Report Number 15C025 REPORT OF MEETING: ASTM Michael E. Beard Conference: Asbestos and Fibrous Minerals Analysis and Research

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1 CHATFIELD TECHNICAL CONSULTING LIMITED 2071 Dickson Road Mississauga, Ontario CANADA L5B 1Y8 Telephone: Fax: Report Number 15C025 REPORT OF MEETING: ASTM Michael E. Beard Conference: Asbestos and Fibrous Minerals Analysis and Research 28 January 2016 to 29 January 2016 Prepared For: Denise Calabrese, Executive Director The Vermiculite Association 2207 Forest Hills Drive Harrisburg Pennsylvania Dr. Eric J. Chatfield President Chatfield Technical Consulting Limited 2016 April 12

2 Chatfield Technical Consulting Limited Report Number 15C April 12; Page 1 INTRODUCTION The ASTM Michael E. Beard Conference is dedicated to the memory of Michael E. Beard ( ). This year it was held from January 28 to January 29, at the Grand Hyatt San Antonio Hotel, in San Antonio, Texas. The subject of this conference was "Asbestos and Fibrous Minerals Analysis and Research". The conference format is the same as that used for the ASTM Johnson Conference series, in that no proceedings are published and electronic recording of the presentations is not permitted. This policy is designed to encourage sharing of the most recent research work and to promote open discussion. Presenters are allowed 15 minutes for their presentation, followed by 5 minutes for discussion. A discussion of the major topics of the conference relevant to the interests of the TVA follows. The conference program and the abstracts are shown in Appendix A. PRESENTATIONS The Fluidized Bed Asbestos Segregator and Similar Elutriation Devices EPA continues to fund research into laboratory methods, the results of which are intended to allow prediction of the levels and characteristics of fiber emissions in real-world situations. In presentations by J. Januch (EPA Region 10) and E. Cahill (EMSL Analytical, Inc.), continuing work on these methods was described. Januch and Cahill reported that their organizations have entered into a Cooperative Research and Development Agreement to manufacture and conduct research with the "fluidized bed asbestos segregator" (FBAS) developed by EPA. It was stated that the goal is to refine the design and carry out performance testing, with the aim of eventually establishing the instrument and its associated procedures as an ASTM method. It is now being stated by E. Cahill that the FBAS is based on the vibrating bed aerosol generator developed in Germany by Spurny in This statement is somewhat curious in view of the fact that when the FBAS was first described at the ASTM Michael E. Beard conference 6 years ago the author of that presentation (J. Januch) appeared to be unaware of Spurny's earlier work and patented instrument,

3 Chatfield Technical Consulting Limited Report Number 15C April 12; Page 2 which was mentioned at that time by a member of the audience during questions following the presentation. The term "FBAS" is a misnomer, in that the instrument does not "segregate" asbestos; it simply aerosolizes the finer fraction of particulate from a crushed sample of material. The FBAS is designed to generate airborne dust from bulk materials, and it has been applied to measurements on vermiculite, talc and soil. It is claimed that concentrations of tremolite can be detected down to %, and that erionite can be detected in soil down to 0.001%. However, during the presentations relating to the FBAS, it was revealed that the mass recovery of this system was found to be less than 5% of expected, and that much of the generated dust had been observed to adhere to the inside of the equipment. This is unacceptable performance by any standard. The presenters reported that they are attempting to improve the recovery by modifying the glass vessel used. It is unlikely that this will solve the wall loss problem, which is almost certainly a result of electrical charges generated on the particles. Any results obtained using this device in its present form are therefore questionable. Regardless of the fact that the current version of the FBAS appears to have significant deficiencies, EPA continues to apply the FBAS (and other methods) to determine fiber emissions, using soils from Libby, a W.R. Grace site in New Orleans, Portland Harbor, the El Dorado lake bed in Nevada and the Atlas mine site at Coalinga. Considerable disparities were reported between the results obtained using the FBAS, the CARB 435 method and the draft ASTM method for determination of asbestos in soils. In Korea, there is also significant interest in analysis of soils for asbestos. Dr. Hyunwook Kim reported the use of a venturi device for generation of dust from soil, along with activity-based air sampling on the site being evaluated. It was concluded that there was no relationship between the results from the venturi device and those from activity-based sampling. Although methods for measurement of amphibole fibers in soil, currently under development by both EPA and ASTM, may not seem relevant to vermiculite, they may become relevant in the future. Fertilizers based on vermiculite from Libby were used over many years, and it may just be a matter of time before someone, either a consultant or EPA, raises this as a further topic for investigation. The TVA therefore needs to keep informed about the analytical methods being developed for determination of asbestos in soil.

4 Chatfield Technical Consulting Limited Report Number 15C April 12; Page 3 Determination of Asbestos in Vermiculite A presentation by Ed Cahill (EMSL Analytical, Inc.) was concerned with vermiculite analysis specifically in New York State, and the uncertainties that are inherent in the existing analytical methods and application of these methods. These methods include the EPA/600/R-93/116 method for determination of asbestos in bulk building materials, the "Cincinnati Method" (EPA/600/R-04/004), the ASTM Draft Qualitative Method, and methods using either heavy liquid separation or the Addison/Davies dissolution procedure. The ASTM Draft Qualitative Method was reported to be 100% accurate in determining the presence or absence of asbestos in vermiculite. However, these performance tests were conducted using asbestos-free vermiculite that had been spiked with amosite. Clearly, this performance test was not realistic, because amosite is not normally a contaminant in vermiculite. This draft method has not yet been approved by ASTM. In New York State, the NYS Department of Health has not approved any analytical method for determination of asbestos in loose-fill vermiculite, and therefore, loose-fill vermiculite is considered to be de facto an asbestos-containing material. For determination of asbestos in spray-on vermiculite-containing fireproofing, NYS DOH Method and a proprietary method of R.J. Lee Group are approved. It was stated that a major objection to both of these methods is that the elapsed time for results from these analyses is more than 18 hours. One topic relating to the analysis of vermiculite-containing fireproofing in New York State was not discussed in the formal presentation, but was discussed in private conversations. It was reported that building owners and consultants in New York State apparently now describe vermiculite-containing fireproofing samples as "trowelled-on", rather than "sprayed-on", in order to avoid the requirement to use the newer, more reliable (and more expensive) analytical methods approved by NYS DOH. Against all advice from the scientists involved in development of NYS DOH Method 198.8, NYS DOH bureaucrats insisted on retaining "sprayed-on" in the description of the samples for analysis by the new methods, regardless of the fact that the materials in both applications are identical and the laboratories would not be able to discern the method of application. According to one laboratory, building owners and consultants now routinely exploit this loophole in the regulation.

5 Chatfield Technical Consulting Limited Report Number 15C April 12; Page 4 A presentation given by Dr. James Webber on behalf of Myron Getman (New York State Department of Health) described the newly-approved methods for determination of fibrous amphibole in sprayed-on vermiculite-containing fireproofing. It was acknowledged that no analytical methods have been approved by New York State for the analysis of other vermiculite-containing products that contain more than 10% vermiculite, and for the analysis of loose-fill vermiculite, which is defined by New York State as de facto asbestos-containing material. A presentation by Dr. James Millette described an inexpensive wet chemistry method by which Libby vermiculite could be discriminated from vermiculite from other sources. The method is intended for homeowners who have vermiculite attic insulation to determine whether they qualify for compensation. This chemical analysis method has been adopted by the Zonolite Attic Insulation trust fund, using a minimum value of 1500 ppm barium as indicative of vermiculite from Libby. Using vermiculite samples from five different sources, Libby, Enoree, Palabora, Xinjiang and Louisa, Dr. Mickey Gunter (University of Idaho) had determined that a chemical analysis of the vermiculite for barium, and to a lesser extent chromium and vanadium, could be used to discriminate Libby vermiculite from vermiculite from the other sources. However, this method assigned one of the Enoree samples as originating from Libby, indicating that it could produce false positives. The cost of such an analysis by the chemical analysis method is approximately $30, which is significantly lower than the costs for other types of analysis. Using the chemical analysis method, in tests by Dr. Millette on 10 Libby vermiculite samples, the barium concentration was found to be greater than 2270 ppm, with the exception of one sample which yielded a result of 818 ppm barium. This sample was found to contain approximately 50% wood and other particles, thus diluting the barium measurement. A similar difficulty with the chemical analysis method is that mixtures of vermiculite, for example a mixture of Libby and Palabora vermiculite, can result in an incorrect decision. A microscopical examination of such a mixture for the presence of fibrous amphibole would likely indicate the presence of Libby vermiculite. Measurement of the barium concentration may be an expedient way to establish the source of historical vermiculite attic insulation when there were realistically only two major sources of vermiculite in use for this application. However, this method is inappropriate for discrimination between the larger number of sources that are currently available. It is possible that measurement of a group of trace elements could uniquely

6 Chatfield Technical Consulting Limited Report Number 15C April 12; Page 5 define the source of an unknown sample of vermiculite. In past work, it has been shown that measurement of a number of trace elements by neutron activation could determine the specific mine from which a sample of chrysotile asbestos originated. Other Issues Relating to Vermiculite A presentation by Mr. Sean Fitzgerald discussed observations of fiber contamination in vermiculite and talc. Mr. Fitzgerald appears to be challenging the results of analyses of Libby vermiculite published in 2003 by the U.S. Geological Survey (USGS). The USGS study found that the most common amphibole fibers in the Libby deposit were winchite. Mr. Fitzgerald made the statement that the most common amphibole fibers were richterite, with winchite being the second most common. He also claimed to have observed: (a) asbestiform amphibole in Palabora vermiculite (although not as much as in other sources); (b) chrysotile, actinolite and anthophyllite in South Carolina vermiculite; and (c) richterite and chrysotile in vermiculite from sources other than Libby. With respect to talc, Mr. Fitzgerald claims to have observed richterite in talc from various U.S. sources, and that in his opinion this has often been erroneously reported as tremolite.

7 Chatfield Technical Consulting Limited Report Number 15C April 12; Page 6 APPENDIX A Conference Program and Abstracts

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