REGULATORY IMPACT ANALYSIS OF CONTROLS ON
ASBESTOS AND ASBESTOS PRODUCTS
FINAL REPORT
VOLUME III
APPENDIX F
Prepared for:
Christine Augustyniak
Office of Toxic Substances
U.S. Environmental Protection Agency
Prepared by:
ICF Incorporated
Fairfax Virginia 22031-1207
January 19, 1989

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TABLE QF CONTENTS
I.
Commercial Paper
II.
Rollboard
III.
Millboard
IV.
Asbestos Pipeline Wrap
V.
Beater-Add Gaskets
VI.
High-Grade Electrical Paper
VII.
Roofing Felt
VIII.
Filler for Acetylene Cylinders
IX.
Flooring Felt
X.
Corrugated Paper
XI.
Specialty Paper
XII.
Vinyl-Asbestos Floor Tile
XIII.
Asbestos Diaphragms
XIV.
Asbestos-Cement Pipe and Fittings
XV.
Asbestos-Cement Flat Sheet
XVI.
Corrugated Asbestos-Cement Sheet
XVII.
Asbestos-Cement Shingles
XVIII.
Drum Brake Linings
XIX.
Disc Brake Pads (Light/Medium Vehicles)
XX.
Disc Brake Pads (Heavy Vehicles)
XXI.
Brake Blocks
XXII.
Clutch Facings
XXIII.
Automatic Transmission Friction Components
XXIV.
Friction Materials
XXV.
Asbestos Protective Clothing
XXVI.
Asbestos Textiles
XXVII.
Sheet Gaskets
XXVIII.
Asbestos Packings
XXIX.
Roof Coatings and Cements
XXX.
Non-Roofing Adhesives, Sealants, and Coatings
XXXI.
Asbestos-Reinforced Plastics
XXXII.
Missile Liner
XXXIII.
Extruded Sealant Tape
XXXIV.
Asbestos Separators in Fuel Cells and Batteries
XXXV.
Asbestos Arc Chutes

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I. COMMERCIAL PAPER
A.	Product Description
Asbestos commercial paper can be classified into trwo categories --
general insulation paper and muffler paper. Commercial papers are used to
provide insulation against fire, heat, and corrosion at a minim thickness.
These papers are used in a variety of specialized applications and are,
therefore, produced in many different weights and thicknesses. They usually
consist of approximately 95 to 98 percent asbestos fiber by weight; the
balance 2 to 5 percent is typically starch binder (Krusell and Cogley 1982),
Commercial papers are produced on conventional papermaking machines. The
ingredients are combined with water to produce a mixture that is fed through a
series of rollers. These rollers apply pressure and heat to produce a paper
of uniform and desired thickness. The paper is then allowed to cool before it
is cut, rolled, and packaged.
Huffier paper is used by the automotive industry for exhaust emission
control systems. The paper is applied between the inner and outer skins of
the muffler or converter to maintain the high temperature necessary for
pollution control within the catalytic converter reaction chamber and to
protect the outer layer from the heat (Krusell and Cogley 1982).
General asbestos insulation paper is used in a variety of industries.
The steel and aluminum industries use it as insulation in furnaces, in trough
linings, in the smelting process, and against hot metal and drippings of
molten metal, Asbestos paper is also used in the glass and ceramic industry
for kiln insulation, in foundries as mold liners, and in the electrical parts
and appliance industry for electrical insulation.
B.	Producers and Importers of Asbestos Commercial Paper
There were two primary processors of asbestos commercial paper in 1981:
Johns-ManviHe Corporation (now Manville Sales Corporation) and Celotex
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Corporation (TSCA 1982a). There were also three secondary processors of
asbestos commercial paper in 1981: Metallic Gasket Division, Sepco
Corporation (now Fiuorocarbon Metallic Gasket Division), Parker Hannifan
Corporation, and Lamons Metal Gasket Company (TSCA 1982b). All of these
companies have stopped processing asbestos commercial paper, and there are
currently no primary or secondary processors of this product (ICF 1986),
However, a representative of Quin-T Corporation's ErUe, PA plant stated that
it is selling small amounts of commercial paper out of inventory. The
official could not quantify the amount sold in 1985, but did state that
production had been discontinued (ICF 1986). Because none of the other
respondents to our survey indicated that they had begun the production of
asbestos commercial paper in the period since the previous survey, or that
they were aware of any other distributors or importer of this product, we have
concluded that there are currently no domestic producers of asbestos
commercial paper. In addition, a 1984 survey of importers failed to identify
any importers of asbestos commercial paper (ICF 1984).
C.	Trends
1981 production of asbestos commercial paper was 936 tons (TSCA 1982a).
As described above, there was no production of this product in 1985.
D.	Substitutes
Asbestos fiber has been used in commercial paper because of its corrosion
resistance, fire resistance, chemical resistance, strength, and durability.
Information on the advantages and disadvantages of asbestos commercial paper
and its substitutes is summarized in Table 1.
The major substitute for asbestos commercial paper is ceramic paper (ICF
1985). Ceramic paper is manufactured by Carborundum Corporation, Cotronics
Corporation, Babcock & Wilcox, and Lydall Corporation. This product shares
many of the advantages of asbestos commercial paper such as corrosion, fire,
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Tabid 1, Subst.lt.ut.Rs for Aisbst.ns Comnerctal Paper
Product
Manufacturer
Advantages
Disadvantages
References
Asbestos Cooinercial Paper
Hone
Fire, heat, rest, and corrosion
raftlatent.
Low cost.
Long service life.
Environmental, and occupational
health problems.
Kruseli and Cogley (1982)
ICF (1986)
Ceramic Paper
Carborundum Corp., BY
Cofcronica Corp., NY
Babcock & Wilcox, GA
Lydall Corp., HH
Heat, corrosion, and chemical
resistant.
Bifth temperature use limit
(2300"F>.
Hot as strong or resilient
as asbestos.
Mori* expensive.
Carborundum (1986)
Cotronics (1986)
Babcock & Wilcox <1986)
Cellulose Paper
Holllngsworth & Vose, MA
Good electrical propsrties.
Inexpensive
Hot heat resistant.
Low temperature use limit.
Bollingsworth 6 Vose (1983)
Fiberglass Paper
Lydall Corp., HH
Boat resistant.
Temperature use limit of
1100'F.
Hot as strong or diiaensionally
stable as asbestos.
Lydall (1983)

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and chemical resistance. However, at extremely high temperatures the hinders
in the paper begin to burn and all that is left is the fiber. The strength
differential becomes more important as the binder burns away because ceramic
fibers are not as strong as asbestos fibers. In addition, ceramic paper is
more expensive than commercial paper.
Despite these drawbacks, ceramic papers can substitute for asbestos
commercial papers in any of the following applications: insulation for the
aluminum and steel industries, foundry insulation, glass making, fire
protecting barriers, mufflers, catalytic converters, kiln and furnace
construction, and other high temperature uses.
Hollingsworth * Vose Company produces a cellulose electrical insulation
paper. This product is a good substitute for asbestos commercial paper in the
electrical parts and appliance industry. It is less expensive than the other
substitutes, but it cannot be used in high temperature applications
(Hollingsworth & Vose 1983).
Lydall Corporation also manufactures fiberglass commercial paper. This
product is considered an inferior substitute because it can only operate at
temperatures up to 1100"F and is not as strong or dimensionally stable as
asbestos commercial paper (Lydall 1983).
E. Snmma rv
Domestic production of asbestos commercial paper did not take place in
1985. A small amount was sold out of inventory, but there is currently no
more consumption of this product. As a result, complete substitution of
asbestos in commercial paper has taken place. The substitutes are more
expensive than the asbestos product, but they have generally been able to
match its performance along the critical dimensions.
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REFERENCES
Babcock & Wilcox Co. T. Viverito. 1986 (October 14). Augusta, GA
Transcribed telephone conversation with Peter Tzanetos, 1CF Incorporated,
Washington, D.C.
Carborundum Corp. C. Demske. 1986 (October 14). Niagara Falls, NY.
Transcribed telephone conversation with Peter Tzanetos, ICF Incorporated,
Washington, D.C.
Cotronics Corp. Representative. 1986 (October 14). Brooklyn, NY.
Transcribed telephone conversation with Peter Tzanetos, ICF Incorporated,
Washington, D.C.
Hollingsworth & Vose. Stowte Ellsworth. 1983. East Walpole, MA.
Transcribed telephone conversation with E, Malitz, ICF Incorporated,
Washington, D.C.
ICF Incorporated. 1984, Imports of Asbestos Mixtures and Products.
Washington, D.C.: Office of Pesticides and Toxic Substances, U.S.
Environmental Protection Agency. EPA Doc. Control No. 20-8600681,
ICF Incorporated. 1985. Appendix K: Asbestos Products and Their
Substitutes, in Regulatory Impact Analysis of Controls on Asbestos and
Asbestos products. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency.
ICF Incorporated. 1986 (July-December). Survey of Primary and Secondary
Processors of Asbestos Commercial Paper. Washington, D.C.
Krusell N, Cogley D. 1982, GCA Corp. Asbestos Substitute Performance
Analysis. Revised Final Report. Washington, D.C.: Office of Pesticides and
Toxic Substances, U.S. Environmental Protection Agency. Contract Number
68-02-3168.
Lydall Corporation. Mr. Devoe. 1983. Rochester, NH. Transcribed telephone
conversation with E. Malitz, ICF Incorporated, Washington, D.C.
TSCA Section 8(a) submission, 1982a, Production Data for Primary Asbestos
Processors, 1981. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. EPA Document Control No,
20-8601012.
TSCA Section 8(a) submission. 1982b. Production Data for Secondary Asbestos
Processors, 1981. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. EPA Document Control Ne.
20-8670644.
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II. ROLLBOARD
A.	Product Description
Rollboard is a paper product that is used to protect against fire, heat,
corrosion, and moisture. It is a thin and flexible material composed
basically of two sheets of paper laminated together with sodium silicate,
Rollboard can be cut, folded, wrapped, and rolled. In addition, it can be
molded around sharp corners (Krusell and Cogley 1982).
The primary constituent of asbestos rollboard is asbestos fiber. The
balance consists of binders and fillers. The asbestos content can range from
60 to 95 percent by weight, but 70 to 80 percent is considered typical.
Frequently used binders include starches, elastomers, silicates, and cement;
common fillers are mineral wool, clay, and lime (Krusell and Cogley 1982).
Rollboard is manufactured in a process similar to that used for millboard
production, but it is produced in a continuous sheet. The ingredients are
mixed together and combined with water. This mixture is then fed into a
conventional cylinder paper machine where heat and heavy rollers are applied
to produce a uniform board. The material is then dried. The final steps are
to laminate two of these sheets together, allow them to set, and to package
the finished rollboard product.
Rollboard can be used in many industrial applications -- it can be used as
a gasket and as a fire-proofing agent for security boxes, safes, and files.
Its commercial uses include office partitioning and garage paneling, while its
residential uss include linings for stoves and electric switch boxes.
B.	Producers and Importers of Asbestos Rollboard
There were no domestic primary or secondary processors of asbestos
rollboard in 1981, although a Johns-Manville Corp. (now Manville Sales Corp.)
plant in Waukegan, 1L was still selling the product out of inventory (TSCA
1982a, TSCA 1982b). In addition, a 1984 survey of importers failed to
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identify any importers of asbestos rollboard (ICF 1984). The Waukegan, IL
plant no longer produces or sells asbestos rollboard (ICF 1986), Because none
of the other respondents to our survey indicated either that they had begun
the production of asbestos rollboard in the period since the previous survey,
or that they were aware of any other distributors or importers of this
product, we have concluded that there are currently no domestic producers or
consumers of asbestos rollboard,
C.	Trends
There was no production of asbestos rollboard in 1981 and there was still
no production of asbestos rollboard in 1985. Small amounts of asbestos
rollboard were being sold out of inventory in 1981, but this bad ceased by
1985.
D.	Substitutes
Most non-asbestos rollboards in the market today are made of ceramic
fibers. Information on asbestos rollboard and its substitutes is summarized
in Table 1.
Cotronics Corporation manufactures ceramic paper which is the primary
substitute for asbestos rollboard (ICF 1985). It is made from high purity
asbestos-free refractory fibers. Even though the product is sold in paper
rolls, it can be made into free standing shapes such as rollboards. The
continuous service temperature is 2300"F and applications include insulation
materials and high temperature gaskets for furnaces, electrical wire
insulation, kiln construction, and cushioning in furnace construction.
Ceramic paper has low specific heat, low thermal conductivity, and has
resistance to thermal shock and corrosion (Cotronics 1986) .
Carborundum Corporation manufactures two asbestos rollboard substitutes.
The first is Fiberfrax 550(R), It is a paper product made of alumina-silicate
(ceramic) fiber and contains approximately 8 percent organic binder. It is
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Table 1. Substitutes fat Asbestos Eollioard
Product
Manufacturer
Advantages
Disadvantages
References
Asbestos Rollboard
Hone
Fire, heat, tot, and corrosion
resistant.
t.ong service 1 if ,
Low cost,
EnvironmentHi end occupational
health problem,
Kruaoll and Cog! f-y (1982)
ICF (1986)
Fibdrfrnt 550(R)
Carborundum Corp.
Niagara Falls, KTY
Bigh temperature use limit
(2300'F).
Resistant to chemical attack.
Good handling strength.
Poor resistance to acids and
alkalies.
Carborundum (1986)
Fiberfrai 970
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resistant to most chemical attacks with the exception of acids and alkalies.
It also possesses good handling strength and has a continuous use temperature
of 2300*F.* Fiberfrax 550{R) is .designed specifically for applications where
high temperature protection is more critical than heat retention. Typical
applications of Fiberfrax 550(E) are industrial gasketing, liquid metal back-
up insulation, brazing furnace insulation, and as an investment casting
parting agent (Carborundum 1986).
The second asbestos rollboard substitute produced by Carborundum
Corporation is Fiberfrax 970(R). It is also a ceramic paper product, and it
contains approximately 6 percent organic binder. Fiberfrax 97Q(R) is noted
for its exceptionally low thermal conductivity and good handling properties.
Fiberfrax 970(R) is less suitable as an asbestos rollboard substitute because
it lacks strength and rigidity; however, it does possess some of the favorable
characteristics found in Fiberfrax 550(R) such as high temperature stability,
resiliency, and excellent corrosion resistance. Typical applications of
Fiberfrax 970(R) include high temperature gaskets, combustion chamber linings,
thermal and electrical insulation, and glass furnace blow pipe insulation
(Carborundum 1986),
Babcock & Wilcox produces non-asbestos ceramic rollboard made of
Kaowool(R) which consists either of Kaolin, a natural occurring alumina-silica
fireclay, or a blend of high purity alumina and silica. Kaowool(R) rollboard
has a maximum temperature use limit of 2300"F, and it possesses good chemical
stability with resistance to most chemicals. Kaowool rollboard is designed to
replace asbestos rollboard in many non-furnace applications such as laundry
and trough linings, gasketing between trough sections, glass conveyer rolls,
The continuous use temperature of asbestos rollboard could not be
determined because the product is no longer produced. However, it is likely
to have been approximately 1000F, the continuous use temperature of standard
asbestos millboard, a product with a very similar composition.
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boiler jacket insulation, electrical appliance insulation, and radiator covers
(Babcock & Wilcox 1986).
The use of asbestos rollboard was very limited and the substitutes are
generally able to match or exceed the performance of the asbestos product.
The price of asbestos rollboard in 1981 was approximately $l,00/lb. (ICF
1985). The current prices for the various substitutes are presented in
Table 2. It is clear that the complete substitution away from asbestos
rollboard has resulted in a higher price.
E. Summary
Domestic production or consumption of asbestos rollboard did not take
place in 1985. This has resulted in complete substitution of asbestos
rollboard with other substitute products. The substitute products are more
expensive, but they have generally been able to match or exceed the
performance of asbestos rollboard.
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Table 2. Prices of Asbestos Rollboard and Its Substitutes
(in /lb.)
Product	Manufacturer	Price	Reference
Asbestos Rollboard None	N/A	1CF (1986)
Ceramic Paper	Cotronics Corp, $8.27-$12.40 Cotronics (1986)
Brooklyn, NY
Fiberfrax 550(R) Carborundum Corp.	$5,92 Carborundum (1986)
Niagara Falls, NY
Fiberfrax 970(R)	Carborundum Corp, $10.24 Carborundum (1986)
Niagara Falls, NY
Kaowool(R)	Babcock & Wilcox	$5.70 Babcock & Wilcox (1986)
Augusta, GA
N/A: Not Applicable.
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REFERENCES
Babcock & Wilcox Co. T. Viverito.
Transcribed telephone conversation
Washington, D,C,
1986 (October 14). Augusta, GA.
with Peter Tzanetos, ICF Incorporated,
Carborundum Corp. C. Demske, 1986 (October 14). Niagara Falls, NY.
Transcribed telephone conversation with Peter Tzanetos, ICF Incorporated,
Washington, D,C,
Cotronics Corp. Representative. 1986 (October 14). Brooklyn, NY.
Transcribed telephone conversation with Peter Tzanetos, ICF Incorporated,
Washington, D.C.
ICF Incorporated. 1984, Imports of Asbestos Mixtures and Products.
Washington, D.C.; Office of Pesticides and Toxic Substances, U.S.
Environmental Protection Agency, EPA Doc, Control No, 20-8600681.
ICF Incorporated. 1985. Appendix H: Asbestos Products and Their
Substitutes, in Regulatory Impact Analysis of Controls on Asbestos and
Asbestos products. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency.
ICF Incorporated. 1986 (July-December), Survey of Primary and Secondary
Processors of Asbestos Rollbosrd. Washington, D.C.
Krusell N, Cogley D. 1982. GCA Corp. Asbestos Substitute Performance
Analysis. Revised Final Report. Washington, D.C.: Office of Pesticides and
Toxic Substances, U.S. Environmental Protection Agency, Contract Number
68-02-3168.
TSCA Section 8(a) submission. 1982a. Production Data for Primary Asbestos
Processors, 1981. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. EPA Document Control No.
20-8601012.
TSCA Section 8(a) submission.	1982b. Production Data for Secondary Asbestos
Processors, 1981. Washington,	D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. EPA Document Control No.
20-8670644.

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III. MILLBOARD
A. Product Description
Asbestos millboard is essentially a heavy cardboard product that can be
used for gasketing, insulation, fireproofing, and resistance against corrosion
and rot. The primary constituent of this product is asbestos fiber, with the
balance consisting of binders and fillers. The asbestos content ranges from
60 to 95 percent, but 70 to 80 percent is considered typical. Frequently used
binders are starches, elastomers, silicates, and cement; common fillers
include mineral wool, clay, and lime (Krusell and Cogley 1982),
Millboard is manufactured in essentially the same way as paper. The
ingredients are mixed together and combined with water. This mixture is then
%
fed into a conventional cylinder paper machine where heat and heavy rollers
are applied to produce a uniform board. The material is cut lengthwise and
then removed for final drying. Standard size millboards are_.42 x 48 inches
and 1/4 to 3/4 inches thick. The most popular millboards are 1/4 and 1/2 inch
thick. Asbestos millboards are very similar to asbestos commercial paper and
are differentiated primarily by their thickness and lower fiber composition
than commercial paper.
Millboard is also sold in different grades. Differences between millboard
grades reflect their ability to withstand elevated temperatures. Standard
asbestos millboard is able to withstand temperatures of 1000"F, while premium
millboard can withstand temperatures well above 2000F (Quin-T 1986a),
The uses of asbestos millboard are numerous. Specific industrial
applications include linings in boilers, kilns, and foundries; insulation in
glass tank crowns, meIters, refiners, and sidewalls in the glass industry;
linings for troughs and covers in the aluminum, marine, and aircraft
industries; and thermal protection in circuit breakers in the electrical
industry. In addition, thin millboard is inserted between metal to produce
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gaskets. Commercial applications for millboard include fireproof linings for
safes, dry-cleaning machines, and incinerators. Asbestos millboard had been
used in residential applications, but this application has ceased (Quin-T
1986b).
B. Producers and Importers of Millboard
There were five primary processors of asbestos millboard in 1981; Celotex
Corporation, GAF Corporation, Johns-Manville Corporation, Nicolet, Inc., and
Quin-T Corporation (TSCA 1982a). Celotex Corporation, Johns-Manville
Corporation (now Manville Sales Corporation), and Nicolet, Inc. have since
stopped producing asbestos millboard. However, Nicolet, Inc. continues to
sell the product out of inventory. GAF Corporation sold their plant in Erie,
PA to Quin-T Corporation, and that plant is still producing asbestos
millboard. The other Quin-T Corporation plant in Tilton, NH still produces an
asbestos product, but they have decided to reclassify it as electrical paper.
Therefore, there is currently only one domestic primary processor of asbestos
millboard. That plant consumed 436 tons of asbestos fiber in producing 581
tons of asbestos millboard in 1985 (1CF 1986).
There were eight secondary processors of asbestos millboard in 1981 (TSCA
1982b). Since that time, four companies have stopped processing asbestos
millboard. The four companies which still process asbestos millboard are;
Capital Rubber & Specialty Company, Fluorocarbon Metallic Gasket Division of
Sepco Company, Lamons Metal Gasket Company, and Parker Hannafin Corporation.
All four companies process millboard for producing gaskets. Capital Rubber
and Specialty Company imported millboard in 1985; no other importers of
asbestos millboard were identified (ICF 1984; ICF 1986). The other three
companies purchased approximately 120 tons of asbestos millboard (ICF 1986).

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C,	Trends
Total annual production of asbestos millboard has declined dramatically
from 2,767 tons in 1981 to 581 tons in 1985. This decline may be somewhat
overstated because Quin-T Corporation's plant in Tilton, NH believes that
their 1981 millboard production should have been classified as electrical
paper. Nonetheless, this decline is expected to continue, and Quin-T
Corporation's plant in Erie, PA plans to stop producing asbestos millboard in
1988 (Quin-T 1986a).
D,	Substitutes
The major advantages of asbestos millboard are its resistance to heat,
fire, rot, and corrosion; its tensile strength, and its low price. In
general, the substitutes can match or exceed the heat and fire resistance of
asbestos millboard, but they do not offer as much rot or corrosion resistance
or as much tensile strength. In addition, all the substitutes are more
expensive. Despite these drawbacks, the substitutes are expected to perform
adequately enough to replace asbestos millboard in all its current uses.
For the purposes of this analysis, the substitutes have been grouped into
two categories -- standard boards and premium boards. This has been done
because the performance characteristics of the boards within each category
are similar, even though their exact chemical compositions are different. The
performance characteristics across categories are, however, different. The
advantages, disadvantages, and prices of asbestos millboard and its
substitutes are presented in Table 1.
The major substitutes for asbestos millboard fall into the standard board
category. The Quin-T Corporation produces a standard board known as mineral
board which can replace asbestos millboard. This product is composed of a
proprietary combination of inorganic fillers. It can withstand temperatures
up to 1000F and can replace millboard in many of its applications, even
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Table 1. Substitute* for Asbestos Millboard
Product
Manufacturer
Advantages
Dlsedvantaftea
References
Asbestos Millboard
Quin-T Corp.
Erie. PA
Fire, boat, and rot resistant.
Corrosion resistant.
Low coat.
Potential environmental and
occupational hoa1th problems.
Krusell and Cogley (1992)
Standard Board
Qulrt-T Corp.
Erie, PA;
Sicolet, Inc.
Ambler, PA
Temperature use limit of 850-
10D0*F.
Not combustible.
Low tensile strength.
High cost.
Quin-T (1986a)
Hicolet (n.d.)
Babeock & Wilcox (1986)
Carborundum C1986)
Cotronics (n.d.)
JanOS (I986)
Hicolet (n.d.
Brooklyn. NY;
Janos Corp.
Hoonachie, NJ;
RicoLst, ID.
Ambler, FA
Premium Board
Babcoclt & Wilcox Co,
Augusta, GA;
Carborundum Corp.
Hi agara Falls, NY;
Cotronics Corp.
Temperature use limit of 1500-
2300'F.
Not combustible,
Heat resistant.
Lam tensile strength,
fligb cost.

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though it has a lower tensile strength.. It costs over $1.23/lb. (Quin-T
1986a).
Nicolet, Inc. produces a non-asbestos standard board known as Nampro
901(R). this product is a cement-bound millboard and can be used in gaskets,
electric ovens, strong-box liners, and welding pads. It has a temperature use
limit of 850F (1200? if strength loss is not detrimental) (Nicolet n.d.).
It costs $1.33/lb. (Nicolet 1986), It has been estimated that these two
standard boards will combine to take 80 percent of the asbestos millboard
market if asbestos is banned (Quin-T 1986a).
The remaining substitutes for asbestos millboard fall into the premium
board category. They are more expensive, but they have much higher
temperature resistance. Janos Industrial Insulation Corporation purchases a
premium board called Nuboard 1800(R) from a British manufacturer and
distributes it in the U.S. This board consists primarily of mineral fibers
and silica. Nuboard 1800(R) can withstand temperatures up to 1800*F. This
product can replace asbestos in many of its premium uses, even though it has a
lower tensile strength. It costs $2.92/lb. (Janos 1986).
Nicolet, Inc. produces a premium non-asbestos board known as Nampro
911(R). This product is an inorganic-bound millboard and can be used in kiln
liners, incinerator liners, induction-furnace liners, and ingot-mold liners.
It has a temperature use limit of 1500*F (2100F if strength loss is not
detrimental (Nicolet n.d.). It costs $2.46/lb. (Nicolet 1986),
Babcock & Wilcox Company produces a premium non-asbestos board made of
Kaowool(R). Kaowool(R) consists either of Kaolin, a naturally occurring
alumina-silica fireclay or a blend of high purity alumina and silica, Kaowool
board has a maximum temperature use limit of 2300*F and possesses good
chemical stability with resistance to most chemicals. Kaowool can replace
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asbestos millboard in almost all its premium applications, and it costs
$4.70/lb. (Babcock & Wilcox 1986).
Cotronics Corporation produces a premium non-asbestos board called Ceramic
Board 360(R). This product is made from high purity refractory fibers which
are interlaced and bonded with an inorganic binder. It is resistant to
oxidizing and reducing atmospheres, molten non-ferrous metals, steam, and most
chemicals and solvents. It also has a continuous use' temperature of 2300*F,
it can be used in rigid high temperature gaskets, heat shields, chemical
reactor insulation, and brazing fixture supports; it costs $1.88/lb.
(Cotronics n.d.).
Carborundum Corporation produces a premium non-asbestos board called GH
Board made of Fiberfrax(R). Fiberfrax(R) consists mainly of ceramic fibers
and has a temperature use limit of 2300*F, In addition, Fiberfrax(R) will
work well in electrical insulating applications because it has a low
dielectric constant and does not conduct electricity. GH board can substitute
for asbestos in all applications where tensile strength is not important, and
it costs $5.05/lb. (Carborundum 1986). The premium boards are estimated to
take the remaining 20 percent of the asbestos millboard market if asbestos is
banned (Quin-T 1986a). All the inputs for the Regulatory Cost Model are
presented in Table 2.
E. Snuiraarv
Asbestos millboard is essentially a heavy cardboard product which can be
used for gasketing, insulation, fireproofing, and resistance against corrosion
and rot. It is typically used in gasketing applications and as a liner in
industrial boilers, furnaces, and kilns.
The only processor of asbestos millboard in 1985 was Quin-T Corporation's
Erie, PA plant. This plant consumed 435 tons of asbestos and produced 581
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tons of millboard. Quin-T Corporation plans to stop processing asbestos in
1988.
The major substitutes for asbestos millboard are mineral boards. If
asbestos were banned, it is estimated that standard mineral boards would
capture 80 percent of the market and that premium mineral boards would capture
the remaining 20 percent. The price of asbestos millboard is $0.88/lb. The
average price of standard mineral board is $1.28/lb. and the average price of
premium mineral board is $3.4Q/lb.
- 8 -

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ATTACHMENT
The projected market Shares for standard board and for premium board were
estimated by Ray Heidt, Sales Manager, Quin-T Corporation (the only domestic
producer of asbestos millboard).
The price of standard board was computed by averaging the prices of the
two standard board products. The average of Quin-T Corporation's mineral
board ($1.23/lb.) and Nicolet, Inc.'s Nampro 901(R) ($1.33/lb.) is $1.28/lb.
The price of premium board was computed by averaging the prices of the
five premium board products. The average of Janos Corporation's Nuboard
1800(R) ($2,92/lb.)t Nicolet Inc.'s Nampro 911(R) ($2.46/lb.) Cotronics
Corporation's Ceramic Board 360(R) ($1.88/lb.), Babcock & Wilcox Company's
Kaowool(R) board ($4.70/lb.), and Carborundum Corporation's GH Board(S)
($5.05/lb.) is $3.40/lb.
9

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REFERENCES
Babcock & Wilcox Go. T. Viverito. 1986 (October 14), Augusta, GA,
Transcribed telephone conversation with Peter Tzanetos, ICF Incorporated,
Washington, D.C.
Carborundum Corp. Applications Engineer, 1986 (November 10). Niagara Falls,
NY. Transcribed telephone conversation with Peter Tzanetos, ICF Incorporated,
Washington, D.C.
Cotronics Corp. (n.d.) Product Literature. Ceramic Board. Brooklyn, NY.
ICF Incorporated. 1984. Imports of Asbestos Mixtures and Products.
Washington, D.C.: Office of Pesticides and Toxic Substances, U.S.
Environmental Protection Agency. EPA Doc. Control No. 20-8600681.
ICF Incorporated. 1986 (July-December). Survey of Primary and Secondary
Processors of Asbestos Millboard. Washington, D.C.
Janos Industrial Insulation Corp. Sales Representatives. 1986 (November 10
and December 5). Moonachie, NJ. Transcribed telephone conversations with
Peter Tzanetos, ICF Incorporated, Washington, D.C.
Krussel N, Cogley D. 1982. GCA Corporation. Asbestos Substitute Performance
Analysis, Revised Final Report, Washington, DC: Office, of Pesticides and
Toxic Substances, U.S. Environmental Protection Agency. Contract 68-02-3168.
Nicolet, Inc. (n.d.) Product Literature. Asbestos-Free Millboard. Ambler,
PA 19002.
Nicolet, Inc. Sales Representative. 1986 (December 4). Transcribed
telephone conversation with Peter Tzanetos, ICF Incorporated, Washington, D.C,
Quin-T Corp. R. Heidt. 1986a (July-November). Erie, PA. Transcribed
telephone conversations with Peter Tzanetos and Eric Crabtree, ICF
Incorporated, Washington, D.C.
Quin-T Corp, E. Kovykio. 1986b (November 11). Erie, PA. Transcribed
telephone conversation with Peter Tzanetos, ICF Incorporated, Washington, D.C,
TSCA Section 8(a) submission. 1982a. Production Data for Primary Asbestos
Processors, 1981. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. EPA Document Control No.
20-8601012.
TSCA Section 8(a) submission. 1982b, Production Data for Secondary Asbestos
Processors, 1981. Washington, D.C.: Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. EPA Document Control No.
20-8670644.
10 -

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IV. ASBESTOS PIPELINE WRAP
A. Product Description
Pipeline wrap is an asbestos felt product, ' It is composed of at least 85
percent asbestos with the balance being cellulose fibers and binders such as
starch and latex. It is manufactured on conventional papermaking machines in a
process similar to that of asbestos roofing felt. The ingredients are combined
and mixed with water. This mixture is then fed through a series of machines
that apply heat and heavy rollers to produce a felt of uniform thickness. The
felt is then coated by pulling it through a bath of hot asphalt or coal tar
until it is thoroughly saturated. The paper then passes over another series of
rollers which set the coal tar or asphalt onto the felt. Next, it passes over
a series of cooling rollers that reduce the temperature and provide a smooth
surface finish. The felt is finally air-dried, rolled, and packaged for
marketing (Krusell and Cogley 1982).
Pipeline wrap is primarily used by the oil and gas industry for coating
its pipelines.^- There is also some use by the chemical industry for
underground hot water and steam piping. Pipeline wrap is occasionally used in
above-ground applications, such as for special piping in cooling towers.
Pipeline wrap itself is only one product used in the coal tar enamel method
of coating pipes. The coal tar enamel process involves five steps. First, a
primer is applied directly onto the pipe. Second, when the primer dries,
heated coal tar is applied to the pipe as it is rotated. Third, a glass mat is
applied over the coal tar. Fourth, the asbestos felt is wrapped onto the pipe
by high-speed wrapping machines. Finally, the pipe is coated
^The Department of Transportation has mandated that all oil and gas
pipelines be coated.
- 1 -

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with kraft paper^ (Power 1986a). The asbestos felt helps protect the pipe from
moisture, corrosion, rot, and abrasion.
B.	Producers and Importers of Asbestos Pipeline Wrap
There were three primary processors and one secondary processor of asbestos
pipeline wrap in 1981. The primary processors were: Celotex Corporation,
Johns-Manville Corporation (now Manville Sales Corporation), and Nicolet,
Incorporated (TSCA 1982a). The secondary processor was Aeroquip Corporation
(TSCA 1982b). There are currently no domestic processors of asbestos pipeline
wrap (ICF 1986). However, Nicolet, Inc. is selling the product out of
inventory and may restart production if demand warrants it (Nicolet 1986a). In
addition. Power Marketing Group distributes asbestos pipeline wrap which it
imports from Manville Sales Corp. (formerly Johns-Manville Corp.) plants in
Canada. No other importers of asbestos pipeline wrap were identified, and
neither firm is aware of any other producers or distributors of this product in
the U.S. (ICF 1984; ICF 1986).
C.	Trends
In 1981, 2,150,615 squares of asbestos pipeline wrap were produced (TSCA
1982b). Nicolet, Inc. has refused to divulge information on 1985 fiber
consumption or pipeline wrap output. Power Marketing Group has provided
information from which one can estimate output and fiber consumption for both
companies. Total fiber consumption and pipeline wrap production are presented
in Table 1. Finally, it should be noted that 1986 output may be much lower
because Nicolet, Inc. has stopped producing the product and is only selling it
out of inventory.
^Kraft paper consists of wood and cellulose fibers,
- 2 -

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Table 1. 1985 Asbestos Fiber Consumption and
Asbestos Pipeline Wrap Production3
Fiber Consumption Pipeline Wrap Production
(in short tons)	(in squares
Total	3,333.3	742,383
Computations underlying these estimates are in the Attachment.
^1 square - 100 square feet
- 3 -

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D. Substitutes
The use of asbestos in pipeline wrap is desirable because of its resistance
to chemicals, rotting, and decay; its dimensional stability; and its heat
resistance (Rood 1986). It is also unaffected by corrosive environments,
cannot be attacked by vermin, and performs in the most severe salt water
conditions (Power 1986a), These qualities are important for underground
pipeline wrap that is used to prevent the deterioration of pipeline buried in
earth or under water.
Power Marketing Group and Nicolet, Inc. both sell a non-asbestos mineral felt
which can be used instead of asbestos pipeline wrap. Power Marketing Group
sells its mineral felt for $5.80/100 square feet, the same price as its
asbestos felt. This product appears to have the same advantages as the
asbestos product -- resistance to chemicals, rotting, and decay; dimensional
stability; and heat resistance (Power 1986b). However, it does not have the
proven track record of asbestos felt because it is a new product. There are
instances of asbestos pipeline wrap being in the ground for over fifty years, a
track record which makes companies reluctant to replace this successful and
proven product.
Nicolet, Inc. refers to its mineral felt as Safelt(R). Safelt(R) is a
combination of minerals, fibers, and binders. It contains a minimum of 75
percent non-biodegradable components. Safelt(R) is available in two types --
960 and 966. Safelt 966 is more dense and is therefore sold in a thinner layer
(Nicolet n.d.). They are both priced $6.20/100 square feet (Nicolet 1986a),
but product literature states that application costs are lower than asbestos
wrap because of their superior wrapping characteristics (Nicolet n.d.). This
characteristic is not modeled because Nicolet officials would not quantify this
advantage and coaters could neither confirm or deny its existence.
Power Marketing Group also sells a fiberglass felt called Duraglass(R). It
- 4 -

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is priced $5,80/100 square feet. They have had problems, however, in using it
in the coal tar enamel method because it does not seem to bond well. Power
Manufacturing is currently in the process of reformulating the product in order
to rectify this problem (Power 1986b). A summary of the characteristics of the
asbestos substitutes is presented in Table 2.
The All American crude oil pipeline, a major cross-country pipeline, is being
coated with a new coal tar system which does not use any asbestos or mineral
felt. A 20 mil thickness of coal tar enhanced urethane is applied first. It
is followed by a 1.5 inch urethane foam layer. The final step is to apply &
covering of Polykin tape (Pipeline Digest 1986). Since this method has no
history, we do not know its advantages and disadvantages.
These are the only direct substitutes for asbestos pipeline wrap in the coal
tar enamel method of coating pipes. However, there are seven other methods of
coating pipes: asphalt enamel, thin-film powder, bonded polyethylene, tape,
extruded polyethylene, sintered polyethylene, and insulation (Pipeline Digest
1986). The 1985 market shares and output levels for these processes are
presented in Table 3.
The coal tar enamel method is the only method of coating pipes that presently
uses asbestos pipeline wrap. In 1985 it accounted for 14.39 percent of the
pipeline coating market (Pipeline Digest 1986). In the event of an asbestos
ban, pipeline coaters and oil industry representatives believe that asbestos
felt used in the coal tar enamel method will be replaced by mineral and
fiberglass felts, both of which are good substitutes (Arco 1986, Energy
Coatings 1986). They do not expect the market share (14.39 percent) held by
the coal tar enamel method to be taken over by any one or all of the other
seven methods just because asbestos felt will be unavailable. Thus, it has
- 5 -

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Table 3. 1985 Market Shares and Output of
Pipeline Coating Processes
Process
Output
(square feet)
Market Share
(percent)
Asphalt Enamel
Coal Tar Enamel
Thin-Film Powder
Bonded Polyethylene
Tape	8,251,037
Extruded Polyethylene
Sintered Polyethylene
Insulation 15,602,441
200,000
88,439,891
263,807,418
28,293,723
1.34
196,255,978
13,704,375
2.54
0.03
14.39
42.39
4.60
31.93
2.23
Source: Pipeline Digest (1986).
- 7 -

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been assumed that substitution will be entirely for asbestos felt rather than
for the coal tar enamel method.
The inputs for the Regulatory Cost Model are presented in Table 4, It has
been assumed that Power Marketing Group or some other company will formulate a
more successful fiberglass felt which will take 20 percent of the market (Areo
1986). The remaining 80 percent of the market will be taken by mineral felt.
Because this is a new product, there is no data on projected market shares. As
a result, it is assumed that the current market shares of the producers of the
asbestos product will apply to the substitutes as well.^ This will result in a
48 percent (0.80 x 0.60) projected market share for Power Marketing Group's
mineral felt and a 32 percent (0.80 x 0,40) projected market share for
Safelt(R) (Nicolet's mineral felt),
E, Summary
Asbestos pipeline wrap is a felt product used in the coal tar enamel method
of coating pipes. This product is not being produced in the U.S., although one
company was selling it out of inventory and another company was importing it
from Canada and distributing it. Total domestic production of this product is
estimated to have been 296,949 squares in 1985,
It has been assumed that adequate substitutes exist for asbestos felt, and,
therefore, pipeline coaters will not switch to alternate methods of coating
pipes in the case of a complete asbestos ban. It is estimated that 20 percent
of the market will be taken by fiberglass felt that costs $5.80/square. The
remaining 80 percent will be taken by mineral felts. Because the two
distributors of asbestos felt are also the major distributors of mineral felt,
it is assumed that they will both retain their current market shares. Hence
Power Marketing's mineral felt will capture 48 percent of the
^We cannot look at the trends in market shares because 1981 data for
Power Marketing Group are not available.
- 8 -

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market at a price of $5.80/square, and Nicolet's Safelt(R) will capture 32
percent of the market at a price of $6.20/square.
- 10 -

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ATTACHMENT
The asbestos fiber consumption and asbestos pipeline wrap output for Power
Marketing Group and Nicolet, Inc. were computed using the following
methodology. Power Marketing Croup estimated that 100 square feet of saturated
pipeline felt weigh 13 lbs. Because the saturated felt is 23 percent asphalt
or tar coating, the unsaturated felt weighs 10.57 lbs. (13/1,23). Because the
unsaturated felt is approximately 85 percent asbestos, 100 square feet of
pipeline wrap contain 8.98 lbs. of asbestos (10.57 * .85). Therefore, the
asbestos product coefficient is 0.00449 (8.98 lbs./square / 2,000 lbs./ton)
tons square.
- 11

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REFERENCES
Arco Oil & Gas Company. J. Murray. 1986 (November 24). Transcribed telephone
conversation with Peter Tzanetos, ICF Incorporated, Washington, B.C.
Energy Coating Company, W. Heineman. 1986 (November 3). Transcribed
telephone conversation with Peter Tzanetos, ICF Incorporated, Washington, D.C.
ICF Incorporated. 1984. Imports of Asbestos Mixtures and Products.
Washington, D.C.: Office of Pesticides and Toxic Substances, U.S.
Environmental Protection Agency. EPA Doc. Control No. 20-8600681.
ICF Incorporated. 1986 (July-December), Survey of Primary and Secondary
Processors of Asbestos Pipeline Wrap. Washington, D.C,
Krusell N, Cogley D. 1982. GCA Corp, Asbestos Substitute Performance
Analysis. Revised Final Report. Washington, D.C.: Office of Pesticides and
Toxic Substances, U.S. Environmental Protection Agency, Contract Number
68-02-3168.
Nicolet, Inc. Sales Representative. 1986a (November 11). Transcribed
telephone conversation with Peter Tzanetos, ICF Incorporated, Washington, D.C.
Nicolet, Inc. R. Hittinger. 1986b (November 5). Transcribed telephone
conversation with Peter Tzanetos, ICF Incorporated, Washington, D.C.
Nicolet, Inc. (n.d.). Product Literature. Safelt. Ambler, PA 19002,
Pipeline Digest. 1986 (April 7). Pipe Coating Survey. Houston, TX.
Power Marketing Group. 1986a. Public comment brief on asbestos pipeline wrap
submitted to U.S. Environmental Protection Agency, Washington, D.C,
Power Marketing Group. J. Toerner. 1986b (October 24 and October 31).
Houston, TX. Transcribed telephone conversations with Peter T2anetos, ICF
Incorporated, Washington, D.C.
Power Marketing Group. G. Pytko. 1987 (January 30). Denver, CO 80231,
Letter to Peter Tzanetos, ICF Incorporated, Washington, D.C. 20006.
Rood K. 1986 (October 31). Independent consultant (former employee of Johns-
Manville Corporation). Transcribed telephone conversation with Feter Tzanetos,
ICF Incorporated, Washington, D.C.
TSCA Section 8(a) Submission. 1982a, Production Data for Primary Asbestos
Processors, 1981. Washington DC; Office of Toxic Substances, U.S.
Environmental Protection Agency. EPA Docuaent Control No. 20-8601012,
TSCA Section 8(a) Submission, 1982b. Production Data for Secondary Asbestos
Processors, 1981. Washington DC: Office of Toxic Substances, U.S.
Environmental Protection Agency. EPA Document Control No. 20-8670644.
12 -

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V. BEATER-ADD GASKETS
A. Product Description
Gaskets can be described as materials used to seal one compartment of a
device from another in non-dynamic applications such as engine and exhaust
manifolds. Asbestos gaskets, used mainly to seal connections and prevent
leakage of fluids between solid surfaces, can be classified into two
categories: beater-add and compressed sheet. Compressed sheet gaskets are
discussed in Section XXVII.
Asbestos beater-add gaskets, are less dense, use shorter asbestos fibers,
and have lower tensile strength than compressed asbestos sheet gaskets.
Consequently, beater-add gaskets are used in less severe applications and at
temperatures ranging up to 750F. At temperatures between 250-750T asbestos
beater-add gasketing can withstand pressure ranging between vacuum and 1,000
psi (Union Carbide 1987). Beater-add gasketing comes in a continuous roll
form (reducing waste during die cutting), is more dimensionally uniform, and
is less expensive than sheet gasketing (ICF 1986).
Asbestos beater-add gasketing is manufactured^ by a technique employing a
paper making process, using fourdrinier or cylindrical paper machines to make
paper from a viscous slurry of asbestos and liquid binders. The asbestos
fibers are incorporated within various elastomeric binders and other fillers
to form the beater-add paper. These products are used extensively for
internal combustion applications and for the sealing component of spiral wound
gaskets (Union Carbide 1987). Beater-add gaskets generally contain 60 to 80
percent asbestos in combination with 20 to 40 percent binders and are used
primarily in the transportation and chemical industries as:
^-The binder is added during the beater process, hence the name
"beater-add".
- 1 -

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 head, carburetor, exhaust manifold, and transmission
gaskets to prevent leakage of oil, fuel, water, gas, or low
pressure steam in automobiles, trains, airplanes, and
ships; and,
 flange, spiral wound, and general service industrial
gaskets to prevent leakage and potential reactions of
chemicals in reactors, compressors, heat exchangers,
distillation columns, and similar apparatus (1CF 1986),
The particular binder used in a beater-add paper determines the material's
suitability for use in water, oil, fuel, or chemical environments. Since the
proportion of fiber to binder determines the intended temperature range,
different grades of asbestos beater-add gaskets are available for different
temperature use limits. Latex is the most popular binder, but styrene~
butadiene, acrylic, acrylonitrile, neoprene, fluoroelastomeric polymers,
rubber, polytetrafluoroethylene (PTFE), and silicone polymers are also used
(Krusell and Cogley 1982).
Gasketing paper is usually produced in a sheet or sheet roll that varies
in thickness from approximately 1/64 inch to 3/16 inch. Gaskets are
fabricated to customer-specified sizes and dimensions from these sheet rolls.
They may be used in this form with no further fabrication required, or they
may be processed further by reinforcing them with wire insertions or by
jacketing the paper with various metal, foils, plastics, or cloth (1CF 1986).
B. Producers and Importers of Asbestos Beater-Add Gasketing
In 1985, four companies, at five locations, Armstrong World Industries
(Fulton, NY), Hollingsworth & Vose (East Walpole, MA), Lydall Corp. (Hoosick
Falls, NY and Covington, TN), and Quin-T Corporation (Erie, PA) produced
asbestos beater-add gasketing. A fifth company, Boise Cascade Corporation
(Beaver Falls, NY) produced beater-add gaskets in 1981, but did not supply
information for the ICF survey. In order to account for the estimated
production of this company, a methodology was developed to allocate the
industry averaged trend to the non-responding companies (Appendix A). The
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consumption in this category for 1985 is estimated, therefore, to be 12,436,4
tons of fibers used to produce 16,505 tons of beater-add gasketing. fable 1
lists the total production of beater-add gaskets. The beater-add gasketing
market was estimated to be worth $24.8 million in 1985, based on an average
price of $0.75 per pound (ICF 1986).
Beater-add gasketing is not imported to the United States. Beater-add
gaskets^ were, however, imported by foreign automobile manufacturers.
Kawasaki, Toyota, and Suzuki have in total reported imports of 361.35 tons.
Other auto makers also imported beater-add gaskets, but the actual import
volume for 1985 was not available (ICF 1986).
C. Trends
Between 1981 and 1985, Rogers Corp. (Rogers, CT), Nicolet, Inc.
(Norristown, PA), and Celotex (Lockland, OH), three manufacturers that
formerly produced asbestos beater-add gasketing, either substituted for
asbestos with other materials or discontinued their operations. During those
four years one company, Lydall Corp. (Hoosick Falls, NY), initiated
production.^ Total production of asbestos beater-add gasketing paper declined
by 37 percent between 1981 and 1985 resulting in a reduction from 26,039 tons
to 16,505 tons (ICF 1986, ICF 1985).
All six manufacturers are currently producing substitutes for their
products. The substitutes currently hold about a 50 percent share of the
gasket market (ICF 1986), but as concern about asbestos grows and substitutes
gain wider acceptance, the production of beater-add asbestos gaskets is likely
to decline further (ICF 1986).
^Gaskets, as opposed to gasketing, are custom made by secondary
processors for their customers.
^Lydall Corp. purchased the beater-add gasketing business of Rogers Corp.
in 1984, and subsequently moved the operation to their Hoosick Falls, NY
location.
- 3 -

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Table 1, Production of Asbestos Beater-Add Gasketing and
Asbestos Fiber Consumption
1985
Fiber Consumption 1985 Production
(short tons)	(short tons) Reference
Total
12,436.4
16,505	IGF (1986)

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D. Substitutes
Asbestos is a chemically inert, nearly indestructible substance that can
be processed into fibers. Asbestos fibers partially adsorb the binder with
which they are mixed during processing, and subsequently intertwine within it
and become the strengthening matrix of the product. Gaskets made using
asbestos contain as much as 80 percent asbestos fiber, some of which has been
employed as a filler. The balance of the product is the binder which holds
the asbestos in the matrix. Industry leaders indicate that they have been
unable to find a single substitute for asbestos that can reproduce all of its
^qualities and have been forced to replace asbestos fiber with a combination of
substitute materials, including cellulose, aramid, glass, PTFE, graphite, and
ceramic fibers. Asbestos used as a filler has been replaced by other fillers
(e.g., clay, mica).
Formulations of substitute products most often include a combination of
substitute fibers and fillers in order to reproduce the properties of asbestos
necessary for a particular application. Formulation of substitute products is
done so as to meet the performance requirements on an application-by-
application basis (1CF 1986), For the purposes of this analysis, the
substitute products have been grouped into six major categories according to
the type of asbestos substitute used:
	cellulose fiber,
	aramid,
	fibrous glass,
m polytetrafluoroethylene (FTFE),
	graphite, and,
	ceramic fiber mixtures (ICF 1986; Palmetto Packing 1986).
Table 2 presents the characteristics of the substitute materials.
The estimated current market shares for the different substitute
formulations are presented in Table 3, For all beater-add applications,
asbestos-based producers still occupy 50 percent of the market. It is evident
- 5 -

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Tab]s 2. Substitutes for Asbasfcos Bnainr Add Basketing Paper
Product
Advantages
Disadvantages
Remarks
Re Serene
Cellulose
IiufTLpunr; Ive,
Good carrier web.
Not heat resistant.
Useul to 350*F.
Not chemically resistant,.
Useful tot low temperature
applications only.
ICF 1986;
ICF 1985;
Hach. Des.,
July 10, 1986.
Aramid
Very strong.
Tear resistant.
High tensile strength.
Bard to cut.
Wears out cutting dyes quickly.
S00""F temperature Unit.
ICF 1986;
ICF 1985;
Maeh, Des., July 10, 1986.
Glass Fibera
Good pensile properties.
Chemical resistant.
Morn ftxprmrt 1 vo than asbestos.
Often used In the auto industry.
ICF 1986;
ICF 1985;
Mach. Des., July 10, 1986.
FIFE	Low friction.	Hot as resilient as asbestos.	Used primarily in the chemical	ICF 1986;
Chemical resistant,	Deforms under heavy loads,	industry.	Palmetto Packing 1966a.
FDA approved to contact food and
medical equipment.
Graphite
Heat resistant to SOOO'F,
Cheraical resistant.
Light weight.
Hare expensive.
Brittle.
Frays.
Fastest growing substitute in the
auto market In high temperature
seals,
ICF 1986;
ICF 1985;
Mach. Des., July 10, 1986;
Onion Carbide 19B7,
Ceramic Paper High heat resistance.	Hot oil resistant.	ICF 1986;
Chemical resistant.	Not resilient,	ICF 1985;
Strong.	More expensive than asbestos.	Mach. Des., July 10, 1986.

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Table 3. Estimated Market Share for Asbestos Substitute
Fibers in Beater-Add Gasketing
Fiber
Estimated
Market Share
(percent)
References
Cellulose
Aramid
Glass
PTFE
Graphite
Ceramic
25
30
20
10
10
5
ICF 1986
Palmetto Packing 1986
ICF 1986
Palmetto Packing 1986
ICF 1986
Palmetto Packing 1986
ICF 1986
Palmetto Packing 1986
Union Carbide 1987
ICF 1986
- 7 -

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from the survey of asbestos processors, however, that the market share of
asbestos-free beater-add gaskets is increasing rapidly as companies replace
asbestos in some applications. One obstacle to complete replacement of
asbestos gaskets by substitute products is military contract specifications
that require asbestos gaskets.
1. Cellulose Fiber Mixtures
Cellulose fibers are generally milled from newsprint or other waste
forms of cellulose (e.g., vegetable matter) in the presence of additives which
ease grinding and prevent fires during processing. Cellulose fiber gaskets
usually contain between 20 and 25 percent cellulose fiber and 50 to 55 percent
fillers and thickeners. The remaining 25 percent is usually an elastomeric
binder (ICF 1986).
Traditionally, cellulose fibers do not resist pressure well and crush
easily. However, proprietary methods have been found to reinforce fibers.
This results in excellent crush resistance, excellent dimensional stability,
and good sealability below 350F. Cellulose gaskets can substitute for
asbestos beater-add gaskets in low temperature applications (below 350*F) such
as with oil, gas, organic solvents, fuels, and low pressure steam.
Three producers of asbestos beater-add gaskets also produce cellulose
based gaskets. They are Armstrong World Industries, Hollingsworth & Vose, and
Lydall Corporation (ICF 1986).
Armstrong World Industries of Fulton, NY, the largest producer of asbestos
containing beater-add gaskets, produces a line of asbestos-free, cellulose
based gaskets, Syntheseal(R). Armstrong indicated that the asbestos-free
formulation costs more to produce and yields a product comparable in quality
to the asbestos product for applications with an operating temperature under
350F (Armstrong 1985).
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Hollingsworth & Vose also produces a line of cellulose based, asbestos-
free gaskets. The formulation includes mineral fillers and an elastomeric
binder. The company cited no quality problems with their asbestos-free gasket
line that costs more to produce (ICF 1986a),
The Lydall Corporation also produces cellulose based gaskets that cost
more than the asbestos formulation. Company officials indicated that these
cellulose based products can only be used in temperatures below 350 F (ICF
1986).
Reinforced cellulose based gaskets have increased in popularity in the
past few years. These gaskets can duplicate all asbestos performance
parameters, except high temperature resistance. Although they can be used at
*
a maximum continuous operating temperature of 350F, their life is
substantially shortened in temperatures over 95F and they cannot be used in
even mild pressure applications (Union Carbide 1987). But in the right
operating environment, manufacturers indicate that the service life of these
asbestos-free gaskets is the same as that of asbestos gaskets (ICF 1986).
In the event of an asbestos ban, cellulose fiber formulations in
combination with clay and mineral thickeners are estimated to capture 25
percent of the gasketing market (Table 3). Prices would be expected to rise
20 percent to $0.90 per pound due to increased material and production costs
(ICF 1986, Palmetto Packing 1986).
2, Aramid Mixture
Aramid fibers are used in asbestos-free gaskets because they are
highly heat resistant and strong (ten times stronger than steel, by weight).
Aramids are at least seven times more expensive than asbestos, by weight, but
as they are less dense and stronger, less is needed for reinforcement
purposes. At high temperatures (above 800"F), the fiber physically degrades,
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and it can only be used in applications where pressure service is below
1,000 psi (Union Carbide 1987).
Aramid gaskets are usually 20 percent aramid fiber, by weight, and 60 to
65 percent filler. The remaining 20 to 25 percent is binder that keeps the
fibers in a matrix. Typical applications include gasketing for internal
combustion engines in off-highway equipment, diesel engines, and compressors.
These applications require a very strong gasketing material that will
withstand moderate temperatures (1CF 1986).
Thermo-Tork (R) is a trade name for the line of aramid-containing gaskets
that Armstrong World Industries markets for operating temperatures over 350F
(Armstrong 1987). The content is a proprietary mixture of aramid fibers and
other fibers and fillers that changes according to intended operating
parameters. Many types of Thermo-Tork (R) gaskets are available, each with
different combinations of suitable operating temperature and pressure ranges
(Armstrong 1987). The various types of gasket were designed for specific
applications, such as:
	small engines and motors,
	sealing fuels, fluids, and hot oils,
	sealing gases, water, and low pressure steam,
and
	compressors and transmissions (Armstrong 1985).
Suitable temperatures can range up to 800F, and pressures can range up to
1500 pounds per square inch. Armstrong indicated no diminished quality with
the non-asbestos gaskets. In fact, greater scalability is often found with
the Thermo-Tork (R) gaskets,
Hollingsworth & Vose identified strength and high temperature resistance
as the reasons for selecting aramids for asbestos beater-add replacement.
Their formulation includes mineral fillers and elastomeric binders. The
estimated cost of the aramid product was 1.5 to 3 times as much as the
asbestos product resulting in gaskets that cost $1.69 per pound (ICF 1986).
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Although aramid products are expensive, their high temperature and
pressure limits make them very attractive for gasket applications. Thus, the
estimated market share for aramid products would be about 30 percent of the
total asbestos market in the event of an asbestos ban (ICF 1986).
3. Fibrou!^=Glass=JlxU!res
Fibrous glass is generally coated with a binder such as neoprene,
tetrafluoroethylene (TFE), or graphite in the manufacturing process to make
gaskets. The glass fibers are relatively easy to manufacture into this
material.
Fibrous glass gaskets can be divided into two groups, "E" glass gaskets,
and "S" glass gaskets, depending upon the type of glass fiber used in the
formulation, "E" glass is one of the more common glass fibers, and it is
occasionally manufactured into a gasketing which is used as a jacket around a
plastic core of carbon or aramid fibers and other material (OGJ 1986).
"E" glass gaskets are suitable for applications where the operating
temperature is below lOOO'F, Above this temperature, the gasketing loses 50
percent of its tensile strength. The material can be used with most fluids
except strong caustics.
The second type of fiber, MS" glass, was developed by NASA and is
recognized as the superior glass fiber in use today (OGJ 1986). This material
is occasionally used as a jacket around a core of graphite and other fibers.
This beater-add gasketing is caustic resistant and can be used in applications
with operating temperatures that reach 1500F (OGJ 1986).
It is estimated that glass gaskets will capture 20 percent of the total
asbestos beater-add gasketing market and will cost twice as much as the
asbestos material. Thus, the price will be $1.50 per pound (Palmetto Packing
1986, ICF 1986).
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4.	Polvtetrafluoroethvlene (PTFE")
Fibers of polytetrafluoroethylene (PTFE) are used as substitutes
for asbestos in gaskets because of their chemical resistance to all but the
most powerful oxidizing agents, acids, and alkalies in temperatures ranging
from -450F to 500F (Chem. Eng. News 1986). PTFE also has good dielectric
strength and impact resistance.
PTFE can be used in specialized applications because it has been approved
by the FDA for contact with food and in medical equipment. In addition, it
does not stain the fluid with which it has contact (Krussel and Cogley 1982).
The finished product is 3.5 times as expensive as the asbestos product
resulting in gasketing material costs of $2.62 per pound. PTFE gaskets will
capture an estimated 10 percent of the total asbestos market in the case of an
asbestos ban (Palmetto Packing; ICF 1986).
5.	Graphite
Flexible graphite^ is made from natural flake graphite, expanded
several hundred times into a light, fluffy material by mixing with nitric or
sulfuric acid. It is then calendered into a sheet (without additives or
binders) (Chem. Eng. News 1986). It is extremely heat resistant and
inherently fire-safe (because it does not contain binders). Graphite gaskets
are suitable for applications where the operating temperatures reach 5000F in
non-oxidizing atmospheres. In the presence of oxygen, the material is limited
to use below 800F (Chem. Eng. News 1986). The gaskets have excellent
^Other forms of graphite with similar properties are also available
(e.g., carbonized viscose rayon), but are grouped in the category for
convenience.
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chemical resistance with the exception of strong mineral acids and can be used
up to 1,500 psi^ (Union Carbide 1987).
Graphite material is often used in oil refineries and oil field
applications because of its high temperature resistance. A wire can be added
to increase strength in high temperature, high pressure applications, (OGJ
1986) .
Graphite is an expensive material, but the addition of various fillers
helps keep the cost competitive with other substitute materials. Graphite
gaskets are estimated to cost twice as much as asbestos beater-add gaskets,
resulting in a cost of $1.50 per pound. This substitute's market share is
estimated to be 10 percent of the total asbestos gasketing market, but this
value is likely to rise to 50 percent for internal combustion engines, and to
20 percent for all applications (Union Carbide 1987).
6. Ceramic Mixtures
Ceramic mixtures are made from high purity silica/alumina fibers
that are thoroughly interlaced in the production process and bonded with
either an elastomeric or inorganic binder. The elastonteric binder can be used
when operating temperatures do not rise above 800F, while inorganic binders
can be used for all operating temperatures. Ceramic fiber products are heat
resistant, chemical resistant, and very strong; this enables them to be used
under stressful operating conditions.
Three major companies that produce ceramic paper used for gasketing
purposes are: Cotronics Corporation, Carborundum Corporation, and Quin-T
Corporation. Only Quin-T is also an asbestos beater-add gasketing producer.
Quin-T indicated that their formulation for asbestos free gaskets was
^Unlike other gasketing materials that exhibit a temperature/pressure
dependence, flexible graphite is able to withstand high pressures independent
of temperatures.
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proprietary, but did state that the ceramic mixture products could capture 5
percent of the asbestos gasketing market.
The manufacturer stated that the ceramic mixture is not as resilient as
asbestos and not as resistant to oil, but claimed that this was not
detrimental to the function of gaskets in most applications.
The price of ceramic gaskets is estimated to be three times that of the
asbestos products they replace, resulting in a cost of $2.25 per pound. The
service life of the substitute product is 5 years, as is that of the asbestos
gasket (ICF 1986).
E.
It appears that substitutes for asbestos containing gaskets currently
exist. These products cost more to produce, however, and may not perform as
well in all applications. Because no single substitute fiber exists,
manufacturers have been forced to replace asbestos with a combination of
substitute materials, including cellulose, aramid, glass, graphite, PTF1 and
ceramic fibers. The substitute materials are a combination of fibers and
fillers designed on an application-by-application basis.
The estimation of market shares and prices of the substitute formulations
in the event of an asbestos ban relies to a large extent upon educated
judgments of industry experts. Table 4 summarizes the findings of this
analysis, and presents the data inputs for the Asbestos Regulatory Cost Model.
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Table 4. Data Inputs for Asbestos Regulatory Cost Modal
(005) Boator Aid Gaskatitig Wmpmt
Product
Output
Product Asbestos
Coefficient
Consumption/
Production Ratio
Price
Equivalent Market
Useful Life Price	Share
Reference
Asbestos Gasket ir,g 16,505 tons 0,75349 tons/ton
Cellulose
Arflmid
Fibrous Glass
PTFE
Graphite
Ceramic
H/A
It/A
H/A
H/A
H/A
H/A
H/A
N/A
H/A
H/A
H/A
H/A
1.02	SI,5D0/ton	5 years	Sl,500/ton	B/A	ICF	1986.
H/A	$l,800/ton	5 years	81,800/ton	25X	ICF	1986.
*
N/A	53,380/ton	5 years	S3,380/tcm	30*	ICF	1986.
H/A	S3,000/ton	5 years	$3,000/ton	20*	ICF	1986; Palmetto Packing.
H/A	$5,2Wton	5 years	$5,Z40/ton	10%	ICF	1986; Palmetto Packing.
H/A	$9,740/fcon	5 years	$3,000/ton	Wt	ICF	1986; Union Carbide 19B7.
H/A	$4,500/tem	5 years	$4,500/ton	5*	ICF	1986.

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REFERENCES
Armstrong World Industries. 1985. Product literature on Thermo -tork(R)
gasketirig material.
Armstong World Industries. L. Creech. 1987 (July 1), Fulton, NY,
Transcribed telephone conversation with Mark Wagner, ICF Incorporated,
Washington, D.C.
Chemical Engineering News, October 27, 1986. Asbestos Users Step Up Search
for Substitutes, McGraw-Hill.
ICF Incorporated. 1985, Appendix H: Asbestos Products and Their
Substitutes, in Regulatory Impact Analysis of Controls on Asbestos and
Asbestos Products. Washington DC; Office of Pesticides and Toxic Substances,
U.S. Environmental Protection Agency.
ICF Incorporated. 1986 (July-December), Survey of Primary and Secondary
Processors of Asbestos Beater-Add Gasketing. Washington, DC,
Krusell N, Cogley D. 1982. GCA Corp. Asbestos Substitute Performance
Analysis. Revised Final Report. Washington DC: Office of Pesticides and
Toxic Substances, U.S. Environmental Protection Agency, Contract 68-02-3168.
Oil and Gas Journal. May 26, 1986. Refining Technology: Substitute Materials
to Replace Asbestos in Refinery-Service Gaskets and Packings. PennWell
Publication. Tulsa, OK. Pp.47-51.
Machine Design. 1986 (July 10). Better Gaskets Without Asbestos. Volume 58,
pp. 67-71.
Palmetto Packing. S. Matt. 1986 (January 8 and 19). North Hales, PA.
Transcribed telephone conversations with Linda Carlson, ICF Incorporated,
Washington, D.C.
Union Carbide Corporation. P. Petrunich. 1987 (March 4). Cleveland, OH.
Letter with enclosures addressed to Tony Bansal, ICF Incorporated, Washington,
D.C.
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