate).
00037002.tern

-------
              Report Number: 000370
                        Client Information
               Project Name: Vermiculite Project
               Project No.:    Nol Available
               P. O. No.:     OY0107NASX
               Sample Type:  Air
Lab/Cor
Sample No.
000370-19
Test
000370-20
Test
000370-21
Test
Client
Sample No.
00154009

00154010

00154011

Descriptio
Pump 5

Pump 1

Dump 5

                                                                    Lab/Cor, Inc.
                                                        A Professional Sen'ice Corporation in the Northwest
                                                                                                                       Report Date: June 6. 2000
                                                                    Tracking Information
Login:        Apr 14, 2000   By:  BAR
Prep:         Apr 17, 2000   By:  DW
Verified:      Apr 17, 2000   By:  DW
Reviewed:     Apr 20, 2000   By:  JH
Final Review:  Jun 6, 2000     By:  JH
                                                      Analysis Information
                 NIOSH
Reference No.:     7402
A///J. Aspect Ratio:  3:1
   7. Length:       5 (im
                 0.25 ^m
                                                                        FINAL TABLE
                                               Transmission Electron Microscopy - NIOSH - Air Sample Analysis
Fiber Type
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
ASBESTOS
NON-ASBESTOS
TOTAL
Concen-
tration
(struc/cc)
0.477
2.445
2.922
0.249
2.056
2.306
0.948
2.548.
3.495
96% Confidence
Interval
(struc/cc)
0.206 - 0.940
1.697-3.193
2.104 - 3.740
0.068 - 0.638
1 .355 - 2.758
1.563-3.043
0.542- 1.539
1.786-3.309
2.604 - 4.387
Struc.
Count
8
41
49
4
33
37
16
43
59
Opt. Vis.
Asb.
Fibs. (%)
16
11
27
^— ^— ^—^••,
Analytical
Sens.
(struc/cc)
0.060
0.062
0.059
Volume
(liters)
16.0
15.3
16.1
Number
of Grid
Openings
40
40
40
Fitter
Area
(mm 2)
385
385
385
Area
Analyzed
(mm2)
0,4026
0.4026
0.4026
Analys
JH
JH
JH
Analysis
Date
-—•'- — i— T-t»K
4/22/00
4/24/00
4/22/00
NA - Nol Apptable. For samples m wh.ch no fiber tvpes are found, percentage values do nol apply.
NOTn:                                                   740° COU"""E ""K a"d "" "
00037002. tern

-------
SAMPLING AND ANALYSIS OF CONSUMER GARDEN
     PRODUCTS THAT CONTAIN VERMICULITE
                      Prepared for:

                 Fibers and Organics Branch
             National Program Chemicals Division
            Office of Pollution Prevention and Toxics
            U.S. Environmental Protection Agency
                    401 M Street, S.W.
                   Washington, DC 20460
                       Prepared by:

                       Versar, Inc.
                    6850 Versar Center
                 Springfield, Virginia 22151
                     August 22, 2000

-------
                            TABLE OF CONTENTS
1.0    INTRODUCTION	1
      1.1    Results of Previously Conducted EPA Regional Analyses of Consumer
            Products for Asbestos Content	2
      1.2    Other EPA Asbestos Surveys	3

2.0    METHODS USED FOR THE EPA/OPPT/NPCD CONSUMER PRODUCT STUDY  . 3
      2.1    Consumer Product Collection	3
      2.2    Bulk Product Sampling	4
      2.3    Laboratory Analyses of Bulk Samples	5
      2.4    Consumer Use Simulation	6
      2.5    Region 10 Bulk Product Method Using Sieving 	9

3.0    RESULTS	10
      3.1    Bulk PLM and TEM Analyses  	10
      3.2    SOP 2000	12
      3.3    Superfund Method	12
      3.4    Consumer Use Simulation	12
      3.5    Region 10 Bulk Product Method Using Sieving 	15

4.0    DISCUSSION	15

5.0    RISK ANALYSIS	16

6.0    REFERENCES  	18

APPENDIX A - Laboratory Reports

-------
                                  LIST OF TABLES
Table 1.   Types and Contents of Asbestos Fibers in Vermiculite Produced in the United
          States	19
Table 2.   Analytical Results of EPA Region 10's Study of Asbestos in Consumer Products  . . 20
Table 3.   Vermiculite or Vermiculite-Containing Products Purchased 	21
Table 4.   Analytical Results	22
Table 5.   Results of Asbestos Analyses Using EPA Superfund Method	25
Table 6.   Fiber Levels in Air Inside the Containment	26
Table 7.   Fiber Levels in Outside Air	27
Table 8.   Estimated Cancer Risks from Asbestos Associated with Consumer Use of
          Vermiculite  	28
                                  LIST OF FIGURES
Figure 1.   Zonolite® Sample Purchased from Kent, Washington	29
Figure 2.   Preparation of TEM Grids  	30
Figure 3.   Transmission Electron Microscpe	31
Figure 4.   Elutriator Used in the Superfund Method	32
Figure 5.   Diagram of 10' x 10' x 10' Containment Used in the Product Use Simulation	33
Figure 6.   Containment Used in Product Use Simulation	34
Figure 7.   Consumer Use Simulation Wearing Protective Clothing	35
Figure 8.   Fligh-Volume Air Sampling Pump 	36
Figure 9.   Outdoor Product Use Simulation 	37
Figure 10. Sieving the Vermiculite Product	38
Figure 11. Asbestos Fiber Seen by TEM	39
Figure 12. Actinolite  Asbestos Fiber	40

-------
1.0    INTRODUCTION

       In 1985, EPA evaluated consumer exposures to asbestos in products (e.g., horticultural
products) containing vermiculite (Versar, 1985).  The exposure assessment used analytical data for
exfoliated vermiculite from a 1982 report prepared by MRI (MRI, 1982).  The analytical data from
the MRI (1982) report were presented in terms of the percent  asbestos in raw, beneficiated,  or
exfoliated vermiculite ore. No data were provided on the asbestos content of vermiculite-containing
consumer products.  A summary of the analytical results from the MRI (1982) study is provided in
Table 1.  Raw ore from the Libby, Montana, mine had estimated asbestos contents ranging from 21
to 26 percent, while ore  from their  Enoree, South Carolina,  mine had <1  percent  asbestos.
Beneficiated Grade Vermiculite ranged from 0.3  to 7  percent at the Libby site and was <1 percent
at the Enoree site.  Exfoliated vermiculite was evaluated from the Enoree site, but not the Libby site.
The asbestos content was <1 percent.  The W.R. Grace Company also analyzed bulk samples of
vermiculite from their mine in South Carolina (IOM, no date). Their procedure involved extracting
vermiculite, chlorite, chrysotile, and other minerals, leaving only amphibole fibers  and examining
samples by scanning electron microscope (SEM) and x-ray diffraction. The results indicated that the
bulk material contained actinolite at low levels (i.e., approximately 0.002%). Similar analyses were
conducted using two expanded vermiculite samples from South Carolina (IOM, 1993).  Only trace
amounts of asbestos fibers were observed in these  samples. In 1990, the Libby mine was closed.
Presumably, vermiculite in currently produced consumer product lines originates from the  South
Carolina or Virginia mines, or mines  located outside the United States.  Inhalation exposure to
consumer products was assessed in the Versar (1985) report using data on the percent asbestos in
exfoliated vermiculite, and assumptions regarding the  amount of vermiculite in consumer  products,
the quantity of dust generated during consumer use, and the volume of air affected, as well as other
assumed exposure factors.

       As a result of reports on residual  contamination and the  potential for human exposures in
Libby, Montana from the now-closed vermiculite mine, and questions posed to EPA about consumer
products that contain vermiculite, there was renewed  interest in evaluating the potential consumer
exposures to asbestos from the use  of  vermiculite-containing  consumer products.  Consumer
exposure to asbestos-contaminated vermiculite can occur during handling of consumer products
containing vermiculite such as, lawn and garden care products, fertilizers, packaging materials, and
loose-fill attic insulation.  EPA Region 10 initiated a study of consumer products containing
vermiculite. Subsequently, EPA, Office  of Pollution Prevention and Toxics (OPPT),  National
Program Chemicals Division (NPCD), requested that Versar conduct sampling and analysis  of
vermiculite-containing consumer products as an expansion and followup to the Region 10 study. This
report briefly describes the results of consumer product survey conducted by EPA Region 10 as well

-------
as a related survey of commercially available building products that was conducted by Region 6 (EPA
Region 6, 2000). It also summarizes the methods used and results of the asbestos analyses from the
recently-conducted EPA/OPPT/NPCD-Versar study of consumer products.

1.1     Results of Previously Conducted EPA Regional Analyses of Consumer Products for
       Asbestos Content

       EPA Region 10 analyzed consumer products containing vermiculite.  These products were
intended for horticultural use (e.g., potting soil, horticultural vermiculite) or laboratory packing (e.g.,
Zonolite*1 chemical packaging).  Initially,  16 bulk  products were  analyzed by polarized light
microscopy  (PLM) (Method EPA/600/R-93/116) and transmission  electron microscopy (TEM)
(Method EPA/600/R-93/116).  The PLM results were either non-detect or trace for all products.
Two products were positive for asbestos, based on the TEM results.  These products were: Zonolite®
Vermiculite (0.56% actinolite and 0.47% actinolite) and Coles Cactus Mix (0.45% actinolite). Based
on these results, Zonolite* was further analyzed by TEM after sieving the sample using No. 10 and
No. 35 screens. The results of this sample indicated 1.88% actinolite/tremolite in the dust portion
that passed through the sieves.  Further analysis by TEM gave results of 0.1% and 2.79%  in the
fraction of material analyzed. This analysis procedure involved a rinsing residue particle separation
technique to further improve the ability to isolate and identify asbestos in the vermiculite containing
products. The residue materials were placed in a beaker and rinsed with deionized water which was
intended to wash any loose fibers from the vermiculite matrix.  After the vermiculite had floated to
the surface, 7 ml of water was extracted from the bottom of the beaker using a syringe and was then
injected into a crucible. The crucible was covered and placed in a drying oven a 68° centigrade for
two or three days until all the water had evaporated. The remaining residue located in the bottom of
the crucible was removed and placed onto a microscope slide following the EPA semi-quantitative
method: EPA/600/R-93/116. A second Zonolite* product (Chubby and Tubby) was analyzed, but
no asbestos was detected. These results are shown in Table 2.

       Region 10 also conducted air monitoring during use of these products using a "glove-box"
technique.  Three separate scenarios were used during the glove box study. The first scenario
involved the potting of plants which involved emptying a container of vermiculite containing soil into
a plastic tub and  then manipulating the  soil to break up clumps. The second scenario involved
preparing potting  soil by mixing 50% vermiculite and 50% peat moss in a container, while the third
scenario involved using pure vermiculite such as that used for laboratory packing purposes. Jars were
placed into a pan and then covered with vermiculite. The three glove box sampling studies took place
over a period of either 15, 20, or 30 minutes. However, one of the manipulation of soil  studies was
run for 100 minutes. For Coles Cactus Mix, no asbestos was detected at a flow rate of 2.8 L/minute

-------
for 30 minutes (NIOSH 7402) or 11.1 L/minute for 100 minutes (Modified EPA-II). Using Zonolite®
Chemical Packaging Material mixed 50/50 with Sun/Gro Peat Moss, the total amount of asbestos
detected ranged from 0.08 to 0.38 structures/cm3 at an air flow rate of 2.8 L/m for 30 minutes and
0.56 to 0.85 structures/cm3 at an air flow rate of 1 l.lL/minute for 100 minutes, using the modified
EPA (1984) (EPA-II Method). When Zonolite® Chemical Packaging Material was tested unmixed,
the total asbestos detected was 6.96 to 8.17 structures/cm3 at an air flow rate of 2.9 L/minute for 30
minutes, using the NIOSH  7402 Method.  TEM analysis was used to estimate fiber content in all
samples (either NIOSH 7402 or Modified EPA-II Method). Use of two TEM methods was necessary
because some  samples could not be tested using the NIOSH 7402 Method due to the excessive
amount of paniculate accumulated on the filter.  The filters required a redeposit process which is not
covered in the NIOSH 7402 Method, but could be performed using the Modified EPA-II Method.

1.2    Other EPA Asbestos Surveys

       In addition to the ongoing work in Libby, Montana, EPA's Superfund program is currently
evaluating possible asbestos contamination at other current and former  vermiculite  mines  and
processing  sites across the country.  EPA's  Boston office is  developing  an improved sample
preparation technique for vermiculite products and exploring options for gathering information on
vermiculite home insulation. Finally, EPA's Dallas office recently concluded the sampling of a limited
number of building construction materials, not including vermiculite products, for asbestos content.
The purpose of this survey was to determine whether these building materials contained more than
one percent asbestos, the threshold  for regulation  under the Asbestos-in-Schools program.  The
results of the  sampling indicated that  none of the 50 products contained  more than one percent
asbestos.

2.0    METHODS USED FOR THE EPA/OPPT/NPCD CONSUMER PRODUCT STUDY

2.1    Consumer Product Collection

       During the initial phase of the EPA/OPPT/NPCD-Versar study, a total of 33 vermiculite and
vermiculite-based  consumer products  were purchased from retail  stores (i.e., hardware  and
department stores) in 9 metropolitan locations throughout the United States by personnel in Versar' s
regional offices.  In addition, vermiculite packaging material was purchased from a  mail order
company in Atlanta, Georgia . This material is typically used in packing laboratory materials. A bag
of Zonolite® Chemical Packaging Vermiculite was also purchased by mail order (Figure  1). This
material was purchased from Burdic Feed,  located in Kent, Washington, where it was being sold for
horticultural purposes. This is the same product that was found to be positive for asbestos content

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by EPA Region 10 (2000). As a result of the initial collection efforts, 35 products were collected.
Following the initial sampling and analysis, additional samples were received and added to the study.
One additional product was  purchased from a retail store in the Springfield, Virginia, area (i.e.,
metropolitan Washington, D.C., area). An additional sample of vermiculite packaging material was
also collected by EPA/OPPT/NPCD personnel during an unrelated sampling event, and provided to
Versar for analysis. This material came from a laboratory packaging company in Batavia, Illinois
(VWR).  It should be noted that VWR is a user, and not a distributor of laboratory packaging
material. The original source of the material is not known. In addition, Region 10 supplied a small
sample of material from a bag of Zonolite* Chemical Packaging Vermiculite that they had purchased
from Burdic Feed in Kent, Washington. This material had been found to be positive for asbestos by
EPA Region 10.  A total of 38 materials were collected overall.

       An attempt was made to ensure that the products purchased in the various locations would
represent a broad range of product types and brands, with emphasis on locally packaged products to
ensure that a wide variety of materials would be sampled.  It should be noted, however, that a
statistically-based sampling approach was not used. Thus, the products purchased may  not be a
nationally representative sample. A list of the products purchased in each of the various locations is
provided in Table 3.

       As indicated in Table 3, the products were composed of either vermiculite only, or a mixture
of vermiculite, and organic, inorganic and other materials (i.e., soil-based vermiculite products such
as potting soil and horticultural mixes).  Other types of vermiculite-containing products, such as
loose-fill attic insulation, were desired for this study, but are apparently not readily available to
consumers and could not be located. Also, as shown in Table 3,  some of the same products were
purchased in more than one location. This was  done to evaluate similarities or differences in the
asbestos content of these products, based on the  region where they were purchased. The  products
in Table 3 were mailed  to Versar Headquarters in Springfield, Virginia, by the regional offices.

2.2    Bulk Product Sampling

       Samples of the various products collected were taken in Springfield, Virginia, and sent to the
EMSL Analytical Laboratories in Westmont, New Jersey.  Although only a small sample (i.e.,
approximately 8 ounces) of the materials was required by the laboratory, most of these products were
purchased in bags containing greater than 4 quarts.  A sample of each product was collected using
a clean stainless steel scoop. To ensure that samples were representative of the entire bag of material,
composite samples of each product were collected by mixing equal portions of product from the top,
middle, and bottom of the bag, for a total sample of approximately 8 ounces. Two sampling methods

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were used for the Zonolite* purchased by mail order from a feed store in Kent, Washington. This
material is the same as the bulk material that was found to be positive for asbestos by researchers in
EPA Region 10 (2000).  First, a composite sample was collected, as described above.  A second
sample was collected from the bottom of the bag to determine whether the asbestos content would
be higher in the bottom of the bag as a result of gravitational settling. This procedure was also used
to sample the bottom of the  bag of Hoffman's vermiculite from  Minnesota during the second
sampling round. Clean, stainless steel scoops were used to place the samples into sterile jars which
were sealed, labeled, and sent to the EMSL Analytical Laboratories for asbestos analysis. As a result
of the initial collection effort, a total of 36 samples were prepared for laboratory analysis.

       In a subsequent round of sampling, an additional 14 samples were collected to increase the
number of samples analyzed by PLM and TEM to 50. Additional samples were comprised of repeat
composite sampling of the 5 samples with quantifiable asbestos; repeat random composite sampling
of 5 more of the original samples (i.e., some non-detect and some with detections below the limits
of quantification); 1 Zonolite* sample collected by EPA Region 10 and sent to Versar (this sample
came  from the bottom  1/3 of a bag of Zonolite*, also purchased from Burdic Feed in  Kent,
Washington); 1 sample  of the vermiculite packaging material from VWR, a  laboratory  supply
company in Batavia, Illinois, that was collected by EPA Headquarters personnel during an unrelated
sampling event; a sample from the gardening consumer product (Pursell's Stay-Green Vermiculite)
that was purchased after the initial product collection round; and a sample from the bottom of the bag
of the product (Hoffman's vermiculite from MN) found in the initial analysis to have the highest
asbestos content.

2.3    Laboratory Analyses of Bulk Samples

       The initial laboratory  analysis of the bulk  products for  asbestos was conducted using 2
techniques: PLM (EPA 600/R-93-116) and TEM (EPA 600/R-93/116) (Figures 2 and 3).  According
to EMSL (Frasca, 2000), the following procedure was followed by EMSL for these analyses:

       For PLM analysis, samples were  first ground to a level where the vermiculite plates
       were barely visible. Point count PLM analysis was performed on eight (8) slides
       running 50 points on each slide.  For TEM analysis, the sample was ground further
       until the vermiculite plates were no longer visible by the eye. The potting soil samples
       were ashed (due to their high organic content) prior to grinding, recording their
       weight before ashing. Subsequently, 0.01 grams of powder was added to 100 mL of
       water, sonicated, and an aliquot of 5 mL was filtered onto a 47 mm filter which was
       then prepared for TEM analysis. For each sample, three areas were sampled and
       analyzed from the filter (i.e., the center, the edge, and in between). This was done to
       counter any variation in radial distribution of particulates.  The TEM analysis was

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       performed by observing 10 grid openings for each of the three TEM grids at 2,OOOX
       magnification as well as 3 grid openings for each of the three TEM grids at 20,OOOX
       magnification. Cut offs of fibers sizes were observed to avoid counting twice. The
       mass of the observed fibers was then calculated, and following its extrapolation to the
       whole filter and to the whole mass of 0.01 grams, the asbestos percent count was
       determined.
The quantitation limits were 0.25 percent for PLM and 0.1 percent for TEM.  PLM and TEM
analyses were also conducted for the three new products collected during the second sampling round
and for the repeat samples (i.e., 5 products with quantifiable asbestos, 5 other randomly selected
products from the initial sampling round, and an additional sample from the bottom of the bag of the
product with the highest asbestos content, based on the initial analysis).

       Based on the results of the initial bulk analyses, several (i.e., five) samples that were positive
for asbestos content using the initial TEM approach, were further analyzed using two additional
techniques: the SOP 2000 (EMSL, 1999) and the Superfund Method (EPA,  1997a). The SOP 2000
method was expected to provide a more refined estimate of the asbestos content of these materials.
This method involved sample preparation (i.e., grinding and sieving the sample to obtain a distribution
of particle sizes); screening with a scanning electron microscope (SEM) to ensure that asbestos fibers
had been removed from the  vermiculite plates; and analysis by both PLM at lOOx magnification
(recording fibers with a 3:1 aspect ratio and determining if they are asbestiform using the criteria
given in Appendix A  of EPA 600/R-93/116) and TEM at 10,000x magnification. The asbestos
percent obtained by PLM and TEM  were  added to obtain total asbestos content.

       The Superfund method (EPA, 1997a) was designed to determine the amount of releasable
asbestos in soils and bulk materials. It uses a horizontal tumbler to generate dust and a vertical
elutriator (Figure 4) to separate the respirable fraction of the dust. The respirable fraction of dust is
collected on filters. The filters are weighed and the mass of dust collected is plotted against time to
determine the rate of dust release (EPA, 1997a).  The asbestos content of the dust on the filters is
quantified by TEM.  The advantage of this method is that it provides results that are suitable for
supporting risk assessments.

2.4    Consumer Use Simulation

       Because the results of bulk product analyses are difficult to use in assessing inhalation risks
to individuals who use these products, air sampling techniques were needed to evaluate potential
releases of asbestos from these products to air. Risk is typically estimated as the concentration of

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fibers per cubic centimeter of air (f/cc), weighted according to the frequency and duration of
exposure, times the  unit risk factor (cc/f)  for asbestos.  According to EPA's Integrated Risk
Information System (IRIS) (EPA, 2000), "the unit risk factor [of 0.23] cc/f is based on fiber counts
made by phase contrast microscopy (PCM) and should not be applied directly to measurements made
by other techniques."  However, PCM cannot distinguish between asbestos and non-asbestos fibers;
it also cannot detect smaller or thinner fibers at all. According to EPA (2000), ?PCM detects only
fibers longer than 5 (j.m and >0.4 (j.m in diameter." TEM can identify asbestos fibers of all sizes and
exclude non-asbestos  fibers. Thus, for the purposes of estimating risk for this study, air samples were
analyzed by both PCM and TEM.  TEM results were reported for all fiber sizes and for fibers > 5/^m
only.

       To simulate indoor product use and measure indoor air asbestos concentrations, a 10'xlO'xlO'
containment was constructed within Versar's research and storage space (Figures  5 and 6).  This
facility is located less than a mile from Versar's headquarters  building.  The dimensions of the
containment were selected to provide enough space for an individual to work inside the structure and
simulate  mixing soils, potting plants, or cleaning out containers of soil. The dimensions were also
assumed to represent a homeowner's garage or small greenhouse.  This containment unit was
specially-designed to  more closely resemble consumer exposure conditions than the glove box used
in the Region 10 study. The containment was constructed from 6-mil polyethylene plastic with the
frame work constructed from wood to provide a rigid structure.  Duct tape was used to seal seams
and no artificial ventilation was provided.  This was assumed to represent conditions in a closed
garage or greenhouse with no windows and a  closed door.  The unit was constructed on a flat
concrete surface. The floor was covered with plastic as it is part of the containment.

       Several products were used within the containment to simulate consumer product use. During
the product simulation,  an individual inside the containment opened a bag of vermiculite containing
material, which was then placed on a rolling cart. On the cart the vermiculite was scooped from the
bag and placed in a stainless steel bowl. The vermiculite was then manipulated by using a metal
spoon to transfer the vermiculite to a second bowl. After this process, the material was discarded and
new material was scooped from the bag. Initially, three products were tested. These were:  Schultz
Horticultural vermiculite, purchased in VA; Hoffman's vermiculite, purchased in MN; and Zonolite®
Chemical Packaging Vermiculite,  purchased by mail order from Burdic Feed in Kent, WA.  The first
two of these products were selected because quantifiable levels of asbestos were observed in them
in previous tests.  The  Zonolite* was selected because another bag of the same material had been
found to have quantifiable levels of asbestos by Region 10,  based on bulk analyses of the whole
product as well as the sieved product. Also, the physical characteristics of these products made them
good candidates for this procedure because, based on qualitative observations, they represented a

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wide range of "dustiness." The Schultz vermiculite had a moisture content that allowed clumping
when hand pressure was applied.  This texture was not representative of most of the products
collected and it is not clear whether the moisture observed in this bag was typical of this product or
whether the bag had absorbed moisture between the time it was packaged and the time it was
sampled. The Hoffman's vermiculite was drier and dustier, but the Zonolite* had an even finer grain
size with a much dustier appearance.  The order at which the three products were tested in the
containment was based on their observed "dustiness" with the least "dustiest" being tested first.

       During a  second set  of simulations, four  additional  products were tested inside the
containment; two had asbestos contents below the limit of quantification, and two were non-detect
based on TEM bulk analyses.  These products were: Jungle Growth Vermiculite, purchased in FL
Country Cottage Horticultural Vermiculite, purchased in VA; Scott's Vermiculite, purchased in TX;
and Kellogg's Vermiculite, purchased in CA. Three of the products were very "dusty," while the
fourth (Kellogg's) was less "dusty." All seven of the products used in the simulation exercise were
vermiculite and not vermiculite mixed with potting soil or some  other ingredient. The containment
was fully cleaned between each sampling event by wet wiping down all interior surfaces and allowing
the air in the containment to be "changed out"  through a Hepa Filtration device.  The individual
within the containment opened a bag of vermiculite and poured it into a second clean container.
Simulated scooping, transferring, and mixing then took place similar to the first simulation event. An
aliquot from the bag was previously collected; however, care was exercised to avoid unnecessary
waste of the original material since future studies or sampling may be necessary or requested.  All
utensils, scoops, and containers were either cleaned prior to use or removed from their factory sealed
packaging. Similar use of vermiculite that took place inside containment will take place in an open
air environment much like that in the yard or on a deck.

       The individual performing work inside the containment wore personal protective equipment
(PPE), as necessary to protect from dusty environments (Figure 7).  A Tyvek full body suit or
equivalent was worn during all inside containment work.  Respiratory protection consisted of a full
face air purifying respirator (APR) equipped with HEPA/P-100 air filters.  PVC gloves were also
worn on the hands. During the work tasks the oxygen level inside the containment was monitored
with the use of a four gas meter. A second person was situated  outside the containment in case of
emergency and to offer support during sampling activity. After the completion of sampling, the inside
of the containment was  wiped down with water, the containment was vacuumed to capture any
residual fibers remaining in the air, and the individual inside followed a modified decontamination
procedure similar to that followed on asbestos abatement projects.

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       Eight air samples were collected using both low volume and high volume pumps. Before and
after each use, each of these pumps were calibrated using a Bios Dry-Cal unit. This device is highly
accurate and served to document any pump fluctuation. Prior to sampling during vermiculite use, the
study area was sampled to document fiber levels. This "pre-sampling" established what, if any, fibers
were present within the ambient air, and if necessary may be used as a comparison measure of the
inside containment sample results. Two of these samples were run using the high volume type air
sample pump.   Air flow was set at approximately 9-9.9 liters of air per minute.  Two inside
containment air sample pumps (Figure 8) were also hi-volume units which were run at 7-8 liters of
air per minute, while a second set of hi-volume sample pumps was located outside the containment.
While working inside the containment, the individual wore two low volume air sample pumps which
were set at approximately 2.1 of air liters per minute and ran for 30 minutes. The cassettes were
oriented to be located within the breathing zone. All high volume air samples ran for approximately
40 minutes.

       Air samples were collected in an outside environment in much the same manner as that inside
the containment (Figure 9). The products with the highest airborne levels from the containment study
were used in the outdoor study. Three high volume pumps were placed downwind from the source
of use. Additionally, two personal samples were collected on the individual performing the work.

       All air samples were analyzed by both PCM and TEM. The N1OSH 7400 (NIOSH, 1994),
and EPA Level II (EPA, 1984) methods were used. The NIOSH 7400 method is a direct preparation
method in which fibers >5 /^m in length with an aspect ratio >3:1 are counted (counting rules A were
used) by PCM. All TEM air samples were prepared using EPA Level n, a direct preparation method,
with  the exception of those samples that were overloaded with particulate matter (i.e., dust).  For
these, an indirect sample preparation method was used to obtain some form of data for these samples
(otherwise, the results would simply have been reported as overloaded), with the understanding that
the samples may not fit the model (e.g., detection limits are higher).  The appropriate number of
blanks were also submitted, as outlined in the guidance documents for each of these methods.

2.5    Region 10 Bulk Product Method Using Sieving

       An additional set of analyses was conducted to examine the asbestos content in the dust
fraction of selected products and to evaluate potential relationships between the fiber content of air
during use of consumer products containing vermiculite and the asbestos fiber content of the fine
particles in these vermiculite products. This analysis was also an attempt to verify the results of EPA
Region 10's results for Zonolite® that was purchased in Kent, Washington.  Region 10 found that the
asbestos content of Zonolite® dust that was generated by sieving the original product through

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standard sieve sizes No. 10 and No. 35 had higher asbestos content (i.e., 1.88%) than the bulk
product (i.e., approximately 0.5%).

       The three initial products used in the indoor containment exercise, including the Zonolite®
purchased by Versar from Burdic Feed in Kent, Washington, Schultz Vermiculite from Virginia, and
Hoffman's Vermiculite from Minnesota, were sieved using the same method as Region 10 (Figure
10).  These three samples were composite samples (i.e., based on a mix of samples taken from the
top, middle, and bottom of the bag).  An additional sample from the bottom of the Zonolite® bag was
also analyzed to be consistent with the Region 10 analysis. This sample came from the bottom of the
bag after the bag was moderately shaken 20 to 30 times.  According to EMSL (2000), the following
procedure was used:

       "Sieve vermiculite sample through No. 10 (2 mm) and No. 35 (500 /^m) sieves.  The
       coarse, medium, and fine portions were analyzed by Polarized Light Microscopy
       (PLM). The fine portion was still too coarse for Transmission Electron Microscopy
       (TEM) analysis and had to be broken down further with mortar and pestle. Of this
       fine powder, 0.01 grams was suspended in  100 mL of particle free,  distilled neutral
       (pH 7) water, sonicated and 5 mL was filtered through a 47 mm diameter, mixed
       cellulose ester (MCE) filter with a 0.45 pm pore size. A small portion of the filter
       was then collapsed with acetone, etched, and analyzed by TEM."

The rationale for conducting this analysis was that if asbestos fibers are more likely to be found in the
fine dust of the vermiculite product, the asbestos fibers would be concentrated in the dust that passes
through the sieves.  Analyzing only the dust fraction would, in effect, increase the possibility of
detecting asbestos by PLM and TEM. If the percent asbestos could be quantified in the fine fraction
as well as in the medium and coarse fractions, a refined estimate of the asbestos content (i.e., greater
sensitivity with lower detection limits) of the whole product could be made.

3.0    RESULTS

3.1    Bulk PLM and TEM Analyses

       Table 4 provides the results of the analyses by  sample  number and location of purchase.
Appendix A provides copies of the Laboratory Reports. The results of the laboratory analysis of the
initial 36 samples indicated that TEM was more sensitive than PLM in detecting asbestos in the
products tested.  Based on PLM analyses, none of the products tested had detectable levels of
asbestos. Using TEM, however, 17 of the 36 samples had detectable asbestos. Of these 17 samples
with detectable asbestos, only  5 had quantifiable levels (i.e.,  greater than 0.1 percent by weight) of
                                           10

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asbestos. The percent of asbestos by weight ranged from 0.13 percent to 0.70 percent for these 5
samples. All of these 5 materials were pure vermiculite products, and not soil-based vermiculite
products. Also, the fiber type observed in these 5 samples was actinolite.  The fiber types observed
in all of the other positive samples were actinolite and chrysotile. It is interesting to note that two
of the  samples with quantifiable levels of asbestos are from the same product type (i.e.,  Ace
Horticultural Grade Vermiculite), purchased in different locations (i.e., Miami, FL, and Minneapolis,
MN).  These samples had levels of 0.35 percent (FL), and 0.24 percent (MN).  Also, three of the
samples with quantifiable levels of asbestos (i.e., Hoffman's Vermiculite, Ace Horticultural Grade
Vermiculite, and Earthgro's Best Vermiculite) are from products purchased in Minneapolis, MN.
The other two products purchased in the Minneapolis area had non-detectable levels of asbestos.
Another interesting observation is that asbestos fibers were observed (but not quantifiable) in the
sample of Zonolite® Chemical Packaging Vermiculite that was collected from the bottom of the bag,
but not in the composite sample.  This may indicate that asbestos fibers may settle to the bottom of
containers in which they are stored. To further investigate this phenomena, a sample was collected
from the bottom of the bag of the product with the highest observed asbestos content (i.e., Hoffman's
vermiculite from MN) and analyzed for asbestos. However, asbestos was not observed above the
quantitation limit in this sample, using both PLM and TEM techniques.  Tremolite was observed
using PLM and actinolite was observed using TEM. Figure 11 shows an asbestos fiber as seen by
TEM.  Figure 12 shows a close-up view of an actinolite asbestos fiber provided by EMSL.

       Resampling of the five positive  samples was conducted. Laboratory PLM analyses of these
samples indicated that non-quantifiable tremolite was observed in the two samples that had the
highest asbestos (actinolite) in the original TEM analysis (non-detected in original PLM analysis).
The other three samples were negative for asbestos in the repeat PLM analysis, just as they were in
the initial PLM analyses. Analyses of the other five repeat samples indicated four non-detects and
one detect (<1% chrystotile and <1% tremolite) by PLM. These samples were all non-detect in the
initial PLM analysis, but four out of five were positive (below the limit of quantitation) by TEM.  The
results of the TEM analyses for the resampling of the five positive samples was as follows: one
sample (Earthgro' s Best Vermiculite from MN) had quantifiable asbestos at 0.17%. The TEM result
for this product was 0.41%  in the initial  analysis.  Three of the five products  with  quantifiable
asbestos in the initial analysis were positive in the repeat sampling, but had concentrations below the
quantification limit. One of the initially positive products was negative when resampled.  Some of
this variability in results may be the result of the non-uniformity within vermiculite products.

       The results of the other three products (VWR laboratory packaging material, Zonolite® from
Region 10, and Pursell's Sta-Green, purchased in VA) collected during the second sampling phase
showed detectable levels of tremolite in all products using PLM. Quantifiable asbestos levels were

                                            11

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observed in two of these: VWR laboratory packaging material (0.6%) and Zonolite" Chemical
Packaging Vermiculite from Region 10 (0.3%).  Using TEM, actinolite (and not tremolite) was
observed in the VWR laboratory packaging material (0.14%) and Zonolite® from Region 10 (below
the quantitation limit).

3.2    SOP 2000

       The five positive samples from the initial bulk sample TEM analyses were analyzed by the
SOP 2000 method.  No detectable asbestos fibers were observed by PLM for any of the samples, and
only one sample (Ace Horticultural Grade Vermiculite from MN; 0.24% actinolite by the initial TEM
bulk analysi s) had detectable actinolite/tremolite below the quantitation limit, based on TEM analyses.

3.3    Superfund Method

       The five positive samples from the initial bulk sample TEM analyses were also analyzed by
the Superfund  Method (EPA, 1997a). The results of these analyses are presented in Table 5. The
table presents the quantity (g) of respirable dust generated per gram of bulk sample, as well as the
total number of asbestos structures observed per gram of respirable dust. The number of asbestos
structures per  gram of sample (s/g sample) was calculated  by multiplying the  respirable dust
concentration (g dust/g sample) by the number of asbestos structures per gram of dust (s/g dust).
These values are also reported in  Table 5.  It should be noted that mean concentrations and 95
percent upper confidence limits (UCL) of the mean concentrations were provided by the laboratory.
The 95 percent UCL values represent a conservative estimate of the asbestos content of the samples.

       The results in Table 5 indicate that, of the five samples that had a quantifiable asbestos content
in the initial bulk analyses, only one sample (Schultz Horticultural Vermiculite from Springfield, VA)
had quantifiable asbestos structures using the Superfund Method.  This sample had 0.13% actinolite,
based on the initial  bulk TEM analysis, but was non-detect by TEM on resampling.  This variability
in results could be due to variability in the sample, as well as the analytical technique.

3.4    Consumer  Use Simulation

       The results  of the air sampling inside the containment are presented in  Table 6.  Outdoor
results are presented in Table 7. As shown in Table 6, asbestos fibers were not detected in indoor
air (i.e., both  area monitors and personal  monitors) or outside the containment  for 5 of the  7
products, using TEM  techniques.  These include: Schultz Horticultural Vermiculite purchased in
Virginia, Jungle Growth Vermiculite from Florida; Country Cottage Vermiculite  from Virginia;

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Scott's Vermiculite from Texas; and Kellogg's Vermiculite from California.  The Schultz sample was
the least "dusty" of the products that were tested inside the containment. No asbestos was observed
in indoor air during the simulation using this product although the results of the bulk product analyses
for this material using TEM were 0.13% asbestos on initial testing and non-detect on repeat analyses.
The Jungle Growth and Kellogg's were both non-detect by both PLM and TEM in the initial bulk
analyses. The Country Cottage and Scott's products had non-quantifiable asbestos in the initial bulk
TEM analyses.  The 2 products with quantifiable asbestos in indoor air were Hoffman's Vermiculite
from Minnesota and Zonolite® from Washington.  The Hoffman's vermiculite was "dustier" than the
Schultz vermiculite, but less dusty than the Zonolite*, Jungle Growth, Country Cottage, and Scott's
Vermiculite. The inside air area monitor results for the Hoffman's vermiculite were non-detect using
TEM, and ranged from 0.027 to 0.047 f/cc using PCM. PCM and TEM did not detect any fibers in
outside monitors. Personal samples during indoor use of Hoffman's vermiculite contained 0.122 to
0.371 f/cc based on PCM, and were non-detect to 0.0935  s/cc (tremolite fibers >5 /^m in length)
based on TEM.  This product had results of 0.7% and BQL asbestos in the bulk TEM analyses. Use
of the "dustier" Zonolite* product, resulted in detectable fiber levels in air both outside (0.011 - 0.012
f/cc) and inside (non-detect to 0.108 f/cc) the containment, and in personal monitors (0.344 -  0.482
f/cc) using PCM. Using TEM, the results were non-detect for outside area monitors, non-detect to
0.0769 s/cc actinolite >5 /^m in length in indoor area monitors, and 0.4171 to 0.6594 s/cc actinolite
>5 /jm in length in the personal samples. It should be noted that the Jungle Growth, Country
Cottage, and Scott's Products were so "dusty" that the filters in the personal air monitors became
overloaded during the 30-minute simulation, and could not be read by PCM.  However, for TEM
analyses, and indirect preparation method was used in which the filters were ashed and resuspended
in water.  A fraction of the resuspended  sample was then filtered and read by TEM.  Asbestos
structures were not detected in these samples.  However, the detection limits for these samples were
high as a result of the required dilution.

       Because use of Zonolite® resulted in the highest indoor air fiber concentrations of the three
products evaluated, it was  used to evaluate  fiber concentrations to which consumers could be
exposed during outdoor use.  The results of this simulation are shown in Table 7. Structures were
not detected by TEM, but fibers were observed in both perimeter (0.011 to 0.013 f/cc) and personal
(0.134 f/cc) monitors using PCM.

       The variability in the PCM and TEM air samples may be due to several factors. PCM counts
all visible fibers as asbestos, while TEM distinguishes between asbestos and non-asbestos. TEM is
more sensitive than PCM since TEM uses higher magnifications.  Some of the TEM samples used
an indirect preparation method which can lead to higher numbers of fibers counted due to  separation
of individual fibers from more complex structures.

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       All QA/QC samples collected inside and outside prior to product use, as well as field blanks,
were negative for asbestos content.

       It should be noted that the air concentrations (i.e., 0.094 to 0.66 f/cc) observed in the product
use simulation (for those products with detectable levels of asbestos in air) are  similar to those
estimated in the 1985 Exposure Assessment for Vermiculite (Versar, 1985) (i.e., 0.038 to 0.93 f/cc),
which used bulk sample results and simple assumptions to estimate the asbestos concentration in air.
For example, the assumptions for use of lawn fertilizers containing vermiculite in the Versar (1985)
report were as follows:

       •   0.0643 percent of garden fertilizer dispersed into the air during application;
       •   15 percent of garden fertilizers was exfoliated vermiculite;
       •   Exfoliated vermiculite contained 1 percent of asbestos fibers;
       •   Label application rate was 7,600 g per 465 m2;
       •   The average lawn size of 1,010 m2 was assumed;
       •   The mid-point of product use would occur at 2 hours for a 4-hour application; and
       •   Fibers released would remain airborne during application and be evenly  distributed in an
           air volume of 1,010 m2 x 1.8 m or 1,818 m3.

The exposure concentration at the mid-point of application was estimated as follows:


                           —	 * 1,010m2 * 0.15 * 0.01 * 0.000643 * 106mg / g * 2 hours
TWA Exposure Concentration =  	= 4.4 mg / m"
                                             1,818m3 * 4 hours
The correlation between PCM fiber counts and TEM mass measurements is very poor. Six data sets,
which include both PCM and TEM measurements reported in EPA (2000), show a conversion factor
between TEM mass and PCM fibers count that ranges from 5 to 150 (^g/m3)/(f/cc).  The geometric
mean of these results is 30 (//g/m3)/(f/cc).  Using this conversion factor of 30 (//g/m3)/(f/cc), as
specified in EPA (2000), this value is equivalent to 0.15 f/cc, and is within the range observed in this
study.
                                            14

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3.5    Region 10 Bulk Product Method Using Sieving

       The three products that were used in the initial indoor air consumer use simulation (i.e.,
Hoffman's, Schultz's, and Zonolite®) were also evaluated using the Region 10 bulk product method
in which samples were sieved before conducting PLM and TEM.  Asbestos was not detected in the
fine fraction using both PLM and TEM analyses on whole samples of these products.  The sample
from the bottom of the bag of Zonolite® indicated only trace asbestos content of the product.  Using
PLM, tremolite  was observed  in  the fine fraction  that passed through the sieves below the
quantification limit of 1%. The asbestos content of the original sample, collected from the bottom
of the bag, would be <0.19% tremolite, based on this result combined with PLM results for the
medium and coarse fractions that showed non-detectable asbestos.  Based on TEM, of the fine
fraction that passed through the sieves, the  asbestos (actinolite/tremolite)  content was below the
quantification limit of 0.1%. Using the  PLM non-detect results for the medium and coarse fractions,
the asbestos content of the  original sample  from the bottom of the  bag would equate to <0.02%
tremolite/actinolite.

4.0    DISCUSSION

       The results of these analyses indicate that some of the consumer products tested contain small
amounts of asbestos. As a result, there may be the potential for exposure during consumer product
use.  Of particular concern  is the variability in the bulk sample results.  As noted in  Table 4, the
sample results varied between analytical methods and repeat samples. It is not surprising that samples
found to contain  asbestos using TEM were non-detect based on PLM because PLM is known to be
less sensitive for this type of study.  Inconsistencies between the original TEM analysis and repeat
TEM analysis are likely as  a result of several factors.  First, the asbestos content of the products
appears to be very close to the detection limit for TEM; thus,  even the slightest variability results in
some analyses being reported as non-detect or below the quantification limit, while others are slightly
above the quantification limit. Also, because only a very small portion of each sample is viewed under
the microscope (i.e., 0.01 g), it may be possible to miss asbestos fibers in a product with very low
(i.e., <1%) asbestos content. Further  variability may occur as a result of the non-homogeneous
nature of the product within the bag, bag to bag variability, and differences between the various
exfoliating plants and mines that produce vermiculite.  In  addition, it has been suggested that
significant variability in asbestos content can also occur within the same vermiculite mine. Finally,
based on the results of the consumer simulation, it appears that the relationship between bulk sample
results (i.e., percent asbestos) and indoor air concentrations  during use, is  not easily quantifiable.
This variability may be based on the product characteristics (i.e., moisture content, particle size, or
                                            15

-------
other factors) or use conditions. Section 5.0 discusses potential risks from exposure to consumer
products containing vermiculite based on the results of this study.

5.0    RISK ANALYSIS

       The cancer risks from asbestos exposure that are associated with use of vermiculite may be
estimated using the personal monitoring results from the product use simulation, either inside the
containment or outside, as follows:

                     .   _   EC x ET / 24 hrs / day x EF x ED
                                    LT x 365 days/ yr
where:
       EC     =      exposure concentration (f/cc);
       ET     =      exposure time (hrs/day);
       EF     =      exposure frequency (days/yr);
       ED     =      exposure duration (years);
       LT     =      lifetime (years); and
       URF   =      unit risk factor (0.23 cc/f).

For the purposes of assessing risks to consumers, a range of exposure conditions were assumed.
First, the same exposure assumptions as those used in the 1985 Exposure Assessment for Vermiculite
(Versar, 1985) were used here (i.e., ET = 4 hours/day; EF = 1 day/year).  ED was assumed to be 30
years and LT was assumed to be 75 years (EPA, 1997b). Consumer risks were also calculated using
a lower exposure time (i.e., one-half hour per day) and exposure duration (i.e., 10 years) to represent
a less conservative scenario, and at a higher exposure frequency (i.e., 6 times per year) to represent
more conservative scenarios.  The estimated consumer risks based on the fiber concentrations in
personal monitors are  presented in Table 8 for all products used in the simulations (products with
non-detectable asbestos, were  assessed at the detection level). The unit risk factor used in the
calculations is from EPA's IRIS (EPA, 2000). It should be noted, however, that according to IRIS,
this "unit risk factor should not be used if the air concentration exceeds 4E-2 fibers/mL [0.04 f/cc]
since above this concentration the slope factor may differ from that stated."  However, because this
is the only unit risk factor currently available, it was used in this assessment.

       For consumers engaging in gardening activities with vermiculite products 4 hours  per day,
once a year for 30 years with vermiculite products, the risks range from 3.1E-6 to 2.8E-5 (Table 8).
The risks are 6 times higher for those engaging in these activities 6 times per year. For consumers
                                           16

-------
who garden with vermiculite for one-half hour per year for 10 years, the risks ranged from 1.3E-7
to 1.2E-6. The risks are 6 times higher for those engaging in these activities 6 times per year.  These
risks  are based  on the air concentrations derived from  the indoor  and outdoor product use
simulations. There are several uncertainties associated with these estimates that should be noted.
For example, data on the actual amount of time that the average consumer is  likely to handle
vermiculite containing asbestos are not  available.  Therefore, the exposure factors used in this
assessment are based on assumptions about the  activities of consumers that may or may not
accurately reflect actual use patterns. However, the assumptions used are believed to provide a range
of risks that would bracket risks among consumers. If consumer exposures/frequencies/durations are
10 to 100 times higher than those assumed here, the corresponding risks to consumers  would also
be 10 to 100 times higher. It is also possible, that not all of the vermiculite used contains asbestos
in the ranges observed in this study. In addition, as mentioned previously, there is some  uncertainty
associated with the use of the URF for fiber concentrations above 0.04 f/cc. However, given the
limited data set, and lack of exposure factors for activities specific to  vermiculite use, these risk
calculations are believed to represent a reasonable range of estimates for the consumer populations.
Occupational exposures were not evaluated as part of this study.
                                            17

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6.0    REFERENCES


EMSL (1999) Asbestos analysis of vermiculite and vermiculite containing products: EMSL analytical
SOP Method 2000 (proprietary method).

EMSL (2000) Overview of EMSL vermiculite sieving method.

EPA (1984) Methodology for the measurement of airborne asbestos by electron microscopy. Report
prepared for the U.S. Environmental Protection Agency,  Environmental  Monitoring Systems
Laboratory by IIT Research  Institute under Contract No. 68-D2-3266.

EPA (1997a) Superfund method for the determination of releasable asbestos in soils and bulk
materials.  Office of Solid Waste and Emergency Response.  EPA 540-R-97-028.

EPA (1997b) Exposure Factors Handbook. Washington, DC: Office of Research and Development.
EPA/600/P-95/002F.

EPA (2000)  Integrated Risk Information System.  U.S.  Environmental Protection Agency,
Washington, D.C. Accessed May 2000.

EPA Region 6   (2000)  EPA "Asbestos in schools product survey and other related studies"
conducted by EPA Region 6.

EPA Region 10 (2000) Preliminary laboratory results of TEM analyses on vermiculite samples from
Retail Home and Garden Centers Project conducted by Lab/Cor Inc. for EPA Region 10.

Frasca, P. (2000) Letter to Versar Inc. dated April 20, 2000 regarding the analytical techniques used
to estimate the asbestos content of vermiculite-containing consumer products.

IOM (Institute of Occupational Medicine) (No Date) Two bulk samples of South Carolina vermiculite
labeled AC 10 and AC 12: Assessment of tremolite and other mineral content. Memo report prepared
by IOM, Edinburgh, Scotland, for Julie C.  Yong, WR Grace & Co. Report No. 86/669 under
Contract No. 7563.

IOM (Institute of Occupational Medicine) (1993) Determination of asbestos content of two expanded
South Carolina vermiculite samples.  Report prepared by IOM, Edinburgh, Scotland, for Julie C.
Yon, WR Grace & Co. Report No. A2679/A2773 under Contract No. 1592/1659.

MRI (1982) Collection, analysis and characterization of vermiculite samples for fiber content and
asbestos contamination. Prepared for U.S. EPA by MRI under Contract No. 68-01-5915.

NIOSH (1994) Method 7400, Issue 2: Asbestos and other fibers by PCM.  National Institute of
Occupational Safety and Health Manual of Analytical Methods (NMAM), 4th edition.

Versar (1985) Exposure assessment for asbestos - contaminated vermiculite. Prepared for U.S. EPA
under Contract Nos. 68-01-6271 and 68-02-3968.
                                          18

-------
          Table 1. Types and Contents of Asbestos Fibers in Vermiculite Produced in the United States*
Mines
W.R.
Grace
Libby,
Montana
W.R.
Grace
Enoree,
South
Carolina
Patterson,
Enoree,
South
Carolina
Venniculite Samples
Head feed (Raw ore)
Beneficiated Grade 1
Beneficiated Grade 2
Beneficiated Grade 3
Beueficiated Grade 4
Beneficiated Grade 5
Mill feed (raw)
Beneficiated Grade 3
Beneficiated Grade 4
Beneficiated Grade 5
Exfoliated Grade 3
Exfoliated Grade 4
Beneficiated Ungraded
Sample
No.
291-1
270-1
276-1
259-1
282-1
264-1
436-1
430-1
433-1
427-1
439-1
442-1
573-1
Total Asbestiform Fibers
Estimated
Contents (%)
21-26
4-6
4-7
2-4
0.3-1
2-4
<1
<1
<1
<1
<1
<1
<1
Mineral Types
Tremo lite- Actino lite
Tremolite-Actinolite
Tremolite- Actino lite
Tremo lite- Actino lite
Tremo lite-Actinolite
Tremolite-Actinolite
Mixed, Tremo-Actin
Mixed, Tremo-Actin
Mixed, Tremo-Actin
Mixed. Tremo-Actin
Mixed, Tremo-Actin
Mixed, Tremo-Actin
Mixed, Tremo-Actin
Respirable Asbestos Fibers
Lab-
Exfoliated
no
no
yes
yes
yes
yes
no
yes
yes
yes
-
-
yes
ITTRI Lab**
xlO6
Fibers/g
62.5
32.5
23.4
42.4
65
142
0.3
3.1
3.1
3.5
11.7
-
0.7
Mass Contents
(ppm)
670
78
48.5
250
460
2600
0.49
3.7
1.4
4.1
-
-
3
ORF Lab 	
xlO6
Fibers/g
131.2
-
-
59
1.8
160
12.3
2.4
2.7
2.9
-
-
1.1
Mass
Contents
(ppm)
690
-
-
240
17
1800
22
1.0
2.0
120
-
-
4.0
Based on Tables 1 and 2 of the MRI report
Analyzed by Ontario Research Foundation
Analyzes by IIT Research Institute
                                                          19

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      Table 2.  Analytical Results of EPA Region 10's Study of Asbestos in Consumer Products
Sample
ID
54200
54201
54202
54203
54204
54205
54206
104200
54207
54208
54209
54210
54211
54212
54213
54214
54215
54216
54217
Product
Black Gold Vermiculite
Coles Vermiculite
Schultz Vermiculite
Whitney Farms Vermiculite
Scott's Vermiculite
Zonolite® Vermiculite
Zonolite® Vermiculite
Zonolite® Chubby & Tubby
Termo-O-Rock
Professional Jiffy Mix Potting Soil
Sam's Choice Professional Potting Soil
Coles Lighthouse Plant Mix
Schultz Seed Starter
Schultz Seed Starter
Coles African Violet Mix
Coles Cactus Mix
Country Cottage Professional Seed Starter
Black Gold Seedling Mix
Scotts Progro Professional Potting Mix
TEM
(%)
ND
ND
ND
ND
ND
ND
ND
ND
0.56 (Actinolite)
1.88
(Actinolite/Tremolite)
O.lO(Tremolite)
0.47 (Actinolite)
2.79 (Tremolite)
ND
ND
0.33 (Actinolite)
0.30 (Tremolite)
ND
ND
ND
ND
ND
ND
0.45 (Actinolite)
ND
ND
ND
PLM
(%)
ND
ND
ND
Trace
Trace
Trace
-
Trace
-
Trace
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Sample
Preparation
Method
A
A
A
A
B
C
A
C
A
B
C
A
C
B
A
B
C
A
A
A
A
A
A
A
A
A
A
Notes:
ND  =  Non-detect.
A   =  Representative sample from cross section of bag. Analyses done by semi-quantitative PLM and TEM method:
        EPA/600/R-93/116.
B   =  Sample sifted with USA Standard Testing Selves (size No. 10 and No. 35).  Analyses done using semi-
        quantitative method: EPA/600/R-93/116. Results represent asbestos content of only the fine portion (i.e., the
        portion that passed through the sieves) of vermiculite product; does not represent percent asbestos in whole
        product.
C   =  Residue after particle separation from Manchester Environmental Laboratory (MEL).  Analysis done using
        semi-quantitative method: EPA/600/R-93/116. Results represent asbestos content of only the fine portion
        (i.e., the portion that passed through the sieves) of vermiculite product; does not represent percent asbestos
        in whole product (see Section 1.1 for details on this procedure).
                                                  20

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            Table 3. Vermiculite or Vermiculite-Containing Products Purchased
Location of Purchase
Tempe, Arizona
Sacramento. California
Denver (Northglen), Colorado
Miami, Florida
Atlanta, Georgia (mail order)
Chicago (Lombard), Illinois
Minneapolis (Hopkins), Minnesota
Philadelphia (Bristol), Pennsylvania
San Antonio, Texas
Springfield, Virginia (Washington, DC area)
Kent, Washington
Batavia, Illinois
Product Name
Black Gold Vermiculite
Whitney Farms Vermiculite
Whitney Farms African Violet Mix
Black Gold Vermiculite
Green-all Vermiculite
Unigro Premium Organic Vermiculite
Kellogg 's Vermiculite
Schultz Professional Potting Soil
Schultz Horticultural Vermiculite
Cole's Houseplant mix
Cole's Premium Vermiculite
Cole's Premium African Violet Mix
Jungle Growth Vermiculite
Ace Horticultural Grade Vermiculite
OFE International Inc. Bromeliad Mix
Ferti-lome Vermiculite
Schultz Horticultural Vermiculite
Jungle Growth African Violet Mix
Ben Meadows Palmetto Lab Pack
Mica Grown Vemiculite
Miracle Gro Vermiculite
Hoffman's Vermiculite
Ace Horticultutal Grade Vermiculite
Earthgro's Best Vermiculite
Country Cottage Vermiculite
Hoffman's African Violet mix
Butterfield Farms Potting Soil
Premier Pro-mix
Scott's Vermiculite
Professional Jiffy Mix
Schundler Horticultual Vermiculite
Care Free Jiffy Mix
Schultz Horticultural Vermiculite
Country Cottage Horticultural Vermiculite
Pursell's Stay-Green Vermiculite
Zonolite® Chemical Packaging Vermiculite
(purchased by Versar)
Zonolite® Chemical Packaging Vermiculite
(purchased by Region 10)
VWR Lab Packaging Material3
VWR is a user of this lab packaging material and is not the distributor of this material.  The original source of this
packaging material is unknown.
                                           21

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Table 4.  Analytical Results
Sample
ID
90812
90813
68184
90814
90815
90816
68189
90817
90818
90819
90820
68191
90821
68190
90822
90823
90824
90825
90826
90827
Purchase
Location
Miami, FL
Miami, FL
(resample)
Miami. FL
Miami. FL
Miami. FL
(resample)
Miami. FL
Temp. AZ
Temp. AZ
Temp. AZ
(resample
Sacramento, CA
(resample)
Sacramento, CA
Sacramento, CA
Sacramento, CA
Northglen, CO
Northglen, CO
Northglen, CO
Brand
Jungle Growth
Ace
OFF International
Inc.
Ferti-lome
Schultz
Jungle Growth
Black Gold
Whitney Farms
Whitney Farms
Black Gold
Green-All
Uuigro
Kellogg's
Schultz
Schultz
Cole's
Product
Vermiculite
Horticultural
Grade
Vermiculite
Bromeliad Mix
(1)
Vermiculite
Horticultural
Vermiculite
African Violet
Mix(l)
Vermiculite
Vermiculite
.African Violet
Mix(l)
Vermiculite
Vermiculite
Premium
Organic
Vermiculite
Vermiculite
Professional
Potting Soil (1)
Horticultural
Vermiculite
Houseplant Mix
(1)
Bulk Analyses
PLM
Results
(weight %)
ND(2)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
BQL
ND
ND
ND
ND
ND
ND
PLM
Fiher
Type
Ohserved
-

-
-
-
-
-
-
-
-
-
-
-
Chrysotile/
Tremolite
-

-
-
-
-
TEM
Results
(weight %)
ND
0.35
BQL (3)
ND
ND
BQL
ND
ND
ND
BQL
BQL
ND
BQL
ND
BQL
ND
ND
ND
ND
ND
TEM Fiher
Type
Ohserved
-
Actinolite
Actinolite
-
-
Actinolite
-
-
-
Actinolite
Actinolite/
Chrysotile

Chrysotile
-
Actinolite

-
-
-
-
SOP 2000
PLM
Results
(weight %)
NA
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
TEM
Results
(weight %)
NA
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
TEM
Fiber
Type
Observed
-

-
-
~
-
-
-


-

-
-
-
-
Superfund Method
Releasable Long
(>S ^ini) Asbestos
Structures/g Samples
Mean
NA (4)
<369
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
95%
UCL
NA
<724
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Region 10 Sieving
Method
PLM
(weight
%)
-

-
-
~
-
-
-


-

-
-
-
-
TEM
(weight
%)
-

-
-
~
-
-
-


-

-
-
-
-
           22

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Table 4.  Analytical Results (continued)
Sample
ID
90828
90829
90830
90831
68185
68183
90832
68186
90833
68187
90834
90835
90836
68193
90837
90838
90839
68192
90840
90841
90842
Purchase
Location
Northglen, CO
Northgleii, CO
Hopkins, MN
Hopkins, MN
(resample)
Hopkins, MN
Hopkins, MN
(resample)
Hopkins, MN
(resample)
Hopkins, MN
Lombard, IL
Bristol. PA
(resample)
Bristol, PA
Bristol, PA
San Antonio. TX
(resample)
San Antonio, TX
Atlanta, GA
Springfield, VA
Brand
Cole's
Cole's
Miracle Gro
Hoffman's
Hoffman's
(bottom of bag)
Ace
Earthgro's
Country' Cottage
Mica Grown
Hoffman's
Butterfield Farms
Premier
Scott's
Professional
Ben Meadows
Palmetto
Schundler
Product
Premium
Vermiculite
Premium
African Violet
Mix(l)
Vermiculite
Vermiculite
Vermiculite
Horticultural
Grade
Vermiculite
Best
Vermiculite
Vermiculite
Vermiculite
African Violet
Soil Mix (1)
Potting Soil (1)
Pro-mix (1)
Vermiculite
Jiffy Mix (1)
Lab Pack
Horticultural
Vermiculite
Hulk Analyses
PLM
Results
(weight %)
ND
ND
ND
ND
BQL
BQL
ND
ND
ND
BQL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
PLM
Fiber
Type
Observed
-

-
-
Tremolite
Tremolite
-
-
-
Tremolite
-
-
-
-
-
-
-
-
-
-
-
TEM
Results
(weight %)
BQL
ND
ND
0.70
BQL
BQL
0.24
BQL
0.41
0.17
ND
ND
BQL
BQL
ND
ND
ND
BQL
ND
BQL
BQL
TEM Fiber
Type
Observed
Chrysotile

-
Actinolite
Anthophyllite
Actinolite
Actinolite
Actinolite
Actinolite
Actinolite
-
-
Actinolite/
Chrysotile
Actinolite
-
-
-
Actinolite
-
Chrysotile
Chrysotile
SOP 2000
PLM
Results
(weight %)
NA
NA
NA
ND
NA
ND
ND
ND
NA
NA
NA
NA
NA
NA
NA
NA
TEM
Results
(weight %)
NA
NA
NA
ND
NA
BQL
ND
ND
NA
NA
NA
NA
NA
NA
NA
NA
TEM
Fiber
Type
Observed
-

-
~
-
Actinolite/
Tremolite
~
-
-

-
-
~
-
-
-
Superfund Method
Releasable Long
(>5 fan) Asbestos
Structures/g Samples
Mean
NA
NA
NA
<241
NA
<380
<414
-
NA
NA
NA
NA
NA
NA
NA
NA
95%
UCL
NA
NA
NA
<472
NA
<745
<811
-
NA
NA
NA
NA
NA
NA
NA
NA
Region 10 Sieving
Method
PLM
(weight
%)
-

-
ND
-

~
-
-

-
-
~
-
-
-
TEM
(weight
%)
-

-
ND
-

~
-
-

-
-
~
-
-
-
                   23

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                                                                     Table 4.  Analytical Results (continued)
Sample
ID
90843
90844
68188
90845
90846
90847
68180
68181
68182
Purchase
Location
Springfield, VA
Springfield, VA
(resauiple)
Springfield, VA
Kent, WA
Kent, WA
Batavia. IL
(provided by EPA)
Kent, WA
(provided by
Region 10)
Springfield, VA
Brand
Care Free
Schultz
Country Cottage
Zonolite* (bottom
of bag)
Zonolite®
(composite
sample)
VWR (5)
Zonolite* (sample
from bottom 1/3 of
bag)
Pursell's
Product
Jiffy Mix (1)
Horticultural
Vermiculite
Horticultural
Vermiculite
Chemical
Packaging
Chemical
Packaging
Lab Packaging
Chemical
Packaging
Sta-Green
Bulk Analyses
PLM
Results
(weight %)
ND
ND
ND
ND
ND
ND
0.6
0.3
BQL
PLM
Fiber
Type
Observed
-
-
-
-
-

Tremolite
Tremolite
Tremolite
TEM
Results
(weight %)
BQL
0.13
ND
BQL
BQL
ND
0.14
BQL
ND
TEM Fiber
Type
Observed
Actinolite/'
Chrysotile
Actinolite
-
Chrysotile
Actinolite

Actinolite
Actinolite
-
SOP 2000
PLM
Results
(weight %)
NA
NA
NA
NA
NA
NA
NA
NA
TEM
Results
(weight %)
NA
NA
NA
NA
NA
NA
NA
NA
TEM
Fiber
Type
Observed
-
~
-
-

-

-
Superfund Method
Releasable Long
(>5 ion) Asbestos
Structures/g Samples
Mean
NA
424
NA
NA
NA
NA
NA
NA
95%
UCL
NA
832
NA
NA
NA
NA
NA
NA
Region 10 Sieving
Method
PLM
(weight
%)
-
ND
-
BQL
---•1%
ND
-

-
TEM
(weight
%)
-
ND
-
BQL
<0.1%
ND
-

-
(1) Ashed due to organic content.
(2) ND = Not detected.
(3) BQL = Below Quantitation limit (0.25% for PLM and 0.1% for TEM).
(4) NA = Not analyzed.
(5) VWR is a user of this lab packaging material and is not the distributor of this material. The original source of this packaging material is unknown.
                                                                                              24

-------
                                   Table 5. Results of Asbestos Analyses Using EPA Superfund Method
Sample
ID
90813
90831
90832
90833
90844
Purchase
Location
Miami. FL
Hopkins, MN
Hopkins, MN
Hopkins, MN
Springfield. VA
Brand
Ace
Hoffman's
Ace
Earthgro's
Schultz
Product
Horticultural
Grade
Vermiculite
Venniculite
Horticultural
Grade
Venniculite
Best
Vermiculile
Horticultural
Vermiculile
Respirable
Dust Cone.
(g dust/g
sample)
2.52E-6
9.54E-7
6.63E-7
1.31E-7
2.93E-6
Total Asbestos
Concentration
(s/g dust)"
Mean
•--1.47E+8
<2.52E+8
<5.74E+8
<3.16E+9
2.18E+8
95% UCL
•-2.88E+8
<4.95E+8
<1.12E+9
<6.19E+9
4.27E48
Long Asbestos
Concentration
(s/g dust)"
Mean
<1.47E+8
'2.52E+8
<5.74E+8
-3.16E+9
1.45E+8
95% UCL
•-2.88E+8
<4.95E+8
'•l.UE+9
<6.19E+9
2.84E48
Total Asbestos
Concentration
(s/g sample)"
Mean
<369
<241
<380
'414
637
95% UCL
<724
<472
<745
-811
1,249
Long (>5 /j,g)
Asbestos
Concentration
(s/g sample)"
Mean
-369
-241
<380
<414
424
95% UCL
<724
>472
<745
-811
832
a Structures per gram of dust.
b Structures per gram of sample.
                                                                    25

-------
                                                       Table 6.  Fiber Levels in Air Inside the Containment
Product/Purchase Location
Schullz Horticultural Vermiculite
Springfield. VA
(ND - 0.13% asbestos, based on TEM on
bulk samples)
Hoffman's Vermiculite
Hopkins, MN
(BQL - 0.70% asbestos, based on TEM
on bulk samples)
Zonolite* Chemical Packaging
\ ermiculite
Kent, WA
(ND - BQL asbestos, based on TEM on
bulk samples)
Country Cottage
Horticultural \ ermiculite
Springfield, VA
(BQL Asbestos, based on TEM on bulk
sample)
Scott's Vermiculite
San Antonio, TX
(ND-BQL asbestos, based on TEM on
bulk samples)
Jungle Growth Vermiculite
Miami. FL
(ND asbestos, based on TEM on bulk
sample)
Kellogg's Vermiculite
Sacramento, CA
(ND asbestos, based on TEM on bulk
sample)
Monitor Location
Outside area monitor
Inside area monitor
Personal monitor
Outside area monitor
Inside area monitor
Personal monitor
Outside area monitor
Inside area monitor
Personal monitor
Outside area monitor
Inside area monitor
Personal monitor
Outside area monitor
Inside area monitor
Personal monitor
Outside area monitor
Inside area monitor
Personal monitor
Outside area monitor
Inside area monitor
Personal monitor
PCM Concentration' (f/cc)
NIOSH 7400 Method
<0.008
<0.008- 0.015
<0.043
<0.008
0.027-0.047
0.122-0.371
0.011-0.012
<0.010- 0.108
0.344-0.482
0.008-0.012
overloaded
overloaded
<0.006
overloaded
overloaded
0.014-0.015
overloaded
overloaded
<0.006
0.017-0.020
< 0.047 -0.074
TEM Concentration6 (s/cc)
EPA Level II Method
ND (<0.0176)
ND(<0.0176)
ND(< 0.1002)
ND (<0.0176)
ND (<0.0178)
ND(<0. 1047) -0.0935
ND (<0.0167)
ND (0.0229) - 0.0961
ND (<0.0229) - 0.0769
0.6255 - 0.7536
0.4170-0.6594
ND(<0.0151)
ND(<0.5012)C
ND (<3.4302)c
ND(<0.0141)
ND(<2.5044)C
ND(<16.0428)C
ND(<0.0151)
ND(<1.0028)C
ND (<3.2868)c
ND(<0.0151)
ND (<0.0149)
ND(<0.1052)
TEM Fiber Type
-
-
-
-
-
Tremolite >5 urn in length
-
Actinolite all fiber lengths
Actinolite >5 [j,m in length
Actinolite all fiber lengths
Actinolite >5 urn in length
-
-
-
-
-
-
-
-
-
-
-
-
Note:

fee = fibers per cubic centimeter
s/cc = structures per cubic centimeter

ND = nou-detect (detection limit)

"   All fibers meeting the counting rules: 3:1 ratio; >5 ^m in length.
b   Asbestos structures.
e   Sample was analyzed by indirect prep., ash and resuspended, 2 to 10% of sample filtered for analyses.
                                                                                     26

-------
                                                          Table 7.  Fiber Levels in Outside Air
Product/Purchase Location
Zonolite® for Horticultural Use
Kent, WA
(ND - BQL asbestos, based on
TEM on bulk samples)
Monitor Location
Perimeter
Personal
PCM Concentration3 (f/cc)
NIOSH 7400 Method
0.01 1-0.013'
0.1 34C
TEM Concentration" (s/cc)
EPA Level H Method
ND(<0.0155)
ND (0.0718)
TEM Fiber Type
-
--
Note:

f/cc = fibers per cubic centimeter
s/cc = structures per cubic centimeter

"   All fibers meeting the counting rules; 3:1 ratio; >5 //,m in length.
b   Asbestos structures.
   One sample was overloaded with dust and could not be read.
                                                                             27

-------
                                  Table 8. Estimated Cancer Risks from Asbestos Associated with Consumer Use of Vermiculite


Schultz's Venniculite
PCM
TEMa
Hoffman's Venniculite
PCM
TEMa
Zonolite®
PCM
TEMa
Countrv CottageVenniculite
PCM
TEMa
Scott's
PCM
TEMa
Jungle Growth
PCM
TEMa
Kellogg 's
PCM
TEMa
EC
(f/cc)

<0.04
<0.10
0.37
0.094
0.48
0.66
<3.4
<16.0
<3.3
0.074
<0.11
Bisk at
ET = 4
EF=1
EF = 30
LT = 75
URF = 0.23
Indoor Use
<1.7E-6
<4.2E-6
1.6E-5
3.9E-6
2.0E-5
2.8E-5
b
b
b
3.1E-6
<4.6E-6
Risk at
ET = 0.5
EF=1
EF=10
LT = 75
URF =0.23

<7.0E-8
<1.8E-7
6.5E-7
1.6E-7
8.4E-7
1.2E-6
b
b
b
1.3E-7
<1.9E-7
Risk at
ET = 4
EF = 6
EF = 30
LT = 75
URF = 0.23

<1.0E-5
<2.5E-5
9.3E-5
2.4E-5
1.2E-4
1.7E-4
b
b
b
1.9E-5
<2.8E-5
Risk at
ET = 0.5
EF=6
EF=10
LT = 75
URF = 0.23

<4.2E-7
5 /_/,m in length.
b  Risk not calculated because concentration term was non-detect with a high detection limit resulting from dilution of the sample.

Note: Risk = [(EC x (ET/24 hr/day) x EF x ED) / (LT x 365 d/yr)] x URF
         EC   =    exposure concentration (f/cc)
         ET   =    exposure time (hr/day)
         EF    =    exposure frequency (days/yr)
         ED   =    exposure duration (years)
         LT   =    lifetime (years)
         URF= unit risk factor (cc/c)
                                                                             28

-------
                -H
Figure 1.  Zonolite* Sample Purchased from Kent, Washington
                          29

-------
Figure 2. Preparation of TEM Grids
                30

-------
Figure 3. Transmission Electron Microscpe
                   31

-------
Figure 4. Elutriator Used in the Superfund Method
                       32

-------
   Vacuum
                      Oxygen Monitor
Air Monitor
f:?- (~} ~n


fe?i- 8f
^ 0) §-.

r^'t1 n o
^ O TI

^ 3. ^

f& 9?. ^
:a_5 o
                                   10ft.
                                      Air Monitor
                                       DO

                                       CD

                                       =3

                                       0
                                      Air Monitor
                                                     o

                                                     ^
                                      Air Monitor
                      Unit is 10 feet high.

      Plastic sheeting is used for walls, ceiling and floor.
   Figure 5. Diagram of 10' x 10' x 10' Containment Used in the Product Use Simulation
                             33

-------
Figure 6. Containment Used in Product Use Simulation
                       34

-------
Figure 7. Consumer Use Simulation Wearing Protective Clothing
                            35

-------
Figure 8. High-Volume Air Sampling Pump
                 36

-------
Figure 9. Outdoor Product Use Simulation
                  37

-------
Figure 10.  Sieving the Vermiculite Product
                   38

-------
Figure 11.  Asbestos Fiber Seen by TEM
                 39

-------
Figure 12.  Actinolite Asbestos Fiber
                40

-------
  APPENDIX A
Laboratory Reports

-------
EMSU
T""Tl*OT A 1 ~*£ I T
E/JVlalj Analytical, inc


107 Haddon Avenue, Westmont, NJ 08108
Attn: David Nelson
Versar Inc.
P.O. Box 1549





TEL:
Customer ID:
Customer PO
Received:
>^^^^^^w^
^^^^•r
856-858-4800 ^^^^
	 ^p—
VERS96

4/17/00
6850 Versar Center
Springfield, VA 221 51
Fax: 703-642-6942
Phone: 703-750-3000 ext. 6946
EMSL Order:
040005712
Project: EPA Vernnculite/4600.008
Analysis of Vermiculite Asbestos by
Sample ID
90812
90813
90814
90815
90816
90817
90818
90819
90820
90821
90822
90823
90824
90825
90826
90827
90828
90829
90830
90831
i-
90832
90833
90834
90835
90836
90837
90838
90839
90840
90841
90842
90843
Key
Asbestos Weight%
BQL
0.35 Weight %
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
0.7 Weight %
0.24 Weight^
0.41 Weight %
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL

Transmission Electron Microscopy
Asbestos Type(s)
ND
Actinolite
ND
ND
Actinolite
ND
ND
Actinolite
Actinolite/ Chrysotile
Chrysotile
Actinolite
ND
ND
ND
ND
ND
Chrysotile
ND
ND
Actinolite
Actinolite
Actinolite
ND
ND
Actinolite/Chrysotile
ND
ND
ND
ND
Chrysotile
Chrysotile
Actinolite/Chrysotile
\ \^V^QUy
LVDI- None Detected
%U.L.u^.^.
Ashed /Not Ashed


Ashed


Ashed


Ashed




Ashed

Ashed

Ashed






Ashed
Ashed
Ashed

Ashed


Ashed
jj

A.V. Samudra, PbJD.

-------
    EMSL Analytical,  Inc.
    107 Haddon Ave., Westmont, NJ 08108
   Attn:     Bradley Norton
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax:     703-642-6809
                   Phone:  703-642-6889
   Project:  4600.008/EPA Vermiculite
                                 Customer ID      VERS96
                                 Customer PO:
                                 Received:         04/14/00 1:16 PM

                                 EMSL Order      040005712
                                 EMSL Project ID:
     Polarized Light Microscopy (PLM) - Point Count Performed by EPA 600/M4-82-020/ELAP
                                                  5.2.1-6.0 Methods*
 Sample
Location
Appearance      Treatment
Asbestos
 % Type
        Non-Asbestos
%   Fibrous          %  Non-Fibrous
 90812
 040005712-0001
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
                                   None Detected
                                                        <1% Cellulose
                                             100.0% Non-fibrous (other)
 90813
 04000S712-O002
                 Grayish/Tan       Teased
                 Non-Fibrous
                 Heterogeneous	
                                   None Detected
                                                        <1% Cellulose
                                             100.0% Non-fibrous (other)
190814
 MO005712-O003
                 Brown/Tan
                 Fibrous
                 Heterogeneous
                 Teased
  None Detected      30.0% Cellulose
                       1.0% Synthetic
                     69.0% Non-fibrous (other)
90815
W00057I2-OWW
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
  None Detected        <1%  Cellulose        100.0% Non-fibrous (other)
90816
340005712-0005
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
                                   None Detected
                        <1%  Cellulose        100.0% Non-fibrous (other)
90817
 40005772-0006
                 Brown/Tan/Gray   Teased
                 Fibrous
                 Heterogeneous
                                   None Detected
                      30.0%  Cellulose
                        <1%  Glass
                       1.0%  Synthetic
                     69.0% Non-fibrous (other)
90818
340005712-0007
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
                                   None Detected
                                                        <1% Cellulose
                                             100.0% Non-fibrous (other)
 0819
 40005712-0003
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
                                  None Detected
                        <1%  Cellulose        100.0% Non-fibrous (other)
90820
140005712-0009
                 Brown/Gray       Teased
                 Fibrous           Dissolved
                 Heterogeneous
                                   None Detected      55.0% Cellulose         42.0% Non-fibrous (other)
                                                        3.0% Wollastonite
90821
 40005712-0010
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
  None Detected         <1%  Cellulose        100.0% Non-fibrous (other)
 0822
 340005712-0011
                 Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
  None Detected         <1%  Cellulose        100.0% Non-fibrous (other)
 Scoff Combs
 Analyst
                                                                                             Stephen Siegel, CIH
                                                                                          or other approved signatory
            .M has been known to miss asbestos in a small percentage of samples which contain asbestos. Thus negative PLM results cannot be guaranteed. Samples reported as
  <1'flr nonohetected should be tested with either SEM or TEM. The above test report relates only to the items tested. This report may only be reproduced in part with written approval
  by y%L. Tip above test must not be used by the client to claim product endorsement by NVLAP nor any agency of the United States Government. All "NVLAP" reports with NVLAP logo
                      iture to be valid. Laboratory is not responsible for the accuracy of results when requested to physically separate and analyze layered samples.
                                                                                                                        Pagel

-------
   EMSL Analytical,  Inc.
   107 Haddon Ave., Westmont, NJ 08108
   Attn:     Bradley Norton
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax:     703-642-6809
                                                  Customer ID
                                                  Customer PO:
                                                  Received:
                                  VERS96


                                  04/14/00 1:16PM
                   Phone: 703-642-6889
   Project   4600.008/EPAVermicullte
                                                  EMSL Order       040005712
                                                  EMSL Project ID:
     Polarized Light Microscopy (PLM) - Point Count Performed by EPA 600/M4-82-020/ELAP
                                                  5.2.1-6.0 Methods*
 Sample
90823

040005712-0012
Location
                 Appearance      Treatment
                Asbestos

                 % Type
                                Non-Asbestos

                       %   Fibrous           %  Non-Fibrous
                 Tan
                 Non-Fibrous
                 Heterogeneous
Teased
                  None Detected
                      <1% Cellulose        100.0% Non-fibrous (other)
90824

040005712-0013
                 Tan
                 Non-Fibrous
                 Heterogeneous
Teased
                  None Detected
                      <1% Cellulose        100.0% Non-fibrous (other)
90825

04000S712-0014
                 Brown/Tan
                 Fibrous
                 Heterogeneous
Teased
None Detected      70.0% Cellulose
                      <1% Synthetic
30.0% Non-fibrous (other)
90826

04000S712-0015
                 Tan
                 Non-Fibrous
                 Heterogeneous
Teased
None Detected        <1% Cellulose        100.0% Non-fibrous (other)
90S27

040005712-0016
                 Brown/Gray/Tan
                 Fibrous
                 Heterogeneous
Teased
                  None Detected
                    50.0% Cellulose
                      <1% Synthetic
                     3.0% Wollastonite
47.0% Non-fibrous (other)
90828
040005712-0017
                 Tan
                 Non-Fibrous
                 Heterogeneous
Teased
                  None Detected
                                        <1% Cellulose
                                           100.0% Non-fibrous (other)
90829

040005712-0018
                 Brown/Gray/Tan
                 Fibrous
                 Heterogeneous
Teased
Dissolved
None Detected       50.0% Cellulose
                      <1% Synthetic
                     3.0% Wollastonite
47.0% Non-fibrous (other)
90830
04000S712-0019 .
                 Gold/Tan
                 Non-Fibrous
                 Heterogeneous
Teased
Nona Detected         <1% Cellulose        100.0% Non-fibrous (other)
90831
040005712-0020
                 Brown/Gold
                 Non-Fibrous
                 Heterogeneous
Teased
None Detected         <1% Cellulose        100.0% Non-fibrous (other)
90833

040005712-0021
                 Tan
                 Non-Fibrous
                 Heterogeneous
Teased
None Detected         <1% Cellulose        100.0% Non-fibrous (other)
90834
040005712-0022
                 Tan
                 Non-Fibrous
                 Heterogeneous
Teased
None Detected         <1% Cellulose        100.0% Non-fibrous (other)
 Scoff Comos
Analyst
                                                                                 ri-
                                                                                              Stephen Siegel, CIH
                                                                                          or other approved signatory
         IPLM has been known to miss asbestos in a small percentage of samples which contain asbestos. Thus negative PLM results cannot be guaranteed. Samples reported as
         | detected should be tested with either SEM or TEM. The above test report relates only to the items tested. This report may only be reproduced in part with written approval
          5 above test must not be used by the diem to daim product endorsement by MVLAP nor any agency of the United States Government. All 'NVLAP* reports with NVLAP logo
                        i to be valid. Laboratory is not responsible for the accuracy of results when requested to physically separate and analyze layered samples.
                                                                                                                        Page 2

-------
   EMSL Analytical,  Inc.
   107 Haddon Ave., Westmorrt, NJ 08108
   Attn:     Bradley Norton
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 221 51
   Fax;     703-642-6809
                                                  Customer ID
                                                  Customer PO:
                                                  Received:
                                                   VERS96


                                                   04/14/00 1:16 PM
                   Phone:  703-642-6889
   Project:   4600.008/EPA Vermlculita
                                                  EMSL Order       040005712
                                                  EMSL Project ID:
    Polarized Light Microscopy (PLM) - Point Count Performed by EPA 600/M4-82-020/ELAP
                                                  5.2.1-6.0 Methods*
Sample
Location
                                 Asbestos

Appearance      Treatment       % Type
                                Non-Asbestos

                       %   Fibrous           %  Non-Fibrous
90832

040005712-O023
                 Gold/Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
None Detected        <1% Cellulose        100.0% Non-fibrous (other)
90835

040005712-0024
                 Tan/Gold
                 Non-Fibrous
                 Heterogeneous
                 Teased
None Detected        <1% Cellulose        100.0% Non-fibrous (other)
90836

040005712-0025
                 Brown/Gold
                 Non-Fibrous
                 Heterogeneous
                 Teased
                                   None Detected
                      <1%  Cellulose        100.0% Non-fibrous (other)
90837

040005712-001$
                 Brown/Black/Gray Teased
                 Fibrous
                 Heterogeneous
                                   None Detected
                    10.0%  Cellulose
                     1.0%  Hair
                      <1%  Synthetic
89.0% Non-fibrous (other)
90838
04000S712-0027
                 Brown
                 Fibrous
                 Heterogeneous
                 Teased
                                   None Detected
                    40.0%  Cellulose
                      <1%  Synthetic
60.0% Non-fibrous (other)
90839
04000S712-002S
                 Gold/Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
                                   None Detected
                                                         <1%  Cellulose
                                           100.0% Non-fibrous (other)
90840

040005712-0029
                 Brown/Tan
                 Fibrous
                 Heterogeneous
                 Teased
                                   None Detected       60.0%  Cellulose
                                                         <1%  Synthetic
                                            40.0% Non-fibrous (other)
90841

MOOOS712-0030
                 Grayish/Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
None Detected         <1%  Cellulose        100.0% Non-fibrous (other)
90842

MOOO5712-0031
                 Gold/Tan
                 Non-Fibrous
                 Heterogeneous
                 Teased
None Detected         <1%  Cellulose        100.0% Non-fibrous (other)
90843

 40005712-0032
                 Brown/Tan/Gold   Teased
                 Fibrous
                 Heterogeneous	
                                   None Detected
                    70.0%  Cellulose
                      <1%  Synthetic
30.0% Non-fibrous (other)
 Scoff Comte
Analyst
                                                                                              Stephen Siegel, CIH
                                                                                           or other approved signatory
        s.plM has been known to miss asbestos in a small percentage of samples which contain asbestos. Thus negative PLM results cannot be guaranteed. Samples reported as
               i should be tested with either SEM or TEM. The above test report relates only to the items tested. This report may only be reproduced in part with written approval
      SL ~n above test must not be used by the dient to daim product endorsement by NVLAP nor any agency of the United States Government. All "NVLAP" reports with NVLAP logo
              t one ajgpature to be valid. Laboratory is not responsible for (he accuracy of results when requested to physically separate and analyze layered samples.
                                                                                                                        Page3

-------
                                                                                                                                   4600
                                                           CHAIN OF CUSTODY RECORD
                   PROJECT NAME
      FIELD
     SAMPLE
     NUMBER
    STATION LOCATION
                                              Received by: (Signature)
                             Relinquished by: (Signature)
                                                                                                                        Received by: (Signature)
Received for Laboratory by
Relinquithed by: (Signature!
Distribution: Oriainal Plus One Accomoaniet Shioment (white and vellnwl: Tnnv tn r.nnrriin«tnr CUM Pi

-------
                                                                                                                           4601
                                                       CHAIN OF CUSTODY RECORD
 PROJECT NO.
PROJECT NAME
                                                                                                                          INDUSTRIAL
                                                                                                                        HYGIENE SAMPLE
                                                                  /
                                                  ) /4. jJffZ fc/J
    SAMPLE
    NUMBER
                             STATION LOCATION
                                           Received by: (Signature)
                                                     Relinquished by: (Signature)
                                                                                                     Date / Time   Received by: (Signature!
                         Received for Laboratory by
                         (Signature)
Relinquished by: (Signature)
Date / Time   Rflmarkl


-------
                                                                                                                                    4602
                                                           CHAIN OF CUSTODY RECORD
 PROJECT NO.
PROJECT NAME
                                                                                                                                   INDUSTRIAL
                                                                                                                                 HYGIENE SAMPLE
      FIELD
     SAMPLE
     NUMBER
                               STATION LOCATION
                                               Received by: (Signaiural
                                                         Relinquished by: (Signature)
                                                                                                                          Received by: (Signature)
                           Received for Laboratory by
Relinquished by: (Signature)
DJctribiilinn: Original Pint Hnn ArrnmnaniA* *5hinm«»nt fuuhit** nnH w«tM/\uM\- Pr»r*\/ */% r>^Ar^;n**«r c;*u c:t— /_:_i.i

-------
EMSL Analytical, Inc
107 Haddon Avenue, Westmont, NJ 08108
                                         TEL: 856-858-4800
Atta:   David Nelson
       Versar Inc.
       6850 Versar Center
       P.O. Box 1549
       Springfield, VA 22151
Fax:   703-642-6942   Phone: 703-750-3000 ext 6946
Project: EPA Vermiculite/4600.008
                                   Customer ED:  VERS96
                                   Customer PO:

                                   Received:     4/14/00

                                   EMSL Order:  040005 817
                  Analysis of Vermiculite Asbestos by Transmission Electron Microscopy
   Sample ID
Asbestos Weight %
Asbestos Type(s)
Ashed/Not Ashed
   90844
   90845
   90846
   90847
0.13Weight%
BQL
SQL
BQL
Actinolite
Chrysotile
Actinolite
ND
Not Ashed
Not Ashed
Not Ashed
Not Ashed
  Key
BQL - Below Quantitation Limit (about 0.1 wt%)
 ND = None Detected
                                                                          A.V. Samudra, Ph.D.

-------
    EMSL Analytical,  Inc.
    107 Haddon Ave, Westmont, NJ 08108
                                       .-™.&_'?L_™7s*i~nr^»«.T ^-. >*=&**»—-^v^*re^*^<^^-*a.garai'«»»*nre^*~'^*'ffis* -TP«: ^a
    Attn:     David Nelson
             Versar Ina
             6850 Versar Center
             PO Box 1549
             Springfield, VA 221 51
    Fax:      703-642-6809
                   Phone:  703-642-6889
   Project:  EPA Vermiculite/4600.008
                                                    Customer ID      VERS96
                                                    Customer PO:
                                                    Received:         04/17/009:51 AM
                                                    EMSL Order      040005817
                                                    EMSL Project ID:
               Polarized Light Microscopy (PLM) Performed by EPA 600/R-93/116 Method

                                                                         Asbestos                           Non-Asbestos
 Sample
Location
Appearance
                                    Treatment
                  %  Type
                                                                                                %   Fibrous
                                                                                                    %  Non-Fibrous
90844

04OOOS317-OOOS
Shultz
Horticultural
Vermiculite
Brown/Tan
Non-Fibrous
Heterogeneous
Teased
                  None Detected        <1%  Cellulose
  u^o Non-fibrous (oiher)
90845
Country Cottage
Horticultural
Vermicufite
Brown/Tan
Non-Fibrous
Heterogeneous
                                                       Teased
                                                                         None Detected        <1%  Cellulose
                                                              100% Non-fibrous (other)
90846

040005817-0007
                   ZonoLite- Fines
                  Tan/Gold
                  Non-Fibrous
                  Heterogeneous
                  Teased
                                   None Detected        <1%  Cellulose
                                                              100% Non-fibrous (other)
90847

040005817-0006
ZonoLite -
Composite
Gray/Gold
Non-Fibrous
Heterogeneous
Teased
                 None Detected       <1%  Cellulose
100% Non-fibrous M-
 Scott Combs
 Analyst
                                                                                                Stephen Siegel, CIH
                                                                                             or other approved signatory
  Disclaimers: PLM has Been known to miss asoestos in a small percentage of samples which contain asbestos. Thus negative PLM results cannot be guaranteed. Samples reported as
  <1* or nor* detected should ba tested with either SEM or TEM. The above test report relates only to trie items tested. This report may only be reproducad in part with written approval
  by $ASL T|ie above lest must not be used by the dient to dain product endorsement by NVLAP nor any agency of the United Slates Government. All "NVLAP" reports with NVLAP
           "lin at least one signature to be vaSd. Laboratory is not responsible for the accuracy of results when requested to physically separate and analyze layered samples.
                                                                                                                              Page 1

-------
                                                           CHAIN OF CUSTODY RECORD
                                                                                                                                   4603
                                                                                                                                    [>&/
                                                                            Relinquished by. (Sifmturtl
                                               Received for Liboritory by
Ralinquitnml by: (Siontturt}
Oiitribulion: Original Plui On« AccornpaniM Shipment (whtu ind ytllovy); Copy to Coordinator Fi«ld Film (pink).

-------
 EMSL Analytical, In .
 107 Haddon Ave, Westmont, NJ 08108
                            Order ID: 040006957
 Attn:     David Nelson
         Versar Inc.
         6850 Versar Center
         PO Box 1549
         Springfield, VA 22151
 Fax:      703-642-6809
 Project:   4600.008/EPA Vermiculite
                             Customer ID:
                             Customer PO:
                             Received:
                             EMSL Order:
                             EMSL Project ID:
                      VERS96
                      5/5/00 11:05 AM
                     040006957
     Asbestos Analysis of Vermiculite by Transmission Electron Microscopy (TEM)
    Client
  Sample ID
    EMSL
   Sample ED
Asbestos
Weight%
Asbestos Type(s)   Ashed / Not Ashed
    68180
    68181
    68182
    68183
040006957-0001
040006957-0002
040006957-0003
040006957-0004
  0.14%
 BQL**
  BQL
  BQL
   Actinolite*
   Actinolite*
    ND***
   Actinolite*
Not Ashed
Not Ashed
Not Ashed
Not Ashed
Key
*ActinoliIte/Richterite
**BQL = Below Quantitation Limit (0.1 weight%)
***ND = None Detected
A.V. Samudra, Ph. D
TEMAnalyst
                                       Stephen SiegeL CIH- Lab Manager
                                             Or other approved signatory

-------
     EMSL Analytical, Inc.
     107 Haddon Ave., Westmont, NJ 08103
     Phone: (609)858-4800    Fax: (609)858-4980  Email:  ssiegel(ESEMSL.com
   Attn:     David Nelson
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA22151
   Fax:     703-642-6809
   Project:  EPA Vermiculite
                  Phone:  703-642-6889
                Customer ID:      VERS96
                Customer PO:     07563
                Received:         05/05/00 11:05 AM


                EMSL Order:      040006957
                EMSL Project ID:
                Analysis Date:      5/11/2000
      Polarized Light Microscopy (PLM) - Point Count Performed  by EPA 600/M4-82-020/ELAP 5
 Sample
Location
                 Appearance
                                                     Treatment
                            N on-As best os

                    %   Fibrous          %  Non-Fibrous
 68180
 040006957-0005
                Brown
                Fibrous
                Homogeneous
Teased
 5.0%  Cellulose        94.5% Non-fibrous (other)    0.6%  Tremotlte
 68181
 040006957-0006
                Brown
                Fibrous
                Homogeneous
Teased
 8.0%  Cellulose        91.7% Non-fibrous (other)    0.3%  Tremolite
 68182
 040006957-0007
                Brown
                Fibrous
                Homogeneous
Teased
10.0%  Cellulose         90.0% Non-fibrous (other)     <1%  Tremolite
 68183
 040006957-0008
                Brown
                Fibrous
                Homogeneous
Teased
10.0% Cellulose        90.0% Non-fibrous (other)    <1%  Tremolite
Essie Spencer
Analyst
                                                                                            Stephen Siegel, CIH
                                                                                         or other approved signatory
 Disclaimers: PLM has been known to miss asbestos in a small pwcentaga of samples which contain asbestos. Thus negative PLM results cannot ba guaranteed.
 <1« or mne.detac.ed should be tested with erther SEM or TEM. The above test report relates only to the Hems testedThjs report may only t» r^ucSlnpar.wpl
               test must not be used by the client to claim product endorsement by NVLAP nor any agency of the United States Government All -NVLAP" reports with NVLAP
           nn at least one signature to be valid. Laboratory is not responsible far the accuracy of results when requested to physically separate and analyze layered samples.
                     ointCount-1
                                                                                                                      Page 1

-------
£# H/SUWTte*v4*L> I
CHAIN OF CUSTODY RECORD
                                               4594

-------
 EMSL Analytical, Inc.
 107 Baddon Ave., Westmont, NJ 08108
                             Order ID: 040007035
 Attn:    David Nelson
         Versar Inc.
         6850 Versar Center
         PO Box 1549
         Springfield, VA 22151
 Fax:     703-642-6809
 Project:   4600.008/EPA Vermiculite
Customer ID:
Customer PO:
Received:
VERS96

5/8/00 11:20 AM
EMSL Order:       040007035
EMSL Project ID:
    Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using
                            Analytical Electron Microscopy
Client
Sample ID
68184
68185
68186
68187
68188
68189
68190
68191
68192
68193
EMSL
Sample ID
040007035-1
040007035-2
040007035-3
040007035-4
040007035-5
040007035-6
040007035-7
040007035-8
040007035-9
040007035-10
Asbestos
Weight %
BQL*
BQL
BQL
0.17
BQL
BQL
BQL
BQL
BQL
BQL
Asbestos
Type(s)
Actinolite
Anthopyllite
Actinolite
Actinolite
ND**
ND
ND
ND
Actinolite
Actinolite
 Key
 *BQL = Below Quantitation Limit (0.1 weight%)
 **ND = None Detected
 Note: All samples -were not ashed prior to analysis
,A.\j Samudra, Ph.D.
     vst
             Stephen Siegel, CIH- Lab Manager
                    Or other approved signatory

-------
    EMSL Analytical, Inc.
    107 Haddon Ave., Westmont, NJ 08108
    Phono: (609)858-4800    Fax: (609)858-4960  Email:  sslegel@EMSL.com
   Ann:     David Nelson
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax:     703-642-6809
                                    Phone:  703-642-6889
   Project:   4601.005/EPA Vermiculite
                                                 Customer ID:      VERS96
                                                 Customer PO:     07563
                                                 Received:        05/08/00 11:20 AM


                                                 EMSL Order      040007035
                                                 EMSL Project ID:
                                                 Analysis Date:      5/16/2000
      Polarized  Light Microscopy (PLM) - Point Count Performed by EPA 600/M4-82-020/ELAP 5

                                                                               Non-Asbestos                            Asbestos
 Sample	Location	Appearance	Treatment	    %   Fibrous          %  Non-Fibrous             % Type
 68184

 040007035-0001
 ACE
 HORTICULTURA
 Brown
 Fibrous
 Homogeneous
 Teased
3.0% Win. Wool
3.0% Wollastonite
94.0% Non-fibrous (other)      None
 68185

 0400070354002
 HOFFMAN
 HORTICULTURA
 Brown
 Fibrous
 Homogeneous
Teased         3.0% Cellulose
                2.0% Wollastonite
                     95.0% Non-fibrous (other)    <1%  Tremolite
 68186
 040007035-0003
ACE
HORTICULTURA
Brown
Fibrous
Homogeneous
Teased         3.0%  Cellulose
                2.0%  Wollastonite
                     95.0% Non-fibrous (other)      None Detected
68187
04000703S-O004
 EARTHGRO'S
 BEST
Brown
Fibrous
Homogeneous
Teased         5.0%  Cellulose
                3.0%  Wollastonite
                     92.0% Non-fibrous (other)    <1%  Tremolite
68188

04000703S-0005
SCHULTZ
HORTICULTURA
Brown
Fibrous
Homogeneous
Teased         4.0%  Cellulose
                3.0%  Wollastonite
                     93.0% Non-fibrous (other)      None Detected
68189

0400070354006
SCHULTZ
HORTICULTURA
Brown
Fibrous
Homogeneous
Teased
5.0% Cellulose
5.0% Wollastonite
90.0% Non-fibrous (other)      N-in at least one signature lo ba valid. Laboratory is not responsible for the accuracy of results when requested to physically separate and analyze layered samples.
                      iirrtCniint-1

-------
                                           4609
CHAIN OF CUSTODY RECORD

-------
  EMSL Analytical, Inc.
  107 Hkddon Ave.. Westmont, NJ 08108
                           Order ID: 040006832
 Attn:     David Nelson
         Versar Inc.
         6850 Versar Center
         PO Box 1549
         Springfield, VA 22151
 Fax:     703-642-6809
 Project:   4600.008/EPA Vermiculite
                           Customer ED:
                           Customer PO:
                           Received:
                           EMSL Order:
                           EMSL Project ID:
                        YERS96

                        5/4/00 12:58 PM
                                 */ --'•


                        040006832
    Asbestos Analysis of Bulk Materials via EMSL SOP 2000 Method using
     Polarized Light (PLM) and Transmission Electron Microscopy (TEM)
    Client
  Sample ID
    EMSL
  Sample ID
  PLM Results
EPA Point Count
TEM Results
Asbestos
Type(s)
    90813
    90831
    90832
    90833
    90844
040006832-0001
040006832-0002
040006832-0004
040006832-0003
040006832-0005
     ND*
      ND
      ND
      ND
      ND
   BDL**              ND
   BDL               ND
   BDL        Actinolite/Tremolite
   BDL               ND
   BDL               ND
Key
*ND = None Detected
**BDL = Below Detection Limit (0.1 weight%)
Essie Spencer
PLMAnafyst
    Samudra. Ph. D
                                      Stephen SiegeL CIH~ Lab Manager
                                              Or other approved signatory

-------
EMSL Analytical, Inc.
107 Haddon Ave., Westmont, NJ 08108
                               Order ID: 040006832
        Asbestos Analysis via EPA Superfund Method for the Determination of Releasable Asbestos Fibers in Soils and Bulk Materials-
                                                              EPA540-R-97-028
Attn:     David Nelson
         Versar Inc.
         6850 Versar Center
         PO Box 1549
         Springfield, VA 22151
Fax:     703-642-6809
Project:   4600.008/EPA Vermiculite
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58 PM
5/17/00

040006832
Releasable Asbestos in Respirable Dust
Client/Lab
Sample ID
90813/
040006832-1
9083 1/
040006832-2
90832/
040006832-3
90833/
040006832-4
90844/
040006832-5
Respirable Dust
Cone
(g/g smpl)
2.516E-06
9.542E-07
6.629E-07
1.311E-07
2.926E-06
Total Asbestos
Analytical
Sensitivity
(s/g dust)
1.47E+08
2.52E+08
5.74E+08
3.16E+09
7.25E+07
Total
Asbestos
Concentration (s/g
dust)
<1.47E+08
<2.52E-K)8
<5.74E+08
<3.16E~09
2.18E+08
Total
Asbestos 95%
UCL
(s/g dust)
<2.88E+08
<4.95E+08
<1.12E+09
<6.19E+09
4.27E+08
Long Asbestos
Analytical
Sensitivity
(s/g dust)
1.47E+08
2.52E-I-08
5.74E+08
3.16E+09
7.25E+07
Long
Asbestos
Cone
(s/g dust)
<1.47E+08
<2,52E+08
<5.74E+08
<3.I6E+09
1.45E+08
Long
Asbestos
95% UCL
(s/g dust)
<2.88E+08
<4.95E+08
<1.12E409
<6.19E+09
2.84E+Q8
Dust
Generation
Rate
(at 60 rpm)
(g/min)
8.60E-05
5.00E-05
2.20E-05
4.00E-06
1.74E-04
A.V. Samudra. Ph.D.
Analyst
                                      Stephen Siegel, CIH- Lab Manager
                                      Or other approved signatory

-------
EMSL Analytical, Inc.
107 Haddon Ave., Westmont, NJ 08108
                               Order ID: 040006832
        Asbestos Analysis via EPA Superfund Method for the Determination of Releasable Asbestos Fibers in Soils and Bulk Materials-
                                                               EPA540-R-97-028
Attn:     David Nelson
         Versar Inc.
         6850 Versar Center
         POBox 1549
         Springfield, VA 22151
Fax:     703-642-6809
Project:   4600.008/EPA Vermiculite

Releasable Asbestos in Laboratory Samples
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58 PM
5/17/00

040006832
Client/Lab
Sample ID
908 13/
040006832-1
9083 1/
040006832-2
90832/
040006832-3
90833/
040006832-4
90844/
040006832-5
Respirable Dust
Cone
(g/g smpl)
2.516E-06
' 9.542E-07
6.629E-07
1.311E-07
2.926E-06
Total
Asbestos
Analytical
Sensitivity
(s/g smpl)
369.36
240.90
380.35
413.63
212.25
Total
Asbestos
Concentration
(s/g smpl)
<369.36
<240.90
<380.35
<413.63
636.76
Total
Asbestos
95% UCL
(s/g smpl)
<723.95
<472.17
<745.49
<810.72
416.02
Long
Asbestos
Analytical
Sensitivity
(s/g smpl)
369.36
240.90
380.35
413.63
212.25
Long
Asbestos
Cone
(s/g smpl)
<369.36
<240.90
<380.35
<413.63
212.25
Long
Asbestos
95% UCL
(s/g smpi)
<723.95
<472.17
<745.49
<8 10.72
416.02
Comments





A,V. Samudra. Ph.D.
Analyst
                                       Stephen Siegel, CIH- Lab Manager
                                       Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                 Order ID: 040006832
  Asbestos Analysis via EPA Superfund Method for the Determination of Releasable
            Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:     David Nelson
          Versar Inc.
          6850 Ve;;ar Center
          PO Box 1549
          Springfield, VA 22151
 Fax:      703-642-6809
 Project:   4600.008/EPA Vermiculite

 Client Sampled 90813
 EMSL Sampled 40006832-001

 Chrysotile Asbestos Analysis Results

   No. of Total Chrysotile Asbestos Structures
   No. of Long (>5 urn) Chrysotile Asbestos Structures
   No. of Total Chrysotile Asbestos Fibers/Bundles
   No. of Long (>5 urn) Chrysotile Asbestos Fibers/Bundles

 Amphibole Asbestos Analysis Results
   No. of Total Amphibole Asbestos Structures
   No. of Long (>5 jam) Amphibole Asbestos Structures
   No. of Total Amphibole Asbestos Fibers/Bundles
   No. of Long (>5 ^m) Amphibole Asbestos Fibers/Bundles
   Amphibole Mineral Type-
 Customer ID:
 Customer PO:
 Received:
 Report Date:

 EMSL Order:
 EMSL Project ED:
    Low
Magnification
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
 ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN SAMPLE
                                                             Cone.
  Total Chrysotile Structures per g Sample                         <369.36
  Total Amphibole Structures per g Sample                        <369.36
  Total Asbestos Structures per g Sample                          <369.36
  Long Chrysotile Structures per g Sample                         <369.36
  Long Amphibole Structures per g Sample                        <36 9.36
  Long Asbestos Structures per g Sample                          <369.36
  Estimated Analytical Sensitivity: (structures/g)
      <369.36
ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN RESPIRABLE
DUST OF SAMPLE
  Total Chrysotile Structures per g Dust
  Total Amphibole Structures per g Dust
  Total Asbestos Structures per g Dust
  Long Chrysotile Structures per g Dust
  Long Amphibole Structures per g Dust
  Long Asbestos Structures per g Dust

  Estimated Analytical Sensitivity: (structures/g dust)

A.V. Samudra. Ph.D.
Analyst
       Cone.
   <146,778,498
   <146,778,498
   <146,778,498
   <146,778,498
   <146,778,498
   <146,778,498
VERS96

5/4/00 12:58 PM
5/17/00

040006832
      High
  Magnification
       0
       0
       0
       0
       0
       0
       0
       0
      N/A
   95% UCL
    <723.95
    <723.95
    <723.95
    <723.95
    <723.95
    <723.95

    <723.95
   95% UCL
 <287,685,856
 <287,685,856
 <287,685,856
 <287,685,856
 <287,685,856
 <287,685,856
   <1 46,778,498     <287,685,856
     Stephen Siegel, CIH- Lab Manager
           Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                  Order ID: 040006832
       Asbestos Analysis via EPA Superfund Method for the Determination of
     Releasable Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:
 Fax:
 Project:
David Nelson
Versar Inc.
6850 Versar Center
PO Box 1549
Springfield, VA 22151
703-642-6809
4600.008/EPA Vermiculite
Customer DD:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58 PM
5/17/00

040006832
                                                        Date Analysis Started
                                                     Date Analysis Completed
                                                              Lab Sample #
                                                     Field Sample ED Number
                                                  Field Prepartation Technique
                                         Additional Lab Preparation Procedures
                                                             Sample Drying
                                                            Sample Splitting
                                                                     Other
                                                             TEM Analysis
                                      Effective Area of Analytical Filter (sq mm)
                                                              Magnification
                                                  Grid Opening Area (sq mm)
                                                     Number of G.O. Scanned
                           Asbestos Structure Size and Type Categories of Interest
                                     Minimum Acceptable Structure ID Category
                                                            Dust Generator
                                                 Mass of Sample Tumbled (g)
                    Air Flow Rate Through ME opening of Dust Generator (ml/min)
                    Ah- Flow Rate Through 1ST opening of Dust Generator (ml/min)
                                              Air Flow Rate Scrubber (ml/min)
                        Estimated Total Air Flow Rate Through Elutriator (ml/min)
                                                                  5/9/00
                                                                  5/10/00
                                                                  040006832-0001
                                                                  90813
                                                                  N/A

                                                                  Yes
                                                                  N/A
                                                                  385
                                                                  19,OOOX
                                                                  0.0061
                                                                  10
                                                                  >0.5fi Length
                                                                  <0.5u Diameter
                                                                  >5:1 Aspect Ratio
                                                                  Amphiboles/Chrysotile
                                                                  >0.5u Length
                                                                  <0.5u Diameter
                                                                  >5:1 Aspect Ratio

                                                                  17.0874
                                                                  1500
                                                                  1300
                                                                  N/A
                                                                  1300
                                 Total Mass of Dust Collected on Dust Filters (g)   0.00043
                                 Time of Dust Collection (24 hr clock) at 60 rpm   30 sec
                                                                 Start/Stop   N/A
              Estimated first-order rate constants for dust generation (min'1) at 60 rpm   2
       Samples from the Isokinetic Sampling Tube (1ST) Opening of the Dust Generator 60 rpm run
                                              Time of Collection (24 hr clock)   30 sec
                                                                 Start/Stop   N/A
                                  Estimated Mass of Dust Collected on Filter (g)   0.00043
A.V. Samudra. Ph. D.
Analyst
                                                  Stephen Siegel, CIH- Lab Manager
                                                        Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                 Order ID: 040006832
       Asbestos Analysis via EPA Superfund Method for the Determination of
     Releasable Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:
 Fax:
 Project:
David Nelson
Versar Inc.
6850 Versar Center
PO Box 1549
Springfield, VA 22151
703-642-6809
4600.008/EPA Vermiculite
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58 PM
5/17/00

040006832
                                                       Date Analysis Started
                                                    Date Analysis Completed
                                                              Lab Sample #
                                                    Field Sample ID Number
                                                 Field Prepartation Technique
                                         Additional Lab Preparation Procedures
                                                             Sample Drying
                                                           Sample Splitting
                                                                    Other
                                                             TEM Analysis
                                     Effective Area of Analytical Filter (sq mm)
                                                             Magnification
                                                  Grid Opening Area (sq mm)
                                                    Number of G.O. Scanned
                           Asbestos Structure Size and Type Categories of Interest
                                    Minimum Acceptable Structure ID Category
                                                           Dust Generator
                                                Mass of Sample Tumbled (g)
                    Air Flow Rate Through ME opening of Dust Generator (ml/min)
                    Air Flow Rate Through 1ST opening of Dust Generator (ml/min)
                                             Air Flow Rate Scrubber (ml/min)
                        Estimated Total Air Flow Rate Through Elutriator (ml/min)
                                                                 5/9/00
                                                                 5/10/00
                                                                 040006832-0002
                                                                 90831
                                                                 N/A

                                                                 Yes
                                                                 N/A
                                                                 385
                                                                 19.000X
                                                                 0.0061
                                                                 10
                                                                 >0.5(i Length
                                                                 <0.5n Diameter
                                                                 >5:I Aspect Ratio
                                                                 Amphiboles/Chrysotile
                                                                 >0.5n Length
                                                                 5:1 Aspect Ratio

                                                                 26.1993
                                                                 1500
                                                                 1300
                                                                 N/A
                                                                 1300
                                 Total Mass of Dust Collected on Dust Filters (g)  0.00025
                                 Time of Dust Collection (24 hr clock) at 60 rpm  30 sec
                                                                Start/Stop  N/A
             Estimated first-order rate constants for dust generation (min"1) at 60 rpm  2
       Samples from the Isokinetic Sampling Tube (1ST) Opening of me Dust Generator 60 rpm run
                                              Time of Collection (24 hr clock)  3 0 sec
                                                                Start/Stop  N/A
                                  Estimated Mass of Dust Collected op^fjer (g)  0.00025

A.V. Samudra. Ph. D.
Analyst
                                                 Stephen Siegel, CIH- Lab Manager
                                                       Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                 Order ID: 040006832
  Asbestos Analysis via EPA Superfund Method for the Determination of Releasable
            Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:     David Nelson
          Versar Inc.
          6850 Versar Center
          PO Box 1549
          Springfield, VA 22151
 Fax:      703-642-6809
 Project:   4600.008/EPA Vermiculite

 Client Sample# 90831
 EMSL Sampled 040006832-002

 Chrysotile Asbestos Analysis Results

   No. of Total Chrysotile Asbestos Structures
   No. of Long (>5 urn) Chrysotile Asbestos Structures
   No. of Total Chrysotile Asbestos Fibers/Bundles
   No. of Long (>5 um) Chrysotile Asbestos Fibers/Bundles

 Amphibole Asbestos Analysis Results
   No. of Total Amphibole Asbestos Structures
   No. of Long (>5 um) Amphibole Asbestos Structures
   No. of Total Amphibole Asbestos Fibers/Bundles
   No. of Long (>5 um) Amphibole Asbestos Fibers/Bundles
   Amphibole Mineral Type-
 Customer ID:
 Customer PO:
 Received:
 Report Date:

 EMSL Order:
 EMSL Project ID:
    Low
Magnification
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
 ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN SAMPLE
                                                             Cone.
  Total Chrysotile Structures per g Sample                         <240.90
  Total Amphibole Structures per g Sample                        <240.90
  Total Asbestos Structures per g Sample                          <240.90
  Long Chrysotile Structures per g Sample                         <240.90
  Long Amphibole Structures per g Sample                        <240.90
  Long Asbestos Structures per g Sample                          <240.90
  Estimated Analytical Sensitivity: (structures/g)
      <240.90
ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN RESPIRABLE
DUST OF SAMPLE
  Total Chrysotile Structures per g Dust
  Total Amphibole Structures per g Dust
  Total Asbestos Structures per g Dust
  Long Chrysotile Structures per g Dust
  Long Amphibole Structures per g Dust
  Long Asbestos Structures per g Dust

  Estimated Analytical Sensitivity: (structures/g dust)

A.y, Samudra, Ph.D.
Analyst
       Cone.
   <252,459,016
   <252,459,016
   <252,459,016
   <252,459,016
   <252,459,016
   <252,459,016
VERS96

5/4/00 12:58 PM
5/17/00

040006832
      High
  Magnification
       0
       0
       0
       0
       0
       0
       0
       0
      N/A
    95% UCL
    <472.17
    <472.17
    <472.17
    <472.17
    <472.17
    <472.17

    <472.17
   95% UCL
 <494,819,672
 <494,819,672
 <494,819,672
 <494,819,672
 <494,819,672
 <494,819,672
   <252,459,016     <494,819,672
     Stephen Siegel, CIH- Lab Manager
          Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                 Order ID: 040006832
       Asbestos Analysis via EPA Superfund Method for the Determination of
     Releasable Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:
 Fax:
 Project:
David Nelson
Versar Inc.
6850 Versar Center
PO Box 1549
Springfield, VA 22151
703-642-6809
4600.008/EPA Vermiculite
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58 PM
5/17/00

040006832
                                                        Date Analysis Started
                                                    Date Analysis Completed
                                                              Lab Sample #
                                                    Field Sample ID Number
                                                  Field Prepartation Technique
                                         Additional Lab Preparation Procedures
                                                             Sample Drying
                                                            Sample Splitting
                                                                     Other
                                                             TEM Analysis
                                      Effective Area of Analytical Filter (sq mm)
                                                              Magnification
                                                  Grid Opening Area (sq mm)
                                                    Number of G.O. Scanned
                           Asbestos Structure Size and Type Categories of Interest
                                    Minimum Acceptable Structure ID Category
                                                            Dust Generator
                                                 Mass of Sample Tumbled (g)
                    Air Flow Rate Through ME opening of Dust Generator (ml/min)
                    Air Flow Rate Through 1ST opening of Dust Generator (ml/min)
                                              Air Flow Rate Scrubber (ml/min)
                        Estimated Total Air Flow Rate Through Ehrtriator (ml/min)
                                                                  5/9/00
                                                                  5/10/00
                                                                  040006832-0003
                                                                  90832
                                                                  N/A

                                                                  Yes
                                                                  N/A
                                                                  385
                                                                  19,OOOX
                                                                  0.0061
                                                                  10
                                                                  >0.5u Length
                                                                  <0.5u Diameter
                                                                  >5:1 Aspect Ratio
                                                                  Amphiboles/Chrysotile
                                                                  >0.5u Length
                                                                  <0.5ji Diameter
                                                                  >5:1 Aspect Ratio

                                                                  16.5938
                                                                  1500
                                                                  1300
                                                                  N/A
                                                                  1300
                                 Total Mass of Dust Collected on Dust Filters (g)   0.00011
                                 Tune of Dust Collection (24 hr clock) at 60 rpm   30 sec
                                                                 Start/Stop   N/A
              Estimated first-order rate constants for dust generation (rain"1) at 60 rpm   2
       Samples from the Isokinetic Sampling Tube (1ST) Opening of the Dust Generator 60 rpm run
                                              Time of Collection (24 hr clock)   30 sec
                                                                 Start/Stop   N/A
                                  Estimated Mass of Dust Collected on Filter (g)   0.00011
Aay. Samudra, Ph. D.
Analyst
                                                  Stephen Siegel, CIH- Lab Manager
                                                        Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmoot, NJ 08108
                               Order ID: 040006832
 Asbestos Analysis via EPA Superfund Method for the Determination of Releasable
           Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:     David Nelson
         Versar Inc.
         6850 Versar Center
         PO Box 1549
         Springfield, VA 22151
 Fax:     703-642-6809
 Project:   4600.008/EPA Vermiculite

 Client Sample# 90832
 EMSL Sample* 040006832-003
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58PM
5/17/00

040006832
Chrysotile Asbestos Analysis Results

No. of Total Chrysotile Asbestos Structures
No. of Long (>5 urn) Chrysotile Asbestos Structures
No. of Total Chrysotile Asbestos Fibers/Bundles
No. of Long (>5 Jim) Chrysotile Asbestos Fibers/Bundles
Amphibole Asbestos Analysis Results
No. of Total Amphibole Asbestos Structures
No. of Long (>5 urn) Amphibole Asbestos Structures
No. of Total Amphibole Asbestos Fibers/Bundles
No. of Long (>5 urn) Amphibole Asbestos Fibers/Bundles
Amphibole Mineral Type-
Low
Magnification
N/A
N/A
N/A
N/A

N/A
N/A
N/A
N/A
N/A
High
Magnification
0
0
0
0

0
0
0
0
N/A
ESTTMATED CONCENTRATIONS OF RELEASABLE ASBESTOS EN SAMPLE

Total Chrysotile Structures per g Sample
Total Amphibole Structures per g Sample
Total Asbestos Structures per g Sample
Long Chrysotile Structures per g Sample
Long Amphibole Structures per g Sample
Long Asbestos Structures per g Sample
Estimated Analytical Sensitivity: (structures/g)
ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS
DUST OF SAMPLE

Total Chrysotite Structures per g Dust
Total Amphibole Structures per g Dust
Total Asbestos Structures per g Dust
Long Chrysotile Structures per g Dust
Long Amphibole Structures per g Dust
Long Asbestos Structures per g Dust
Estimated Analytical Sensitivity: (structures/g dust)
A.V. Samudra, Ph,D.
Cone.
<380.35
<380.35
<380.35
<380.35
<380.35
<380.35
<380.35
IN RESPffiABLE

Cone.
<252,459,016
<252,459,016
<252,459,016
<252,459,016
<252,459,016
<252,459,016
<252,459XP16

95% UCL
<745.49
<745.49
<745.49
<745.49
<745.49
<745.49
<745.49


95% UCL
<494,819,672
<494,819,672
<494,819,672
<494,819,672
<494,8 19,672
<494,81 9,672
. <494,819,672

Analyst
    Stephen Siegel, CIH- Lab Manager
          Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                  Order ID: 040006832
       Asbestos Analysis via EPA Superfund Method for the Determination of
     Releasable Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:
 Fax:
 Project:
David Nelson
Versar Inc.
6850 Versar Center
POBox 1549
Springfield, VA 22151
703-642-6809
4600.008/EPA Vermiculite
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/00 12:58 PM
5/17/00

040006832
                                                        Date Analysis Started
                                                     Date Analysis Completed
                                                               Lab Sample #
                                                     Field Sample ID Number
                                                  Field Preparation Technique
                                          Additional Lab Preparation Procedures
                                                              Sample Drying
                                                            Sample Splitting
                                                                      Other
                                                              TEM Analysis
                                      Effective Area of Analytical Filter (sq mm)
                                                              Magnification
                                                  Grid Opening Area (sq mm)
                                                     Number of G.O. Scanned
                            Asbestos Structure Size and Type Categories of Interest
                                     Minimum Acceptable Structure ID Category
                                                            Dust Generator
                                                 Mass of Sample Tumbled (g)
                    Air Flow Rate Through ME opening of Dust Generator (ml/min)
                    Air Flow Rate Through 1ST opening of Dust Generator (ml/min)
                                              Air Flow Rate Scrubber (ml/min)
                        Estimated Total Air Flow Rate Through Elutriator (ml/min)
                                                                  5/9/00
                                                                  5/10/00
                                                                  040006832-0004
                                                                  90833
                                                                  N/A

                                                                  Yes
                                                                  N/A
                                                                  385
                                                                  19,OOOX
                                                                  0.0061
                                                                  10
                                                                  >0.5u Length
                                                                  <0.5(j. Diameter
                                                                  >5:1 Aspect Ratio
                                                                  Amphiboles/Chrysotile
                                                                  >0.5p, Length
                                                                  <0.5(a Diameter
                                                                  >5:1 Aspect Ratio

                                                                  15.2587
                                                                  1500
                                                                  1300
                                                                  N/A
                                                                  1300
                                  Total Mass of Dust Collected on Dust Filters (g)  0.00002
                                  Tune of Dust Collection (24 hr clock) at 60 rpm  30 sec
                                                                 Start/Stop  N/A
              Estimated first-order rate constants for dust generation (rain"1) at 60 rpm  2
       Samples from the Isokinetic Sampling Tube (1ST) Opening of the Dust Generator 60 rpm run
                                              Time of Collection (24 hr clock)  30 sec
                                                                 Start/Stop  N/A
                                  Estimated Mass of Dust Collected on^Filter (g)  0.00002
A.V. Samudra. Ph. D.
Analyst
                                                  Stephen Siegel, CIH- Lab Manager
                                                        Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                 Order ID: 040006832
  Asbestos Analysis via EPA Superfund Method for the Determination of Releasable
            Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:     David Nelson
          Versar Inc.
          6850 Versar Center
          PO Box 1549
          Springfield, VA 22151
 Fax:      703-642-6809
 Project:   4600.008/EPA Vermiculite

 Client Sample# 90833
 EMSL Sample# 040006332-004

 Chrysotile Asbestos Analysis Results

   No. of Total Chrysotile Asbestos Structures
   No. of Long (>5 um) Chrysotile Asbestos Structures
   No. of Total Chrysotile Asbestos Fibers/Bundles
   No. of Long (>5 um) Chrysotile Asbestos Fibers/Bundles

 Amphibole Asbestos Analysis Results
   No. of Total Amphibole Asbestos Structures
   No. of Long (>5 um) Amphibole Asbestos Structures
   No. of Total Amphibole Asbestos Fibers/Bundles
   No. of Long (>5 um) Amphibole Asbestos Fibers/Bundles
   Amphibole Mineral Type-
                                                    Customer ED:
                                                    Customer PO:
                                                    Received:
                                                    Report Date:

                                                    EMSL Order:
                                                    EMSL Project ID:
                                                        Low
                                                    Magnification
                                                        N/A
                                                        N/A
                                                        N/A
                                                        N/A
                                                        N/A
                                                        N/A
                                                        N/A
                                                        N/A
                                                        N/A
 ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN SAMPLE
                                                             Cone.
                                                            <413.63
Total Chrysotile Structures per g Sample
Total Amphibole Structures per g Sample
Total Asbestos Structures per g Sample
Long Chrysotile Structures per g Sample
Long Amphibole Structures per g Sample
Long Asbestos Structures per g Sample

Estimated Analytical Sensitivity: (structures/g)
                                                            <413.63
                                                            <413.63
                                                            <413.63
                                                            <413.63
                                                            <413.63

                                                            <413.63
ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN RESPIRABLE
DUST OF SAMPLE
  Total Chrysotile Structures per g Dust
  Total Amphibole Structures per g Dust
  Total Asbestos Structures per g Dust
  Long Chrysotile Structures per g Dust
  Long Amphibole Structures per g Dust
  Long Asbestos Structures per g Dust

  Estimated Analytical Sensitivity: (structures/g dust)

A.V. Samudra, PbJD.
Analyst
                                                           Cone.
                                                      <3,155,737,705
                                                      <3,155,737,705
                                                      <3,155,737,705
                                                      <3,155,737,705
                                                      <3,155,737,705
                                                      <3,155,737,705
VERS96

5/4/00 12:58 PM
5/17/00

040006832
      High
  Magnification
       0
       0
       0
       0
       0
       0
       0
       0
      N/A
    95% UCL
    <810.72
    <810.72
    <810.72
    <810.72
    <810.72
    <810.72

    <810.72
   95% UCL
<6,185,245,902
<6,185,245,902
<6,185,2^5,902
<6,185,245,902
<6,185,245,902
<6,185,245.902
                                                      <3,155,737,705   <6,185,245,902
                                                        Stephen Siegel, CIH- Lab Manager
                                                              Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, N.J 0810$
                                  Order ID: 040006832
      Asbestos Analysis via EPA Superfund Method for the Determination of
     Releasable Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:
 Fax:
 Project:
David Nelson
Versar Inc.
6850 Versar Center
PO Box 1549
Springfield, VA 22151
703-642-6809
4600.008/EPA Vermiculite
Customer ID:
Customer PO:
Received:
Report Date:

EMSL Order:
EMSL Project ID:
VERS96

5/4/0012:58 PM
5/17/00

040006832
                                                        Date Analysis Started
                                                    Date Analysis Completed
                                                              Lab Sample #
                                                    Field Sample ID Number
                                                  Field Preparation Technique
                                         Additional Lab Preparation Procedures
                                                             Sample Drying
                                                            Sample Splitting
                                                                     Other
                                                             TEM Analysis
                                      Effective Area of Analytical Filter (sq mm)
                                                              Magnification
                                                  Grid Opening Area (sq mm)
                                                    Number of G.O. Scanned
                            Asbestos Structure Size and Type Categories of Interest
                                     Minimum Acceptable Structure ID Category
                                                            Dust Generator
                                                  Mass of Sample Tumble (g)
                    Air Flow Rate Through ME opening of Dust Generator (ml/min)
                    Air Flow Rate Through 1ST opening of Dust Generator (ml/min)
                                              Air Flow Rate Scrubber (ml/min)
                        Estimated Total Air Flow Rate Through Elutriator (ml/min)
                                                                  5/9/00
                                                                  5/10/00
                                                                  040006832-0005
                                                                  90844
                                                                  N/A

                                                                  Yes
                                                                  N/A
                                                                  385
                                                                  19,OOOX
                                                                  0.0061
                                                                  10
                                                                  >0.5u. Length
                                                                  <0.5}i Diameter
                                                                  >5:1 Aspect Ratio
                                                                  Amphiboles/Cbrysotile
                                                                  >0.5ji Length
                                                                  <0.5u. Diameter
                                                                  >5:1 Aspect Ratio

                                                                  29.7354
                                                                  1500
                                                                  1300
                                                                  N/A
                                                                  1300
                                 Total Mass of Dust Collected on Dust Filters (g)   0.00087
                                  Time of Dust Collection (24 hr clock) at 60 rpm   30 sec
                                                                 Start/Stop   N/A
              Estimated first-order rate constants for dust generation (min'1) at 60 rpm   2
       Samples from the Isokinetic Sampling Tube (1ST) Opening of the Dust Generator 60 rpm run
                                              Tune of Collection (24 hr clock)   30 sec
                                                                 Start/Stop   N/A
                                   Estimated Mass of Dust Collected ojn Filter (g)   0.00087
A.V. Samudra. Ph. D.
Analyst
                                                  Stephen Siegel, CIH- Lab Manager
                                                        Or other approved signatory

-------
 EM3L Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                                 Order ID: 040006832
  Asbestos Analysis via EPA Superfund Method for the Determination of Releasable
            Asbestos Fibers in Soils and Bulk Materials- EPA540-R-97-028
 Attn:     David Nelson
          Versar Inc.
          6850 Versar Center
          PO Box 1549
          Springfield, VA 22151
 Fax:      703-642-6809
 Project:   4600.008/EPA Vermiculite

 Client Sampled 90844
 EMSL Sample# 040006832-005

 Chrysotile Asbestos Analysis Results

   No. of Total Chrysotile Asbestos Structures
   No. of Long (>5 um) Chrysotile Asbestos Structures
   No. of Total Chrysotile Asbestos Fibers/Bundles
   No. of Long (>5 um) Chrysotile Asbestos Fibers/Bundles

 Amphibole Asbestos Analysis Results
   No. of Total Amphibole Asbestos Structures
   No. of Long (>5 (im) Amphibole Asbestos Structures
   No. of Total Amphibole Asbestos Fibers/Bundles
   No. of Long (>5 um) Amphibole Asbestos Fibers/Bundles
   Amphibole Mineral Type-
 Customer ID:
 Customer PO:
 Received:
 Report Date:

 EMSL Order:
 EMSL Project ID:
    Low
Magnification
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
    N/A
 ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN SAMPLE
                                                             Cone.
  Total Chrysotile Structures per g Sample                         <212.25
  Total Amphibole Structures per g Sample                        636.76
  Total Asbestos Structures per g Sample                          636.76
  Long Chrysotile Structures per g Sample                         <212.25
  Long Amphibole Structures per g Sample                        212.25
  Long Asbestos Structures per g Sample                          212.25
  Estimated Analytical Sensitivity: (structures/g)
      <212.25
ESTIMATED CONCENTRATIONS OF RELEASABLE ASBESTOS IN RESPIRABLE
DUST OF SAMPLE
  Total Chrysotile Structures per g Dust
  Total Amphibole Structures per g Dust
  Total Asbestos Structures per g Dust
  Long Chrysotile Structures per g Dust
  Long Amphibole Structures per g Dust
  Long Asbestos Structures per g Dust

  Estimated Analytical Sensitivity: (structures/g dust)

A.V. Samudra. Ph.D.
Analyst
       Cone.
    <72,545,694
    217,637,083
    217,637,083
    <72,545,694
    145,091,389
    145,091,389
 VERS96

 5/4/00 12:58 PM
 5/17/00

 040006832
      High
  Magnification
        0
        0
        0
        0
        3
        2
        0
        0
Actinolite/Richterite
    95% UCL
     <416.02
     1248.06
     1248.06
     <416.02
     416.02
     416.02

     <416.02
    95% UCL
  <142,189,561
  426,568,683
  426,568,683
  <142,189,561
  284,379,122
  284,379,122
    <72,545,694     <142,189,561
     Stephen Siegel, CM- Lab Manager
          Or other approved signatory

-------
Sample
1ST Port
            90813
ME Port
1
5
10
30
60
Sample wt
0.045
0.239
0.237
0.319
0.221
Tare
19.581
19.178
18.449
18.379
18.379
Final
19,626
19.417
16.686
16.698
186
             0.043
           18,598   18.641




ise / Minute
1 0.045
5 0.0478
10 0.0237
v\ n m nsiiTn
60 0.003683333



n n*\

n 04 -
fl fYW -
n n**
ft iws
n no -
nnm
n m -
nnna -
n -
c

*^
I
\
\
\
\
\^^
^^"^K^^
<""~"'~-— -— ^- .,
'— ^
) 10 20 30 40 50 60 7











0
Sample
1ST Port
90831
 0.025
                                                     Release / Minute
ME Port
1
5
10
30
60
Sample wt
0.033
0,05
0.058
0.075
0111
Tare
19.029
20.514
17.84
18.782
18.749
Final
19.062
20.564
17,898
1 8,857
18.86
                                                          1
                                                          5
                                                          10
                                                          30
                                                          60
                                                       0.033
                                                        0.01
                                                       0.0058
                                                       0,0025
                                                      0.00185
18.785     18.81
                                                                                               10       20       30       40       50       60       70

-------
Sample
1ST Port
            90832
ME Port
1
5
10
30
60
Sample wt
0.018
0.044
0,043
0.101
0.088
Tare
19.683
19.448
19.432
19.901
20.375
Final
19.701
19.492
19.475
20.002
20,463
0.011
19.152   19,163
                                                    Release / Minute
                                                          1
                                                          5
                                                         10
                                                         30
                                                         60
                                                       0.018
                                                      0.0088
                                                      0.0043
                                                    0.003366667
                                                    0.001466667
                                                                                                10
                                                                                            20
                                                                                           30
40
Sample
1ST Port
             90833
ME Port
1
5
10
30
60
Sample wt
0.006
0,01
0.018
0.016
0.01
Tare
18.305
19.439
19.444
20.982
19.583
Final
18.311
19.449
19.462
20,998
19.593
             0.002
                        18.989   18.991

Release / Minute

1 0.006
U.UUz
10 0.0018
30 0.000533333
60 0.000166667





rt nc



n m -

n m -
t\ M*\ -
n r\4
n rvw -

(









^
^*— ^-— —- i
3 10 20 30 40 50 60 7











0

-------
Sample
             90844
                                                      Release / Minute
ME Port
1
5
10
30
60
Sample wt
0.04
0.074
0.091
0.097
0.098
Tare
19.254
19.582
19.511
19.886
20.404
Final
19.294
19.656
19.602
19.963
20.502
                                                           1
                                                           5
                                                           10
                                                           30
                                                           60
                                                         0.04
                                                        00148
                                                        0.0091
                                                     0.003233333
                                                     0.001633333
1ST Port
0.087
20.502    20.589
                                                                                    0.05 T	
                                                                                   0.045
                                                            0.04
                                                           0.035
                                                            0.03
                                                           0.025
                                                            0.02
                                                           0.015

-------
   EMSL Analytical, me	
   107 K>Mw Al*, WeiOUMt, NJ 0*108
  Aim:
  Fax;
                             Order H>: 040008582
Linda Phillips/David Nelson
VersarJjoc.
6850 Versar Center
K> Box 1549
Springfield, VA 22151
703^42-6809
  Project:   4600.00S/EPA Vermiculite
                                               Customer ID:
                                               CdstomerPO:
                                               Received:
                                     EMSL Order:
                                     EMSL Project ID:
       VERS96

       06/01/00 3;OOPM



       040008582
    Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Analytical
                                   Electron Microscopy
     Client
   Sample IP
     90831

     90844
     90847
             EMSL
            Sample ID
          040008582-1
          040008582-2
          040008582-3
Aabeatos
—.?V. Jg -^
 BQL*

 BQL
 BQL
Asbestos Type(s)    Aahed / Not Ashed
    ND**
     ND
     ND
Not Ashed
Not Ashed
Not Ashed
 This analysis is on fine portion of sample after sieving with #1Q and #35 sit

 K**
 *BQL= Below Qaantitetion JJmh (0.1 wdglrt%)
 **ND-- None Detected                S    )
A.V. Samndra. Ph. D
TEMAnafyst
                                                       Stephen Sieget, Off- Lab Manager
                                                            Or other approved signatory

-------
   EMSL Analytical, Inc.
   1*7 H*.J
-------
                                                                                        4605
t \ f BOJICf MO
». I /y   .  _
           01
                                         CHAIN OF CUSTODY RECORD

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
 Attn:
 Fax:
                             Order ID: 040009370
Linda Phillips/David Nelson
Versar Inc.
6850 Versar Center
PO Box 1549
Springfield, VA 22151
703-642-6809
 Project:   4600.005/EPA Vermiculite
                                                Customer ID:
                                                Customer PO:
                                                Received:
                                       EMSL Order:
                                       EMSL Project ID:
                      VERS96

                      06/14/00 9:54 AM



                      040009370
   Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Analytical
                                    Electron Microscopy
    Client
  Sample ID
              EMSL
            Sample ID
Asbestos
Weight%
 Asbestos Type(s)    Ashed / Not Ashed
    68194
           040009370-1
  BQL*
Tremolite/Actinolite
                                                                                Not Ashed
 •   This result is for TEM of fine portion of sample.

 •   Asbestos amount in original sample based on this value, and ND in coarse and medium portions (by
    PLM) is <0.02% Tremolite/Actinolite.

 •   The samples was sieved to coarse, medium, and fine portions using #10 and #35 sieves.
 *BQL = Below Quantitation Limit (0.1 weight%)
A.V. Samudra, Ph. D
TEMAnalyst
                                                 Stephen Siegel, CIH- Lab Manager
                                                       Or other approved signatory

-------
 EMSL Analytical, Inc.
 107 Haddon Ave., Westmont, NJ 08108
                              Order ID: 040009370
 Attn:
 Fax:
         Linda Phillips/David Nelson
         Versar Inc.
         6850 Versar Center
         PO Box 1549
         Springfield, VA 22151
         703-642-6809
Project:   4600.005/EPA Vermiculite
                                                  Customer ID:
                                                  Customer PO:
                                                  Received:
                                                  EMSL Order:
                                                  EMSL Project ID:
VERS96

06/14/00 9:54 AM



040009370
 EPA Protocol for Screening Soil and Sediment Samples For Asbestos Content Used
                by USEPA, Region 1 Laboratory (Rev May 24,1994)
                          Modified by EMSL (Sept 1999)
Client Sample ID

68194
EMSL Sample
ID
040009370-1
Location

ox ""
Asbestos
<0.19%Tremolite
 •   Samples were sieved to coarse, medium, and fine portions using #10 and #35 sieves.

 •   Final Asbestos result reported is based on ND in coarse and medium portions, <1%
    Tremolite in fine portion by PLM.
Scott Combs
Analyst
                                                     Stephen Siegel, CIH- Lab Manager
                                                          Or other approved signatory

-------
Vfcr/wir
                                                                                                                       4596
                                                                                                                      INDUSTRIAL
                                                                                                                    HYGIENE SAMPLE
                                                     CHAIN OF CUSTODY RECORD
                                                                                                                         ~OT
                              Date / Time
            Received by: (Signature)
                                                                    Relinquished by: (Signature)
                                                                    Date / Time
                                                                   Received by: (Signature)
                                          (Printed)
                                       (Printed)
                                   isao
                                                                                                             (Printed)
Relinquished by: (Signature)
(Printed)
Date / Time
Received for Laboratory by:
Date / Time  Remarks
                                          (Printed)

-------
   EMSL Analytical, Inc.
   107 Haddon A vs., Westmont, NJ 08108

   Phone: (608)868-4800    Fax: (609) 858-4960   Email:  aslegeieEIVlSL.cofn
   Attn:     Linda Phillips/Dave Nelson
            Versar Inc.
            6650 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax:      705-642-6809
   Project:   4601.OOS/EPAWIMS ATT
               Phone:  703-642-6889
       Customer ID:       VERS96
       Customer PO:
       Received:          05/26/00 12:17 PM


       EMSL Order:       040008279
       EMSL Project ID:
       Analysis Date:        5/30/2000
   Asbestos Fiber Analysis by Transmission Electron  Microscopy (TEM), Selected Area Elec
                                      Diffraction (SAED), and  Energy Dispersive
                        X-Ray Microanalysis (EDX) - Performed by EPA Level II Method.
Sample
Volume    Asbestos        # Structures
(liters)      Type(t)     Asbestos    Non-Asb.
     Analytical
     Sensitivity
       (S/cc)
                                                                                  Concentration
(S/mm>)
                                                                        S/cc   Notes
 AMS-001-A

 040008279-0001
  1264   Amosite
                                                1
                                               0.0050
                                                             16.39
                                                                        0.0050  Kber Is greater than 5 microns in
                                                                                length
 AMS-002-A

 040008279-0002
  1330   None Detected
        0.0047
                                                                       <0.0047
 AMS-003-A

 040003279-0003
   337  None Detected
0       0.0187        <16.39      <0.0187
 AMS-004-A

 040008279-0004
   355  None Detected
0       0.0178        <16.39      <0.0178
 AMS-005-A

 040008279-0005
   359  None Detected
        0.0176        <16.39      <0.0176
 AMS-006-A

 040008279-0006
   355  None Detected
0       0.0178        <16.39      <0.0178
 AMS-007-A

 040008279-0007
    63  None Detected
        0.1002        <16.39      <0.1002
 AMS-008-A

 040008279-0008
    63  None Detected
                                              0.0998        -=16.39      <0.0998
 Anant Samudra
 Analyst
                                                                                            Stephen Siegel, CIH
                                                                                         or other approved signatory
  Disclaimers: The laboratory is not responsible tor data reported in strucrures/cc, which is dependent on volume collected by non-laboratory personnel. This report may not be
  ••••-"—•"••, except in full, without written permission by EMSL Analytical, Inc. This report must not be used to claim product endorsement by NVLAP or any agency of the U.S.
        •-*• This report relates only to the samples reported above. Quality control data (including 95% confidence limits and laboratory and analysts' accuracy and precision) is
         "i request.
        far NVUVP PLM/TEV #101048-0, NY ELAP *10872
                                                                                                                     PTOR1

-------
   EMSL Analytical,  Inc.
   107 Haddon Ave., Westmont, NJ 08108
   Phone: (809)86^*800    Fax: (609)868-4860  Email:  sslegel@EMSL.com
   Attn:     Linda Phillips/Dave Nelson
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax      703-542-6809              Phone:  703-642-6889
   Project:   4601.005/EPA WIMSATT
                                                      Customer ID:      VERS96
                                                      Customer PO:
                                                      Received:         05/26/00 12:17 PM


                                                      EMSL Order.      040008279
                                                      EMSL Project ID:
                                                      Analysis Date:     5/29/2000
                  Fiber Analysis of Air Samples via NIOSH 7400, Revision 3, Issue 2, 8/15/94
 Sample
Location
                                        LOO      Fibers/     Fibers/
Sample Date    Volume Fiber*  Fields     (fib/cc)      nun'        cc   Notes
 AMS-001-A
 040008279-0001
                        5/25/2000    1264.40   16.0   100       0.002      20.38     0.006
AMS-002-A
040008279-0002
                        5/25/2000   1329.75    6.5   100       0.002       8.28     0.002
AMS-003-A
040008279-0003
                        5/25/2000    337.18   10.0   100       0.008      12.74     0.015
AMS-004-A
040008279-0004
                        5/25/2000    354.60   <5.5   100       0.008       <7.0     <0.008
AMS-005-A
040008279-0005
                        5/25/2000    358.52   <5.5   100       0.008       <7.0     <0.008
AMS-006-A
040008279-0006
                        5/25/2000     355.46   <5.5    100       0.008       <7.0     <0.008
AMS-007-A

040008279-0007
                        5/25/2000      63.00   <5.5    100       0.043       <7.0     <0.043
AMS-008-A
040008279-0008
                        5/25/2000      63.21   <5.5    100       0.043       <7.0    <0.043
AMS-009-A
040008279-0009
                        5/25/2000       0.00   <5.5    100
                                                                          <7.0
                                                                                         Field Blank
AMS-010-A
040008279-0010
                        5/25/2000       0.00   <5.5    100
                                                                          <7.0
                                                                                         Field Blank
AMS-011-A
040008279-0011
                        5/25/2000       0.00   <5.5    100 •
                                                                          <7.0
                                                                                                         Field Blank
 Tom Beer
 Analyst
                                                                                                  Stephen Siege!, CIH
                                                                                               or other approved  signatory
  Limit of detection is 7 fibers/mm5. The laboratory is net responsible for data reported in fibers/cc, which is dependent on volume collected by non-laboratory personnel. This report
  relates onry to the samples reported above. This report may not be reproduced, except in full, without written approval by EMSL.
  Analysis performed by EMSL Westmont (NY State ELAP #10872}
                                                                                                                            1 o(2

-------
   EMSL Analytical, Inc.
   107 Haddon Ave., Westmont, NJ 08108
   Phone: (609)858-4800	Fax: (609)858-4360  Email:  S5iegel@EMSl..eom
  Attn:     Linda Phillips/Dave Nelson
           Versar Inc.
           6850 Versar Center
           PO Box 1549
           Springfield, VA 22151
  Fax:      703-642-6809
  Project:   4601.005/EPA W1MSATT
                   Phone:  703-642-6889
                                                   Customer ID:       VERS96
                                                   Customer PO:
                                                   Received:          05/26/00 12:17 PM
                                                   EMSL Order:       040008279
                                                   EMSL Project ID:
                                                   Analysis Date:      5/29/2000
Sample
Fiber Analysis of Air Samples via NIOSH 7400,  Revision 3, Issue 2, 8/15/94


                    Sample Date    Volume Fibers   Fields
Location
 LOD

-------
                                                                                                                                4610
                                                          CHAIN OF CUSTODY RECORD
 PROJECT NO.
PROJECT NAME
      FIELD
     SAMPLE
     NUMBER
                              STATION LOCATION
HelinauifKeii by/ (Signature)
                           Received by: (Signature)
                                                                          Relinquished by: (Signature!
                                                                                                   Received by: (Signature)
Relinquished by: (Signature)
                          Received for Laboratory by:
Oiitribution: Oriainal Plui One Accomoanies Shiomant (white anri

-------
 Iferaar.
                             ASBESTOS AIR SAMPLE DATA
Versar Job No..
Project Manager,
Date: 5  IZSICO      	
Collection Method:/*£y/-y»W.gy>
Sample Media: • *s'/.9v*te _z
-------
 Vcrauir-
                          ASBESTOS AIR SAMPLE DATA
Versar Job No.	
Project Manager.
Date: 4 Itfl0P Shift-
                                               Client
Collection Method;
Sample Media:
               T
                       ftbe/gfa &&&1-
                                               Sample
                                               Samples Collected bv:
                                             Analyze for gramas/ '*f#esszx
                                             Temp:  74*       /Rel Humid:
                                   SAMPLE DATA
 Sample No.
 Pump No.
 Time On
 Time Off
 Total Time (min.)
 Flow Rate (LPM)
                    2.
 Volume (liters)
                    6,5
 Fibers/Fields
 Detection Limit
 Results f/cc
Analyst
QC Recounts (f/cc)
QC Analyst


















                                 SAMPLE LOCATION
Sample No.
/4#/-^??tf
4fu$ -&%'/%






/&£*&#^QO #***&*&&&
/&fOV*^ats Mv&a JtStStKJ i





HT
*s*
A?au
*f*J£





LOG
'*J^
* -£





TYP
P
f*





PM
)^)
//"I





ABT
	
	 .





SAM
1/4






Height (HT)
Location (LOG): 1 ~ Inside Work area 0 = Outside work area
Type (TYP): G = General Area P = Persona* A = Ambient B = Field Blank
Phase (PH): S = Pre-Start R = Removal E = Establish Containment C = Cleanup F = Final air
Abatement (ABT): FP = Fireproofing CT = Ceiling Tiles FT = Floor Tiles Bi = Boiler
„ TP = Transite Panel AC = Acoustical Ceiling Texture M = Adhesive Mastics
T R = Roofing Materials PI = Pipe Lagging j« - m i iLfM*
Sampling (SAM): AG = Aggressive NA = Non-Aggressive
Note: Ail Personal Samples Must Have Worker Name and Social Security Number.
Comments:

-------
    EMSL Analytical, inc.
    107 Haddon Ave., Westmont, NJ 08108
    Phone: (609)868-4800    Fax: (609)858-4860   Email:  ssiegel@EMSL.com
   Attn:     David Nelson
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax:      703-642-6809
   Project:   4601.005
             Phone:  703-642-6889
                                           Customer ID:      VERS96
                                           Customer PO:
                                           Received:         05/27/00 9:41 AM
                                           EMSL Order      040008375
                                           EMSL Project ID:
                                          Analysis Date:        5/30/2000
   Asbestos Fiber Analysis by Transmission Electron Microscopy (TEM), Selected Area
                         Electron  Diffraction (SAED), and Energy Dispersive
                 X-Ray Microanalysis (EDX) - Performed by EPA Level II Method.
Sample
Volume    Asbestos
(liters)      Typefs)
                       ff Structures
                    Asbestos    Non-Asb.
Analytical
Sensitivity
  (S/cc)
                                                                                  Concentration
                                                         (S/mm1)
                                                                        S/cc    Notes
AMS-013A

040008375-0017
359   None Detected
                                             0.0176         <16.39     <0.0176
AMS-014A

040008375-0018
365   Nont Detected
                                             0.0173        <16.39     <0.0173
AMS-015A

040008375-0019
355   None Detected
                                             0.0178        < 16.39     <0.0178
AMS-016A

040008375-0020
337   None Detected
                                             0.0187        <16.39     <0.0187
AMS-017A

040008375-0021
 67   Tremolite
                                   2       0.0935          1639      00935   Fiber is greater than 5 microns in
                                                                             length
AMS-018A

040008375-0022
 30  None Detected
                                            0.1047
                                                          <16.39     <0.1047
AMS-019A '

040008375-0023
378  None Detected
                                            0.0167        <16.39     <0.0167
AMS-020A              375  None Detected

040008375-0024
                                           0.0168        <16.39     <0.0168
AMS-021A

040008375-0025
276  None Detected
                                            0.0229        <16.39     <0.0229
 Anant Samudra
 Analyst
                                                                                           Stephen Siegel, CIH
                                                                                        or other approved signatory
  Disclaimers: The laboratory is not responsible for data reported in structures/cc, which Is dependent on volume collected by non-laboratory personnel. This report may not be
  duplicated, except in full, without written permission by EMSL Analytical, Inc. This report rnust not be used to claim product endonsement by NVLAP or any agency at the U S
         -" This report relates only to the samples reported, above. Quality control data (including 95% confidence limits and laboratory and analysts' accuracy and precision) is
           irequest
           NVLAP PLM/TEM#101048-0, NY£LAP#10872
                   level 11-1
                                                                                                                     Page 1

-------
  EMSL Analytical, Inc.
  107 Kaddon Ave., Westmont, NJ 08108
  Phone: (609)858-4800    Fax: (609)868-4960  Email:  ssiegeieEMSL.com
  Attn:    David Nelson
          Versar Inc.
          6850 Versar Center
          PO Box 1549
          Springfield, VA 22151
  Fax:     703-642-6809
  Project:  4601.005
Phone:  703-642-6889
                             Customer ID:
                             Customer PO:
                             Received:
VERS96
                                              05/27/00 9:41 AM
                             EMSL Order       040008375
                             EMSL Project ID:
                            Analysis Date:        5/30/2000
 Asbestos Fiber Analysis by Transmission Electron Microscopy (TEM), Selected Area
                       Electron Diffraction (SAED), and Energy Dispersive
               X-Ray Microanalysis (EDX) - Performed by EPA Level II Method.
Sample
AMS-022A
040008375-0026
AMS-022A
040008375-0033
AMS-023A
040005375-0027
AMS-023A
040008375-0034
AMS-024A
040008375-0028
AMS-024A
040008375-0035
Volume Asbestos
(liter*) Type(s)
328 Actinolfte
328 Actinolite
67 Actinolite
67 Actinolite
61 Actinolite
61 Actinolite
Analytical
# Structures .«,„? itivjiy
Asbestos Non-Asb. (S/cc)
5 0 0.0192
4 0 0.0192
8 0 0.0942
7 0 0.0942
6 0 0.1043
4 0 0.1043
Concentration
(S/mm>)
81.97
65.57
131.15
114.75
98.36
65.57
S/cc
0.0961
0.0769
0.7536
0.6594
0.6255
0.4170
Notes
This result is for all length fibers.
This result is for fibers 5 microns a
greater in length.
This result is for all fiber lengths.
This result is for fibers 5 microns a
greater in length.
This result for all fiber lengths.
This result is for fibers 5 microns a
greater in length.
Anant Samudra
Analyst
                                                                                       Stephen Siegel, CIH
                                                                                    or other approved signatory
 Disclaimers: The laboratory is not responsible for data reported in structures/cc. which is dependent on volume collected by non-laboratory personnel. This report may not be
 duplicatqf, except in full, without written permission by EMSL Analytical, Inc. This report must not be used to claim product endorsement by NVLAP or any agency of the U.S.
         This report relates only to the samples reported above. Quality control data (including 95* confidence limits and laboratory and analysts' accuracy and precision) is
         \ request
       for NVLAP PLM/TEM #101048-0, NY 6LAP #10872
                  Level 11-1
                                                                                                                Page 2

-------
   EMSL Analytical, Inc.
   107 Haddon Ave., Westroont, NJ 08108
   Phone: (603)85S4800    Fax: (609)858-4960  Email:  sslegdeEMSL.com
   Attn:     David Nelson
           Versar Inc.
           6850 Versar Center
           PO Box1549
           Springfield,  VA 22151
   Fax:     703-642-6809
   Project:  4601.005
                     Phone:  703-642-6889
                                                      Customer ID:      VERS96
                                                      Customer PO:
                                                      Received:         05127/00 9:41 AM
                                                      EMSL Order:      040008375
                                                      EMSL Project ID:
                                                      Analysis Date:      5/30/2000
          Fiber Analysis of Air Samples via NIOSH 7400,  Revision 3, Issue 2,  8/15/94
 Sample
Location
                                        LOD      Fibers/     Fibers/
Sample Date    Volume Fibers  Fields      (fih/cc)      mm1       cc   Notes
AMS-013-A
040008375-0007
                        5/25/2000    358.52   <5.5   100       0.008       <7.Q    <0.008
AMS-014-A
040008375-0002
                        5/25/2000    365.34   <5.5   100       0.007       <7.0    <0.007
AMS-015-A
040008375-0003
                        5/25/2000    354.60   34.0   100       0.008      43.31      0.047
AMS-016-A
040008375-0004
                        5/25/2000     337.18   18.5   100       0.008      23.57      0.027
AMS-017-A
040008375-0005
                        5/25/2000      67.47   51.0   100       0.040      64.97      0.371
AMS-018-A
040008375-0006
                        5/25/2000      60.30   15.0   100       0.045      19.11      0.122
AMS-019-A
040008375-0007
                        5/25/2000     378.40    9.5    100       0.007       12.1      0.012
AMS-020-A
040008375-0008
                        5/25/2000     375.21    8.0    100       0.007      10.19      0.011
AMS-021-A
0400083754009
                        5/25/2000     276.09   <5.5    100       0.010      <7.0     <0.010
AMS-022-A
040008375-0010
                        5/25/2000     328.49   72.0    100       0.008     91.72     0.108
AMS-023-A
040008375-0011
                        5/25/2000      62.00   61.0    100       0.043     77.71     0.482
 Tom Beer
 Analyst
                                                                                  Stephen Siege), CIH
                                                                               or other approved signatory
  Limit of detection is 7 fibers/mm2. The laboratory is not responsible for data reported in fiberefcc, which is dependent on volume collected by non-laboratoiy personnel. This report
  relates only to the samples reported above. This report may not be reproduced, axcept in full, without written approval by EMSL
  Analysis performed by EMSL Weslmont (NY State B-AP #10872)
                PCM-1
                                                                                                                            1 Of 2

-------
   EMSL Analytical, Inc.
   107 Haddon Ave., Westmont, NJ 08108
   Phone:(609)858-4800    Fax:(609)858-4960  Email:  sstegeieEMSL.com
  Ann:     David Nelson
           Versar Inc.
           6850 Versar Center
           PO Box 1549
           Springfield, VA 22151
  Fax;     703-642-6809
  Project:   4601.005
                     Phone:  703-642-6889
                                                     Customer ID:       VERS96
                                                     Customer PO:
                                                     Received:          05/27/00 9:41 AM
                                EMSL Order
                                EMSL Project ID:
                                Analysis Date:
                                                                       040008375
                                                                                      5/30/2000
          Fiber Analysis of Air Samples via NiOSH 7400, Revision 3, Issue 2, 8/15/94
Sample
Location
                                        LOD      Fibm/    Fibers/
Sample Dote    Volume Fibers  Fields     (fib/cc)      mm1       cc   Nata
AMS-024-A

0400083754012
                        5/25/2000     60.54   42,5    100       0.044     54.14     0.344
AMS-025-A

040008375-0013
                                       5/25/2000
                                              <5.5    100
                                                     <70
                                                                                                        Field Blank
AMS-026-A

040008375-0014
                                       5/25/2000
                                              <5.5    100
                                                                          <7.0
                                                                                                        Field Blank
AMS-027-A

040008375-0015
                                       5/25/2000
                                              <5.5    100
                                                     <7.0
                                                                                                        Field Blank
AMS-028-A

040008375-0016
                        5/25/2000
                                              <5.5    100
                                                                          <7.0
 Tom Beer
 Analyst
                                                                                  Stephen Siegel, CIH
                                                                               or other approved signatory
  Limit of detection is 7 fibers/mm". The laboratory is not responsible for data reported in tibere/cc, which is dependent on volume collected by non-laboratory personnel. This report
  relates only to the samples reported above. This report may not be reproduced, except in full, without written approval by EMSL
  Aralysis performed by EMSL Westmont (NY State ELAP #10872)
                PCM-1
                                                                                                                           2 of 2

-------
                                                           CHAIN OF CUSTODY RECORD
                                                                                                                                    4595
              t
                                 Due / Time
                                       fflt>
              ReceJMd by: (Signature)
                              Q A
                              Relinquished by: (Signature)
                                               Printed)
                                                                   I 7. M
                                                                            (Printed)
                                                                            o
Date / Time
                                          Received by: (Signature)
                                                                                         (Printed)
Relinquished by: (Signature)
(Printed)
Date / Time
Received fori^aterattiry by:
(Signature)
Date / Time   Remarks
                                               (Printed)
            tinat Pin* r*r*

-------
                                                   CHAIN OF CUSTODY RECORD
   ted)
Relinquished by: (Signature)
 (Primed)
                            Date / Time
                           wA
      (XPrinted)
/ Time
 by: (Signature)/)
juwR
Received for Laboratory b_y;

         i '•. • U '  -i
                                        (Printed)
                                                                 Relinquished by: (Signature)
                                                                 (Printed)
                      Date / Time   Remarks
                                                            Date / Time
                                                                                                                4611
                                                                                                                INDUSTRIAL
                                                                                                              HYGIENE SAMPLE
                                                                Received by: (Signature)
                                                                                                        (Printed)
ni«f rihiif inn • Orinlnnl Pine
                         nipc 
-------
 Ifrrsar-
Versar Job No.
Project
Date:
                             ASBESTOS AIR SAMPLE DATA
                                                    Client:
                  Shift:
                                                    Sample Location:
 Collection Method: A//&t# <74k&/£jt# tetrgtzC
 Sample Media:. v6~/.  3u&g.  2
                 T
Samples Collectedly:
Analyze for:
Temo:
                                                                     JRel. Humid:
                                        SAMPLE DATA
Analyst
QC Recounts (f/cc)
QC Analyst


















                                     SAMPLE LOCATION
   Sample No.
                                                                  HT
                                                                      LOG
                                                                           TYP
                                                                                PH
                                                                                    ABT
                                                                           A
                                                                      a
                                                                          A
                                                                      ~r
A
                                                                               Hi
                                     W
                                                                   '0
                                                                          A
                                                                        r
Height (HT)
Location (LOG):
Type (TYP):
Phase (PH):
Abatement (ABT):
Sampling (SAM):
                I = Inside Work area  O = Outside work area
                G = General Area  P = Personal  A = Ambient  B = Field Blank
                S = Pre-Start  R = Removal   E = Establish Containment   C = Cleanup   F = Final air
                FP = Fireproofing  CT = Ceiling Tiles   FT = Floor Tiles   Bi = Boiler
                TP = Transite Panel   AC = Acoustical Ceiling Texture   M = Adhesive Mastics
                R = Roofing Materials  PI = Pipe Lagging   /yj_-
                AG = Aggressive   NA = Non-Aggressive
Note: Ail Personal Samples Must Have Worker Name and Social Security Number.
Comments:
L:\TEMPLATBASBESTOS\AASD.TMP

-------
                             ASBESTOS AIR SAMPLE DATA
Versar Job No.
Project Manager /&#£#
Date:^ ll^l #p  Shift:
                                                   Client
                                                   Sample Location:
Collection Method :
Sample Media: .
                                 /£*&-
Samples Collected by:
Analyze for:
Temp:  *7l*_ _ IRei Humid:
                                       SAMPLE DATA
 Sample No.
                                                                                           J
 Pump No.
 Time On
 Time Off
                                                         /rf/
 Total Time (min.)
 Flow Rate (LPM)
                      f.
 Volume (liters)
 Fibers/Fields
 Detection Limit
 Results f/cc
Analyst
QC Recounts (f/cc)
QC Analyst


















                                    SAMPLE LOCATION
                                                                HT
                                                                     IOC
                                                                          TYP
                                                                               PH
                                                                                   ABT
                                                                                        SAM
                                                                      a
                                                                                      JLW
                                                               ft
                                                                    o
                       A
ytf
                                                                     -r:
                                                                         A
                                                                         A
Height (HT)
Location (LOG):
Type (TYP):
Phase (PH):
Abatement (ABT):
Sampling (SAM):
                I = Inside Work area   O = Outside work area
                G = General Area   P = Personal   A = Ambient  B = Field Blank
                S = Pre-Start  R = Removal  E = Establish Containment   C = Cleanup   F = Final air
                FP = Fireproofing  CT = Ceiling Tiles  FT = Floor Tiles   Bi = Boiler
                TP = Transite Panel  AC = Acoustical Ceiling Texture   M = Adhesive Mastics
                R = Roofing Materials   PI = Pipe Lagging
                AG = Aggressive  NA = Non-Aggressive
Note: All Personal Samples Must Have Worker Name and Social Security Number.
Comments:
I -\TFMPI ATFVASRPSTnRVAASn TMP

-------
 Ifrraar.
 Versar Job No. _
 Project Manager^
 Date: 4 12&I6& Shift:
                              ASBESTOS AIR SAMPLE DATA
                                   Client:
 Collection Method:
 Sample Media:  , «/j~ / /
                                   Sample
                                   Samples Collected by:.
                                   Analyze for:./1
                                   Temp: "7?^	/ReL Humid
                                        SAMPLE DATA
 Sample No.
 Pump No.
 Time On
 Time Off
 Total Time (min.)
 Flow Rate (LPM)
 Volume (liters)
 Fibers/Fields
 Detection Limit
 Results f/cc
Analyst
QC Recounts (f/cc)
QC Analyst


















                                     SAMPLE LOCATION
   Sample No.
                                                                  HT   LOC  TYP   PH   ABT  SAM
Height (HT)
Location (LOC):
Type (TYP):
Phase (PH):
Abatement (ABT):
I = Inside Work area  O = Outside work area
G = General Area  P = Personal  A = Ambient   B = Field Blank
S = Pre-Start   R = Removal   E = Establish Containment  C = Cleanup
FP = Ftreproofing  CT = Ceiling Tiles   FT = Floor Tiles   Bi = Boiler
TP = Transite Panel   AC = Acoustical Ceiling Texture   M = Adhesive Mastics
R = Roofing Materials  PI = Pipe Lagging
AG = Aggressive   MA = Non-Aggressive
F = Final air
Sampling (SAM):

Note: All Personal Samples Must Have Worker Name and Social Security Number.
Comments:
L :\TEMPLATSASBESTOS\AAS D. TM P

-------
   07/14/2800   13:52
                           8568584960
EMSL ANALYTICAL  INC
PAGE   02
  EMSL Analytical, Inc.
  107 HadflOtl Av»., Ws»t«nont, NJ 0»1M
  Phone: (8091»S8-4800
Attn:    Linde Phillips/Dave Nelson
        Versar Inc.
        6850 Vsraar Center
        PO Box 1549
        Springfield. VA 22151
Fax:     703-642^808            Phone: 703-642-6889

Project  4801.006/EPA V«rmicullt»
                                                            Customer ID:     VERS96
                                                            Customer PO:
                                                            Racelved:        07/12/0010:17 AM


                                                            EMSL Order:     040011455
                                                            EMSL Project ID:
                                                           Analysis Date:      7/13/2000
  Asbestos
             Fiber Analysis by Transmission Electron Microscopy (TEM), Selected Area
                     Electron Diffraction (SAED), and Energy Dispersive
              X-Ray Microanalysis (EDX) - Performed by EPA Level  II Method.
                   Volume
                                           * Structures
Sample
                             1)pt(3)     Asbatot
                                                         Analytical
                                                         Sensitivity
                                                                       (S/mm')
                                                                                     S/cc
AMS-040-A

0400114 B5-OOCH
                   1124  Non« Detected
                                                             0.0058       <16.39     <0-OQS6
AMS-041-A

Q400114SS-0002
                          None Detected
                                                             0.0053       <16.39     <0.0053
AMS-042-A 403 Nona Detected
04001 14&S4003
AMS-043-A 424 None Detected
OW01146BJM04
AMS-044-A 448 None Detected
04001 USS-0005
AMS-045-A 444 None Detected
040011466-0008
AMS-047-A 56 None Detected
0400114553)007 .
0 2.6341 <2755.20 <2.6341 Saitpta ww «™ly»d by mtfred
prop, am and rnuapeno. 2K of
Mtnpl* ld. i% of
•arnpla WM tllterad for analyali.
Debbie Little
 Analyst
                                                                                    Staphwi Sl«gel, CIH
                                                                                 or otner approved signatory
  Oi«e[alnwr»> Tha laboratory la net retponHWa for Hate rapaitad In ainutmtlce. which li dapwxlant en valutna eolleetad hy nerHabarakuy p«r*flmal. Thi. mpoft n\»y not ba
           cft in full, withoul writlvn p»rmi»»on by EMSL Analytic*!, Inc. Thh report mun net be UMd to cliim product cntfonwrranl by NVLAP or any aaancy orme U.S.
          Thl« »port »!•(«> only to th» wmpj» raporttd «wv». QualKy eor*»i 
-------
07/14/2800   13:52    85685B4960
                                                        EMSL ANALYTICAL INC
                                                                                                 PAGE  01
  EMSL Analytical, inc.
  107 HJddort Ave., Wwtmont, NJ 08108
  Phone: (M9) 868-4800   F»«: (M»««M9«0  Email:
  Attn;    Linda Phillips/Dave Nelson
         Veraar inc.
         6850 Versar Center
         PO Bex 1548
         Springfield, VA22151
  Fax;    703-642-8809           Phona:  703-642-6889
  Project:  4801,006/EPA Varmiculita
Customer ID:     VERS96
Customer PO:
R*ceived:       07/12/00 10:17 AM

EMSL Ofder     040011455
EMSL Protect ID:
Analysis Date:    7/13/2000
        Fiber Analysis of Air Sampled via NIOSH 7400, Revision 3, Issue 2, 8/15/94
                                                               LOD    Fiber*/   Fiber*/
Sample Location Sample Date
MWS-040-A 7/1 1/2000
34001 14SS-0001
WS.041-A 7/11/2000
34001 1466-OOOS
WIS-042-A 7/11/2000
34001 14&&0003
MYIS-043-A 7/11/2000
T4001145&-Q004
MWS-044-A 7/11/2000
MOOtf4SS-0005
\MS-C45-A 7/11/2000
•XCQ114S±OOOt
MWS-047-A 7/11/2000
140011455-0007
WMS-048-A 7/11/2000
WOMMSWroOB
\M$W9-A 7/11/2000
H001146W009
WWS-050-A 7/11/2000
M00114554010
WS-051-A 7/11/2000
)40Q114SS-0011
Volume ftben Fields (flt/ec) mm' cc ffeta
1124.00 «5.5 100 0.002 <7.0 <0.002
182.0C <5.S 100 0.015 <7.0 <0.015
OvaHomted
OvorlaiKW
448.15 <5.5 100 0.006 <7.0  7 nben/tnm*. TT>» laborasoiy u not retporniwo tor a
rata(m only to (ha isimpten rsportnd ahovtt This report may ml bBraprt
Anal/als pairormod by EM6L Wotmont (NY Stan ELAF in 0672)
1
Stephen Siegel, CIH
or other approvad signatory
>l« report* In flMri/ct wnicft Ig Mptmunt on vamim colterted by nan-labarataiy perurvMI Thto racort
iduCBd. 
-------
                                                    CHAIN OF CUSTODY RECORD
                                                                                                                  4598
                                                                                                                                      (S
                                                                                                                                      •si
 PROJECT NO,     PROJECT NAME
                        TIME
                                     IPrmd)
                                            STATION LOCATION
                                                                                                                  WDUSTBIAL
                                                                                                                HYQIEN« SAMPLE
                                                                                                                                 V
                                                                                                                  REMARKS
                                                                                                                    y
                                                                                                                      '
                                                                                                                         m
afoVI-.
PUMKilf

I Tin*   Received by:
                                                                  Rtriinquiided by: (Signttun)
                     Dit» / Timt  Hdctivtd by: fSignawntJ
          Afe&J
                                         [Prlntidl
                                  (Prinndl
                                                                                                          (PiinMd)
           by: (Kgnrtvnl
Data / Time
        R«eaiv«d for LihorttDry by:
/Turn
 iPrtnttdl
        IPr(nt*d)
                                                      <**>*Mvsn*+ts:i •cmtv^.-f^-.-^f^ltMr^^'^amo.vf^ami^ff.
                                                                                                                               • -    f

-------
07/14/2000  13:52
8568584950
VensarJobNo.
Project Manager!
                                        EMSL  ANALYTICAL INC
                                  ASBESTOS AIR SAMPLE DATA
                                                        dient
PAGE  04
      71// /«? Shtt^_
Collection MethodL4^££.
Sample Metfa;.
                                                       Sampfe Location:
                                                       Samples Collected by
                                                       Analyze for
                                                       Temp:
                                            SAMPLE DATA
Anadyst
QC Recounts (Efcc)
QC Analyst





*







' T '••

!


                                         SAMPLE LOCATION
                                                                    WT
                                                                   ab
                                                                  ff'o
                                                                  1*0
                                                                        o
                                                                        O
                                                                            TIP
                                                                                 m
                                                                         ^t
       Location (LOG):
       Type(TYP):
       PhBMflPH):
       Abatement (AST):
                               0 =* OUttida WOlk ATM
                             P = P*raonal   A-Antfent   B-FieidBlank
               S-Prw-Start  R =. Removal   £ = Btabtoh Containment   C^Ctaanup  F =
               FPsRraprtwfjng  CT;» C«»jg T*s  FT - ROOT Tiles  Bf = Boft«r
               TP=TramV»Pwwl  AC = Acouaflcat Cefflng Texium   M = Adiahre MaaHe»
               R » Rocfag kU*tlate  PI - Pipe Lagging
       SampBrtg (SAM):

       Note: AO Personal Svnpte l*Mt Have Wgiker Nwi» and Social Sacui*y Nutnbw.

       Corntnents:

-------
07/14/2000  13:52
              8558584960
                                        EMSL ANALYTICAL INC
                                  ASBESTOS AIR SAMPLE DATA
                          PAGE  05
  Versar Job No.
                                                      caiant
  Sampte Media:^^/./,.*.
                                  .~
Sampte Location:,
Samples Collected
Analyze for.
Temp:.
                                                       f? r
                                                                      ./Rel HuwidL ^f V*  ' ~
                                           SAMPLE DATA
        Sampte Mo
        Pump No.
                                                                2&-&UJL
        Tone On
        Time Off
        Total Tta»e(min.)
        Flow Rate (LPM)
        Volume (Itteis)
        DMBctfoii Umtt
        Results ffcc
Amiyst
QC Recounts (ffcc)
QC Analyst


















                                       SAMPLE LOCATION
                                                                              m
                                                                              Kt
Hrf0ittOtt)
Lucartton (LOC):
Type(TYP):
Phase (PH):
                                    P^Porsonai
                                                                C = Cleanup  F-Rniair
               SaprthStart  R

               TP = Tnarmto Panai  AC * Acoustic* Cafflng Texture  M =» Adhenva Masfica

Samptog (SAM):    AG-Affljmsaiw  NA = | ~
      Note: Afl Penomi Samptes Murt Ha*« VVbtker Nsme and S
-------
07/14/2008  16:12     8568584960
                                                              EMSL ANALYTICAL  INC
                                                                                   PAGE   01/04
    EMSL Analytical, Inc.
    »07 HtddOn Av«,, Wtatmont, NJ 08108
    Phont: (608j«6B^eOO  _F.x:
    Aitn:    David Nelson
           Verear Inc.
           6850 Versar Center
           PO Box 1548
           Springfield, VA 22151
    Fax:     703-642-6809
    Project;  EPA-VERMICULITE
            Phone:  703-342-6889
                                                       Customer ID:     VERS96
                                                       Customer PO;
                                                       Received:        07/13/00 4.36 PM


                                                       EMSL Order:      040011572
                                                       EMSL Project ID;
                                                      Analysis Date:      7/13/2000
   Asbestos Ffber Analysis by Transmission Electron Microscopy (TEM), Selected Area
                       Electron Diffraction (SAED), and Energy Dispersive
                X-Ray Microanalysis (EDX) - Performed by EPA Level II Method.
 Sample
AMS-052-A

010O11'572-0001
423  Nona Detected
AMS-053-A

04001 15724M02
AMS-054-A
040011S72-0003
424  None Detected
418  None Detected
                                                         Analytical
                                                         Sensitivity
                                      1.0047     <1103.1S    <1.0047
                                                                                        prep, uh and rasuopand 5% at
                                                                                        Mmpte was fiHared for arwlytii.
                                      1.0028     <1 103.19
                                                           <1.0028   Bampto «» eiwiyad by indlwcl
                                                                    orop. »jh ind reou»f»na s% a»
                                                                    umpte wei niand for «i«ly«ii.
                                      0,0151
                                                  <16.39    <0.0151
AMS-055-A

040011572-0004
415  Nona Detected
                                      0.0152       <16.39    <0.0152
AMS-056^A
(MOorrsTZ-ooos
AMS-057-A
04001 1572-OOOg
AMS-058-A
0400*7575-0007
86 None Detected
65 Ncme Detedad
403 Nona Detected
0
0
0
3.2868
6.5605
0,5271
<551.41
<11Q3.19
<551.41
O.2868
<66605
<0.5271
Sample won anityzaa by rr^ljrvct
prep, uh «na ™«jjp«nd. 10X of
urnpla we* fill«r«d (or analyaji.
Sampla w«> auty»d by Inmract
pr«p. Mh «nd rwu»p4>na. S<( gf
i*rip|» wtn Dtttnd fcr analyiu.
Ssmpis was ww^zad by indirect
prep, >di and reiu.pand. 1 0% of
.\.
AMS-059-A 424 None Detected

-------
  .  07/14/2000  16:12
         8568584960
                                                        EMSL ANALYTICAL  INC
                                PAGE   02/84
    EMSL Analytical, Inc.
    107 Haddon Awt., Wratmont, NJ 08108
                      Fax;
Attn:    David Nelson
       Verear Inc.
       6850 Veraar Center
       POBox 1549
       Springfield, VA 22151
Fax:    703-642-8809
Project:  EPA-VERMICULITE
                               Phone: 703-542-6660
                                       Customer ID:     VERS96
                                       Customer PO:

                                       Received:        07/13/004:36PM


                                       EMSL Order      040011572
                                       EMSL Project 10:
                                     Analyst Data:      7/13/2000
   Asbestos Fiber Analysis by Transmission Electron Microscopy (TEM), Selected Area
                      Electron Diffraction (SAED), and Energy Dispersive
               X^Ray Microanalysfs (EDX) - Performed by EPA Level II Method
Sample
AMS-063-A

040011672-0011
Anont Samudrs
Analyst
Volume
(Bias)
                                       # Structure
                                                   Analytical
                                                   Sensitivity
                                                     (S/cc)
_  Cancqptmtinn
 (SAnmJ
                                                                                    Nottf
AMS-061-A
M0011672-OQ10
AMS-082-A
oiemnKiv-ivm
41 5 Nona Detected
61 None Detected
0
0
0.0152
3.4654
< 16.39
O51.41
<0.0152
<3.4654

Sample w«« wvlyzatj by Mired
                                                                                    ssmpla w.! fi||»roa to Mslystg.
  62  None Detected
                                     3.4302
                                                <551.41
                                                          O.4302
                                                                                                 .
                                                                                    ianp(» wai (iltuad fa- enalyli*
                                                                            Stephen Siagei. CIH
                                                                         or other approved signatory
                                                           , fIBOflJ »» ™n-l«bor»toy panawwi TW. r.p«t may net b.

-------
,  07/14/2000  16:12     8568584960
                                                             EMSL ANALYTICAL INC
                                            PAGE   03/04
      EMSL Analytical, Inc.
      tor Haddon Av«.. WMtmont, NJ 08104
     J*han«: (909)838-4800   ftK (609)838^00
     Attn:     David Nelson
              Veniar inc.
              6850 Versar Center
              PO Box 1648
              SpringflaW, VA 22151
     Fax:      703-642-BB09
     Project   EPA-VERMICULITE
                                 Phone: 703-642-6689
Customer ID;     VERS96
Customer f>O:
Received:        Q7/1 3/00 4:36 PM


EMSL Onier:      040011572
EMSL Pfoject ID:
Analysis Data:     7/13/2000
            Fiber Analysis of Air Samples via NIOSH 7400, Revision 3, Issue 2, 8/15/94
Sample
                 Location
   AMS-052-A
   AMS-053-A
   AMS-054-A
   040011SJZ.OOQ3
   AMS-055-A
   040011572-0004
   AJvts-ose-A
   040Q11S7SW005
                                                                        LOD
                                    Sample Dale   Volume fUen fields    (fitfcc)     mm'      cc   Nota
                                      7/13/2000
                                                                                                 Overloadaa
                                      7/13/2000
                                   7/13/2WO    418.28   13.0   100      0006~   Ifl^i
                                                                                        0015
                                                                                        OD14
                                   7/13/2000
   040011S72-OOOB
                                      7/13/2000
                                                                                                 Ouorloaded
  040011572-0007
                                      7/13/2000
  AMS-05S-A
  640011572^000$
                                  7/13/2000
                                                                                             OvertofltJad
  040011673-0000
                                     7/13/2000    418.28   7.0   100      0.006      8.92     0.
                                                                                            008
  040011S72-0010
                                     7/13/2000    41471   10.5   100      0,006     13.3B     0.012
                                     7/13/2000
                                                                                                Overloaded
   Tom Boor
   Analyst
                                                                                         Stephen Siagel, CIH
                                                                                      or other approved signatory
   Analysla parfarmxl by EMSL Vf»*int>ft |MV $M8 EUSP <(10»T2)

                PCM-1
                                                                                                                 1 of 2

-------
07/14/2000   16:12     8568584960
EMSL  ANALYTICAL INC
PAGE   34/04
   EWSL Analytical, Inc.
   107 Haddon Ay*., Wa»tmont, NJ 06108
   _gjlgna; (809)888-4800    Fm: (8M)$$3-4igC  Emtll; gin
   Attn:    David Nelson
          Versa; Inc.
          6850 Versar Center
          PO Box 1649
          Springfield. VA 22151
   Fax    70^642-6808
 Customer ID;     VERS96
 Customer PO:
 Received.       07/13/00 4:36 PM
   Project:  EPA-VERMfCUUTE
                               Phona: 703-642-8SB9
 EMSL Order:     040011572
 EMSL Project ID:
 Analysis Date:    7/13/2000
         Fiber Analysis of Air Samples via NIOSH 7400, Revision 3, Issue 2, 8/15/94
Sample Location
AMS-OS3-A
0*0011572-0011
AMS-C64-A
040011572-0013
AMS-065-A
040G11ST24Q14
AMS-G66-A
040011S7i-9015
AMS-067-A
0400115724010
LOD
SamptfDalt Volume Fibers fields (flb/cr)
7/13/2000
7/13/2000 o.OO <5.5 100
7/13/2000 000 <5.5 100 ~
7/13/2000 0.00 <5.5 100
7/13/ZOOQ D.OO <5.5 100
FOKT3/ Filters/
"""' « Notti
Ovanoad«|
<7,0 Flaid Blink
<7.0 FiaW Blank
<7,0 Flaw Blink
<7.0 F«id Blank
 Steve Slegel
Analyst

                                                                              Stephen Slegel. CIH
                                                                           or oth«r approvad signatory
                         ia^^^ri»3SRS»^                                ^* -p"

-------
                                                                                                              4613
                                                 CHAIN OF CUSTODY RECORD
                                                                                 3
PROJECT NO.
PROJECT NAME
     FliLO
    SAMPLE
    NUMBER
DATE
      TIME
I
STATION LOCATION
                                                                                     PARAMETERS
                                                                                 INDUSTRIAL
                                                                               HYGIENE EAMPLE
                                                                                                             REMARKS
                                                                                                               -©-
tort -oft -0
                                                                                                ro
                                       xK
                            Date / Time
                               JS5
                          W/fa
                                                 Relinquiihed by:
                                        (PriniedJ
                                                                 IPrinttd]
                                                  Data / Time
                                                                          Raceived by: IStgntiurg)
                                                                                                       (Prltittd!
 [Printed >
             Daw / Tim*
                                        RaoBtvcd for Liborrtary by:
                                        (Sign»turt)
                                                    D»t* / Timi
                                                                                                                   IT/tt-i Lfa&Jt /"

-------
Vcrwr.
                           ASBESTOS AIR SAMPLE DATA
Versar Job No.
Project Ms.ns.qrr
                                                 Client
                 Shift
Collection Method:
Sample
                                                Sample Location;,
                                                Samples Collected fay::;
                                                Analyze for -^-~-''/7
                                                                   /Rel. Humid:
                                      SAMPLE DATA
 Sample No.
 Pump No.
 Time On
 Time Off
                                                       /*/?£,
 Total Time (mln.)
                     _m_
 Row Rate (LPM)
                                                       t&Y
      *-•**.
 Volume (liters)
 Flbara/Flalds
 Detection Limit
 Results f/cc
Analyst
QC Recounts (f/cc)
QC Analyst


















                                    SAMPLE LOCATION
                                                               HT
                                                                   IDC
                                                                        TTP
                                                                             PM
                                                                                 AttT
                                                                                      SAM
                                                                        A
                                                                                     JtM
                                                                    O
                                                              5
                                                                   o
A
HA
IX
                                                                             tM
Height (H^
Location/LOC):
Type mff>):
Phase'CPH):
Abatement (AST):
                 ) ^ Inside Work area  O - Outside work area
                 G = General Area   P« Personal  A = Ambtent  B= Reid Blank
                 S = Pro-Start   R = Removal   E = Establish Containment   C = Cleanup  F = Final air
                 FP = Rrepmoflna  CT = Ceiling Tiles  FT = Floor Tiles   BI=Bofler
                 TP = Tranate PaneJ  AC = Acoustical Ceiling Teadum   M = Adhesive Mastics
                 R = Roofing Materials  PI - Pipe Lagging
                 AG - AgflresaivB  NA -
Sampling (SAM):

Note: All Personal Samples Must Have Worker Name and Social Security Number.

Comments;
          yjfrr&f/r:
 L:\TtMPLATE\ASBeSTOS\AASD.TVP

-------
                           ASBESTOS AIR SAMPLE DATA
VersarJobNo..
Project Manager
Date: 7 l/t
                 Shift_
Collection Method:/**^/*"
                                                 Client.
                                                 Sample Location;.
                           /&%
Sample Media: . l/f/t fr/rf >«ft4r' jf
    Samples Collected by;
    Analyze for
    Temp:   Zf*      /Re). Humid:
                                     SAMPLE DATA
Sample No.
                                                                  titf-ffi-rt
 Pump No.
                                                                                ZO'i-
Tim* On
Time Off
                      fin
ff'f
Total Time (mln.)
Flow Rate (LFM)
Volume (liters)
                                             -;_

                                   SAMPLE LOCATION
                        MS
                                     st4sK.pt*)
Height (HT)
Location (LOG):
Type (TYP):
Phase (PH):
Abatement (ABT):
Sampling (SAM):
                 I => Inside Work area   O - Outside work anu
                 G = GerwraJ Area   P^Pereonat  A = Ambient   B = Field Blank
                 S = Pre-Slart  R «= Removal  E = Establish Containment  C « Cleanup   F =• Final air.
                 FP = Ftrepraofing  CT = CeiHng Tilas   FT = Floor Tiles   Bi = Bailer
                 IP ^ Transite Parwl   AC = Acoustical Ceiling Twctura   M = Adhesive Mastics
                 R = Roofing Material*   PI - pipe Lagging
                 AG - Aggressive  NA - Non-Wggressive
Note: All Personal Samples Miwt Have Worker Name and Sodal Security Number.
Comments:
          at

-------
    EMSL Analytical, Inc.
    107 Haddon Ave., Westmont, NJ 08108
    Phone: (809)858-4800    Fax: (609)858-4960   Email:  ssi
   Attn:    David Nelson
           Versar Inc.
           6850 Versar Center
           PO Box 1549
           Springfield, VA 22151
   Fax;     703-642-6809
                                  Phone:  703-642-6889
   Project  #4601.005/EPA-Vermiculite
                                           Customer ID:     VERS96
                                           Customer PO:
                                           Received:        07/14/00 10:30 AM


                                           EMSL Order     040011640
                                           EMSL Project ID:
                                          Analysis Date:      7/15/00
   Asbestos Fiber Analysis by Transmission Electron Microscopy (TEM), Selected Area
                        Electron Diffraction (SAED), and Energy Dispersive
                X-Ray Microanalysis (EDX) - Performed by EPA Level II Method.
Sample
Volume    Asbestos
(liters)      Type(s)    Asbestos   Non-Asb.
                                            it Structures
      Analytical
      Sensitivity
        (S/cc)
                                                                              Concentration
                                                                                         S/cc    Notes
AMS-068-A

040011640-0001
  403  None Detected
0       0.0157        <16.39     <0.0157
AMS-069-A

040011640-0002
  424  None Detected
0       0.0149        <16.39     <0.0149
AMS-070-A

040011640-0003
  418  None Detected
                                   0       0.0151        <16.39     <0.0151
AMS-071-A

040011640-0004
  415  None Detected
                                           0.0152        <16.39     <0.0152
AMS-072-A

040011640-0005
   58  None Detected
0       0.1096       <16.39     <0.1096
AMS-073-A

040011640-0006
   60   None Detected
                                           0.1052       <16.39     <0.1052
 Ron Mahoney
 Analyst
                                                                                       Stephen Siege), CIH
                                                                                   or other approved signatory
          NVLAPPLM/TEM #101048-0. NY ELAP #10872
   4Sl^rS:   .  SfJLT ?' T P°nSible f0r data ™Por">d in slructuresfcc, which is dependant on volume coltected by non^abaratory penwnnel      o   y n
                i   ?" ""I"8" Penmpsslon by EMSL A^yfeal. ^ This report must no. be used to data pradud endonenSSby N^AP or an,tt,^u¥
                rt relates crt  the samples reported abova. QuaHty control data (including 95% confidence limit, and laboraUxy 2* analysts'
                                                                                                               Page 1

-------
   EMSL Analytical, Inc.
   107 Haddon Ave., Westmont, NJ 08108
   Phone: (609)858-4800    Fax: (609)888-4960  Email:  ssiegel@EMSL.com
   Attn:     David Nelson
            Versar Inc.
            6850 Versar Center
            PO Box 1549
            Springfield, VA 22151
   Fax:      703-642-6809
                                     Phone:  703-642-6889
   Project:  #4601.005/EPA-Verniiculite
                                                     Customer ID:      VERS96
                                                     Customer PO:
                                                     Received:         07/14/00 10:30 AM

                                                     EMSL Order      040011640
                                                     EMSL Project ID:
                                                     Analysis Date;     7/14/00
           Fiber Analysis of Air Samples via NIOSH 7400,  Revision  3, Issue 2, 8/15/94
 Sample
Location
                                        LOD     Fibers/    Fibers/
Sample Date    Volume Fibers  Fields     (fib/cc)     mm'        cc   Nates
 AMS-068-A
 040O11640-0001
                          7/13/00     402.70  14.0   100       0.007      17.83     0.017
AMS-069-A
040011640-0002
                          7/13/00     423.60  17.5   100       0.006      22.29     0.020
AMS-070-A
040011640-0003
                          7/13/00     418.30   <5.5   100       0.006       <7.0     <0.006
AMS-071-A
040011640-0004
                          7/13/00     414.70   <5.5   100       0.006       <7.0    O.006
AMS-072-A
040011840-0005
                          7/13/00      57.60    5.5   100       0.047       7.01    <0.047
AMS-073-A
0400116404006
                          7/13/00      60.00    9.0   100       0.045     11.46     0.074
AMS-074-A
040011640-0007
                         7/13/00      0.00   <5.5   100
                                                                         <7.0
AMS-075-A
040011640-0008
                         7/13/00      0.00   <5.5   100
                                                                         <7.0
AMS-076-A
040011640-0009
                         7/13/00      0.00   <5.5    100
                                                                         <7.0
AMS-077-A
040011640-0010
                         7/13/00      0.00   <5.5    100
                                                                         <7.0
 Tom Beer
 Analyst
                                                                                                Stephen Siegel, CIH
                                                                                             or other approved signatory
  Unit of detection is 7 fibers/mm-. TTra laboratory is not responsible for data reported in fibers/cc. which is dependent on volume collected by non-Jaboratorv oereonrtel This report
  relates only to the samples reported above. TOs report may ml be reproduced, except In full, without writtenapproval by EMSL         ™rHaoormory personnel, inis report
  Analysis performed by EMSL Westmont (NY Slate ELAP #10872)
                PCM-1
                                                                                                                          1of1

-------
                                                                                                                            4614
                                                       CHAIN OF CUSTODY RECORD
PROJECT NO.
PROJECT NAME
                                                                                                                           INDUSTRIAL
                                                                                                                         HYGIENE SAMPLE
     FIELD
    SAMPLE
    NUMBER
                             STATION LOCATION
             Date / Time    Received by: (Signature)
                                                                       Relinquished by: /Signature)
                                                                                                Received by: (Signature)
                         Received for Laboratory by
Relinquished by: (Signature)

-------
Versar Job No..
Project Manager.
Date:  7
   Collection Method:
   Sampte Media:  VJ
                              ASBESTOS AIR SAMPLE DATA
                                                     Client
                                                     Sample Location:
Samples Collected by:
Analyze for.
Temp:.
-7
-------
Versar Job No. _,
Project Manager.
                                ASBESTOS AIR SAMPLE DATA
                                                       Client
    Collection Method:
    Sample Media;
                     Shift
                                                       Sample Location:.
                      .
                         /«.
                                                   Samples Collected bv:-^g
                                                   Analyze for
                                                   Temp:_
                                                                                    '•  f —»•
                                                                                    ...  Cm .X
                                          SAMPLE DATA
Analyst
QC Recounts (f/cc)
QC Analyst
















.

                                      SAMPLE LOCATION
                                                                   mr
                                                                                  PN
                                                                                      ABT
                                                                                          SAM
                                                                             T5
                                                                             75
                                                                                      SL

                                                                        n
                                                                         7?
 Height (HT)
 Location (LOG):
 Type (TYP):
 Phase (PH):
 Abatement (ABT):
 Sampling (SAM):
              I = Inside W«k area  O = Outside worts area
              G = General Area   P = Persona)  A = Ambient  B-Field Blank
              S » Pre-Start  R = Removal   E = Establish Containment   C « Cleanup  F - Final air
              FP = Fireprpofing   CT = Ceifing Tiles   FT«Floor Tiles   Bi = Boiler
              TP = Transito Panel   AC = AcoustfcaJ Cefling Teacture   M = Adhesive Mastics
              R = Roofing Materials   PI = Pipe Lagging
              AG = Aggressive  NA = Non-Aggressive
Note: Afl Personal Samples Must Have Worker Name and Social Security Number.

Comments:	
L\TEMPLATBASBESTOS\AASO.TMP

-------
     EMSL Analytical, Inc.
     107 HaeWon Aw«., Wwrtmont, NJ 08108
     Attn:    David Neteon
            Versar inc.
            6850 Versar Center
            PO Box 1648
            Sprtngfidd, VA 22151
            703-642-3809           Phone;

    Project:   EPA VermicMme««OlJJ05
                                                         Customer ID:     VERS8B
                                                         Customer PO:

                                                         Received:       0&02/00 10:54 AM


                                                         EMSL Order:     040008587
                                                         EMSL Project ID:
   Asbestos F,ber Analysis by Transmission Electron Microscopy ITEM)  Selected Area
                       Electron Diffraction (SAED), and Energy Dispersive^'               *
                X-Ray Microanalysis (EDX) - Performed by EPA Level II Method
 Sampl*
 023ft.

 040008597-0012
 030A

 040008597-0013


 031A

 040008597-0014
                    877
                    676  Norn, Detected
                    408  None Detected
                                                  0      Q0093      <163g
                                                  1      0.0155      <16J8
 032A

 040O08597-001S
                                                        Q.0155       d6.39
033A

04000SS07-0016


034A

040008507-0017
035A

040008597-0018
406  Overloaded


	1	.	

 90  None Detected


	•	__	

 88  Nona Detected
                                                12     0.0702       <16.39     
-------
     EMSL Analytical, Inc.
     107 Haddon Ave., Westmont, NJ Owl08
    Attn:     David NeJsort
             Versar Inc
             6850 Veraar Center
             PO Box 1548
             SpringfleW, VA22151
    Fax:      70^642-6809
    Project:   EPA Vermicul««/48IM,go6
                                    Phone:  703-542-68B8
 Customer ID      VERS96
 Customur PO:
 Recawed.;         06/02/00 10:54 AM


EMSL Order      04000H587
EMSL Project ID:
Analysis Date:      S2/2aoo
           Fiber Analysis of Air Samples via NIOSH 7400, Revision 3, Issue 2, 8/15/94
 Sample
                Location
 029A

 040008507-0001
                                                                         t-OD      fibers/    FU>m/
                                    Sample Date    Volume Fibm  FleUt     QWtc)      mm'       cc
                                  ••^'•^^—^^^^^
                                       8/1/2COO    8/5,92  <5.5    100
 03QA

 040008SS7-0002
                                       6/1/2000     57S.34   <5.5    100
 031A
 049008537-0603
                                      6/1/2000     408.01    9X>   100     TOOT     TM6"    OoT
040008687-0004
6/1/2000 407.16 11,0 100 0.007 14,01 0.013 ' "

033A 6M/2000 — 	 cwioadad .'' ''." '~T — ' 	
 044008597-0005
034A

040006537-0006
                                       Q/1/2000
 035A
                                       8/1/2000
                                                   57.87   24.0   100       0.031     30,57  (  0.134
036A

040008507-0008
                                      fi/1/2000
                                                   0.00   «5.5    100
                                                                                   <7.0
                                                                                                 Plaid Blank
                                      &1/2000
                                                    0.00   <5.5   100
                                                                                    <7.0
                                                                                                  Field Blank
040009597-0903
038A

6/1/2000
fi/1/2000
0.00 <55 100
0.00 <5.5 100
<7.0 Field atvvk
1

fJO new Blank '
04000S5fff-0011
 Dava Stan/rope
 Analyst
                                                                                           Staptwi Siege!, CjH
                                                                                        or oBier approved wsnatory
 Analysis perfomigo By BUSLWeetmont (NY SBM«ELW»1DB72)
                                                                           -T«™«»-

-------
  CHAIN "OF CUSTODY RECORD
to Coordi ruswr Fretd Pi£s« bu« L-1 t^^^Q&JU&sJr /^TT-yT^

-------
                             ASBESTOS AIR SAMPLE DATA
 Versar Job No. _
 Project Manag
 Collection Method
 Sampfe Media.. *«•*
                                      SAMPLE DATA
 Sample No.
 Total Time (min.)
 Flow Rate (LPM)
 Volume (liters)
 :lbera/Fielda
Detection Limit
Results f/cc
Analyst
     i ••»
QC Recounts (f/cc)
QC Analyst
                                   SAMPLE LOCATION
 £	
 Height (HT)
 Location (LOC):
 Type (TYP):
 Phase (PH):
 Abatement (ABT):
                 Inaide Vtfortc area  O = Outside wo/k area
               G-General Area  P = Pe«onal  A = Ambient  8 = ReldBlank
               5 = pre^tart   R = Removal   E = Establish Containment   C - Cleanup  F = Final a/r
               FP = F«pmaflng  CT»Ceitog Tile,  FT-FlaorTite   Si^Boto
               R^-liIS*^ f"el1  ^^^^calCeillnaTexture  M = AdheaiveMaatfcs
               R - Roofing Materials  p| ~ P|pe Lagging
               AG st Aggressive NA = Non-Aggressive
Sampling (SAM):

Note. All Personal Samples Must Have Worker Name and Social Security Numter

Comments:  ^y/feT  t&UeZTeA  !&&£*/& rfjXtte  f^ ^

-------
                            ASBESTOS AIR SAMPLE DATA
 Versar Job No _
 Prajegt Manager
 Collection
 Sampte Media:
                                                  Client
                                                  Sample
                                                  Samples
                                                  Analyze
                                     SAMPLE DATA
QC Recounts (T/cc)
QC Analyst
                                 SAMPLE LOCATION
               = Inside Wortc area   O = Outside work an-a
                               -Personal  A = Ambient  B = Field Blank
                                        Establish Containment
 Height (HT)
 Location (LOG)
 TypaCTYP):
 Phase 
-------