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 17112

Dr. Eric J. Chatfield

President

Chatfield Technical Consulting Limited

2016 April 12

CHATFIELDTECHNICAL

CONSULTING

LIMITED

2071 Dickson Road

Mississauga, Ontario

CANADA L5B 1Y8

Telephone: 905-896-7611

Fax: 905-896-1930

E-mail: echatfield@ejchatfield.com

Chatfield Technical Consulting Limited Report Number 15C025 2016 April 12; Page 1

INTRODUCTION

The ASTM Michael E. Beard Conference is dedicated to the memory of Michael

E. Beard (1940 - 2008). 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 1981. 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,

Chatfield Technical Consulting Limited Report Number 15C025 2016 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 0.0001%, 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.

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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 198.8 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.

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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

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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.

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APPENDIX A

Conference Program and Abstracts