Installation Dismantling of a Peerless Residential Boiler I

ISExppsure to Airborne

. . Asbestos Fiber During

Installation and Dismantling of a

Peerless Residential Boiler

I

J

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FILED: NEW YORK COUNTY CLERK 02/23/2018 06:23 PM INDEX NO. 190311/2015

NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 02/23/2018

Exponent®

Exposure to Airborne

Asbestos Fiber DuringInstallation and Dismantling of a

Peerless Residential Boiler

Prepared forf'

McGivney & Kluger, P.C.

23 Vreeland Road

Suite 220

Florharn Park, NJ 07932

Prepared by

Exponent

39100 Country Club Drive

Farmington Hills, MI 48331

October 31, 2007

. .

© Exponent, Inc.

Doc.Doc. no,no, 0701900.0000701900.000 BOTOBOTO "1007::Dbd5"1007::Dbd5



October 31, 2007

Contents

Eme

List of Figures iii

List of Tables i11

Aeronyms and Abbreviations iy

Executive Summary I

1 Introduction 3

2 Materials and Methods 4

Description of Boiler 4

Exposure Simulation Approach 4

Testing Facility 5

Bulk Material Testing 6

Test-Room Air Sample Collection and Analysis 7

Calculation of 8-Hour TWA Concentrations 8

Quality Assurance and Quality Control 9

3 Results 10

4 Discussion and Conclusions 12

5 References 14

Figure, Tables and Photographs

Appendix A. Reports of Bulk Sample Analyses

Appendix B, PCM and TEM Reports, and Chain-of-Custody Forms.

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October St 2007

List of Figures

Figure L Test facility room layout showing sample locations

List of Tables

Table L Work log, boiler disassembly and reassembly, September 26, 2007

Table 2. Work log, burner replacement and total boiler disassembly, September 28, 2007

Table 3. Test room air rates

Table 4 Bulk sample results

Table 5. Pretest baseline area sample results, September 19--21, 2007

Table 6. Personal sample results, boiler disassembly and reassembly, September 26, 2007

Table 7, Area samples, burner replacement and total boiler disassembly, September 28, 2007

Table 8. Personal sample results, burner replacement and total boiler disassembly, September

28, 2007

Table 9 Area samples, burner replacement and total boiler disassembly, September 28, 2007

Table 10 Personal sample results, calculated eight-hour time-weighted average concentrations

September 26 and 28, 2007

Figure, Tables and Photographs are provided at the end of the text.

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October 31, 2007

Acronyms and Abbreviations

AER air exchange rate

ACGIH American Conference of Governmental Industrial Hygienists

ASTM American Society for Testing and Materials

BTU British Thennal Units

CIH Certified Industrial Hygienist

CO2 carbon dioxide

EPA U.S. Environmental Protection Agencyf/ce fibers per cubic centimeter

ft feet

HEPA high-efficiency particulate air

hr hour

I-B-R Industrial Boiler and Radiator Manufacturers

L/min liters per minutem3mIT]

3cubic meters

MCE mixed cellulose ester

NIOSH National Institute for Occupational Safety and Health

OSHA Occupational Safety and Health Administration

PBZ personal breathing zone

PCM phase contrast microscopyPCM-E phase contrast microscopy-equivalent:

PEL perrnissible exposure limit

PLM polarized light microscopyppm parts per million

STEL short-term exposure limit

TEM transmission electron microscopyTLV threshold limit value

TWA time-weighted average

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.IO-4-W-S,

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â€”â€”

October 31, 2007

Executive Summary

This report presents the methods and analytical results associated with testing data obtained

during the installation, servicing, and dismantling of a Peerless Boiler Co. (Peerless) Super

Section Oil Boiler Model JO-4-W-S, a residential"packaged"

hot water boiler. The primaryobjectives of the study were to:

1. Determine the asbestos content of various seals and gaskets found in the

boiler.

2. Determine the concentrations of asbestos fiber released while performingwork tasks associated with installation and disassembly of a sectional-type

cast-iron boiler, and the asbestos exposure incurred by both the primaryworkers (plumber and helper) and a bystander,

To meet the second objective, J a representativ6 but"worst-case"

work area, consisting O of a small

room ("test chamber")chamber"

with low air exchange rates (averages less than 0.5 Air Exchange Rate

(AER)/hr) was used, Another objective of this study was to measure short-term exposures and

to calculate 8-hour time-weighted average concentrations (TWAs) for each of the three test

participants. These were then compared to present Occupational Safety and Health

Administration's (OSHA's) short-term (30-minute) exposure limit (STEL) and the OSHApermissible exposure limits (PELs) and American Conference of Governmental Industrial

Hygienists (ACGIH) threshold limit values (TLV) to assess the measured exposure

concentrations against workplace guidelines.

A total of twelve asbestos bulk samples were collected, four before and eight after the

performance of several boiler related work tasks, A total of 38 air samples were collected

during the two day testing period. These 38 samples consisted of 21 personal breathing-zone

(PBZ) samples, 15 test-room area samples, and 2 samples collected outside of the test chamber.

Prior to the first test day, 8 baseline area samples were also collected. Air samples were

analyzed using phase contrast microscopy (PCM) and transmission electron microscopy (TEM)to determine total fiber and percent asbestos fiber concentrations, respectively.

Based on the test results obtained during installation, servicing, and dismantling of the Peerless

residential boiler in a small room, one would expect that the release of asbestos fibers in an

indoor residential setting (most likely a basement) from any similarly constructed boiler would

result in exposures well below current the OSHA 30-minute STEL of 1.0 fibers per cubic

centimeter (f/ce), or the PEL of 0.1 f/ce as an 8-hour TWA for a plumber, plumber's helper, or

bystander."bystander,"bystander, The study results indicate the following:

• Asbestos-containing materials in the Peerless boiler were made exclusivelyfrom chrysotile asbestos fiber and were found in rope seals and in a paper

gasket. Bulk asbestos concentrations in these materials ranged from 50% to

70% chrysotile,

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October 31, 2007

* Separating a factory-assembled sectional boiler block prior to installation,were it ever to be performed indoors in a residential setting, produces

airborne asbestos exposures well below the current OSHA PEL of 0.1 f/ce 8-

hour TWA. Furthermore, based on the findings in this study, similar work

outdoors would likely produce little or no measurable exposure to

asbestos fiber.

• Handling and manipulating an estimated 27 feet of asbestos rope, cutting this

rope and scraping an asbestos gasket from a Peerless residential boiler that

had been in service for more than 30 years, resulted in airborne exposure well

below the current OSHA STEL of 1,0 f/ce and PEL of 0.1 fice 8-hour TWA,

• Boiler reassembly and final installation work tasks also resulted in airborne

exposures well below the current OSHA PEL for the workers and bystander,

• Total disassembly of a Peerl ess sectional boiler with asbestos-containingmaterials likewise resulted in airborne exposures well below the current

OSHA PEL

Cleanup of debris by dry sweeping after boiler disassembly resulted in

airborne exposures below the current OSHA PEL

• Historically, workers perfonning work tasks similar to those tested in this

study would not be occupationally exposed to airborne asbestos

concentrations. Expected TWA concentrations would likely be on the order

of 2,500 times below the ACGIH TLV of 5 million particles per cubic foot

(equivalent to approximately 30 f/cc) that was in place from 1946 to 1971,1,000 times below the 1971 OSHA PEL of 12 f/cc and 400 times below the

1972 PEL of 5 f/ce, .

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,Exponent's,Exponent's

October 31, 2007

1 Introduction

A study of occupational asbestos fiber exposure during a simulated installation and disassemblyof a residential boiler manufactured by Peerless Boiler Co. (Peerless) was performed at

Exponent's Farmington Hills, Michigan, office. Conducting the study for Exponent was Del

Malzahn, Certified Industrial Hygienist (CIH). Mr. Paul Armstrong, CIH, with Performance

Environmental Services, Inc. (Performance), located in Wixom, Michigan, assisted Mr.

Malzahn in the exposure study. The work tasks were performed by Mr. David Varcoe, a

Michigan Master Licensed Plumber and certified asbestos contractor/supervisor under 1988

Michigan Public Act 440, Asbestos Abatement Accreditation program. Assisting Mr. Varcoe as

the"helper"

was Mr. David Szakal, who is a certified asbestos building inspector under

Michigan Public Act 440. Both Mr, Varcoe and Mr. Szakal are with Performance.

The boiler, Peerless Model JO-4-W-S , serial number JO-18302, is a packaged sectional-type

boiler. The term"packaged"

is used by Peerless to denote that the boiler is factory assembled,

The boiler was fully operational when located in a Pennsylvañiaresidence and determined to

have been manufactured in 1973. Bulk asbestos samples of gasket, sealing, and insulatingmaterials were collected by McGivney & Kluger PC, on September 6, 2007. This samplingevent was conducted prior to removing the boiler, to verify the presence of asbestos-containingmaterials in the boiler. These four samples were received by Exponent on September 7, 2007,

and were submitted to Bureau Veritas North America, Inc., in Novi, Michigan, for asbestos

analysis. The gasket and sealing materials, including flue rope and section rope, were

determined to contain chrysotile asbestos fibers. Results indicated that the boiler's jacket

insulating materials were composed of fibrous glass. Based on these preliminary bulk sample

results, Exponent concluded that the boiler was suitable for use in the simulation study.

The boiler was received at Exponent's Farmington Hills facility on September 18, 2007, and on

inspection, was found to be intact and in very good condition, as shown in Photos 1, 2 and 4,

The back sheet-metal jacket panel was slightly dented but no other signs of damage were

observed. The boiler was placed in a test chamber, which had been built by the study team at.Exponent'

s Farmington Hills facility, where the exposure sirriulation was conducted. Followinga pre-test baseline sampling period, airborne asbestos fiber samples were collected on

September 26 and 28, 2007, during installation, servicing, and disassembly of the Peerless

boiler, The following sections further describe the materials and methods used in this exposure

present and discuss the results, and offer conclusions reached based on the analysis.

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chamber."

October 31, 2007

2 Materials and Methods

This exposure simulation involved certain work tasks associated with installation, servicing, and

removal or disassembly of a 1973 Peerless Model JO-4-W-S residential sectional boiler.

Although separating the boiler's block assembly during the installation of a factory-assembled

boiler is believed to be performed infrequently or never attempted by most residential installers,this task was evaluated in this exposure simulation nevertheless, as a

"worst"case scenario.

Exposure simulation is designed to simulate historical exposures to products that were

manufactured and used during a time when no air samples were collected; as such, exposure

simulation is a technical approach for filling gaps in industrial hygiene (exposure) data. This

exposure simulation was conducted to evaluate the airborne asbestos exposures associated with

installation, servicing, and removal of a sectional boiler, including work with various asbestos-

containing components. As part of this study, airborne samples were collected to assess

exposures to both a primary worker, such as a plumber, as well as a plumber's helper and a

bystander.

Description of Boiler

A 1973 Peerless Super Section Oil Boiler was located in a residential setting and removed

intact. This boiler is approximately 41 inches high and weighs an estimated 500 pounds. The

outside dimensions are approximately 20 by 22 inches. The boiler has a net Industrial Boiler

and Radiator Manufacturers (I-B-R) rating of 520 square feet of steam; 125,300 British Thermal

Units (BTUs) per hour of steam; and 145,200 BTU per hour of water. The exterior of the boiler

consists of a removable sheet-metal jacket, under which is fiberglass insulation completely

surrounding the section block. The insulation covers the block section assembly, which is

spaced with pads to eliminate corrosion; each section is sealed with asbestos rope for retention

of hot gases. Atop the boiler is a steel, corrosion resistant flue collector with flue duct,

approximately 12 inches in length and 7 inches in diameter, also sealed with asbestos rope

(between the flue collector and the section block). An oil burner assembly, located at the front

of the boiler at the refractory combustion chamber, was sealed with a fiberglass rope and paper

asbestos gasket,

Exposure Simulation Approach

All exposure testing was carried out in an enclosed structure termed the "test or simulation

chamber For all tests, the boiler was placed in the center of the test chamber, to allow for

access from all sides, and was non-functional, without any serviceable hook-ups, David Varcoe,

a Licensed Master Plumber in the state of Michigan (active since 1991), conducted the removal,

working on one section at a time. Other project personnel included two Certified 'industrial

Hygienists and a licensed mechanic. Paul Armstrong, CIH, was present outside the test

chamber during all tests, to provide direction and act as safety officer for the project, but entered

the chamber periodically to change out sampling cassettes. Del Malzahn, CIH, was present

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October 31, 2007

inside the test chamber to conduct industrial hygiene monitoring, directly observe the boiler

disassembly, and provide industrial hygiene expertise and to represent a"bystander"

during the

work tasks

Prior to testing, bulk analysis of certain components was performed to determine asbestoscontent and fiber type. To assess the airborne asbestos exposures associated with installation,

servicing, and removal of the Peerless boiler, the simulation test was divided into five tasks:

• Removal of various boiler components to expose the block assembly

• Separation of the block assembly into two halves, to facilitate an unusual

installation

• Complete re-assembly and simulation of complete boiler installation,

including hookup of all utilities and gas flue

• Replacement of the oil burner assembly and gaskets

• Total tlisassembly and removable of'boiler, including separatingthe entire

block assembly, to simulate a boiler replacement.

To complete the first task, the oil burner assembly at the opening of the combustion chamber

was removed to expose the gasket and section rope, the flue collector was removed to expose

the flue rope, and the exterior metal jacket (front, top, and side panels) was removed to expose

the insulation and cast-iron sectional block. The gasket, section rope, and flue rope were

scraped, if necessary, to remove any residue. The work tasks used commonly available tools,such as screwdrivers, hammers, chisels, and pry bars, and were performed by a Master Licensed

Plumber. All exposure testing was conducted in a test chamber, described in the next section,and conditions were considered to be representative of those in a residential basement. Still

photographs and video recordings were taken during the exposure testing. Time logs for all

work tasks during the two days of the simulation are shown in Tables 1 and 2.

Testing Facility

All tests on the Peerless boiler were carried out at Exponent offices and test facilities in

Farmington Hills, Michigan. A test chamber was built inside the loading dock at Exponent's

Farmington Hills, Michigan office (termed the "loading do ck"), The dimensions of the room

containing the chamber are approximately 15 ft by 25 ft, with 20-ft ceilings. The floor is

concrete, and the walls are made of cinderblocks. The room was void of any ventilation system

(no supply or return for heating or cooling). A roll-up garage door, which remained closed

during the duration of the testing, led to the outdoors, The loading dock was kept under

negative pressure during the duration of the testing and was outfitted with an air scrubber and

high-efficiency particulate air (HEPA) unit. This chamber is approximately 12-ftby

20-ft by10-ft (at peak) including an entry hallway (approximately 1,756 cubic feet, or 50 m of air

volume excluding the entrance hallway) framed in a carport structure (Photo 3). The volume of

this chamber is smaller than the minimum size basement found in a national survey of 256

homes (Murray, 1997), The chamber frame was anchored to a plywood floor that sat atop the

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October 31, 2007

concrete floor of the loading dock room, The frame was wrapped in three layers of

polyethylene sheeting (Visqueen®) on all four walls and the ceiling to contain any fibers that

might be released during testing, and to allow for easier cleanup between exposure tests, The

floor was covered with a single layer of polyethylene sheeting which was replaced at the end offirst test day,

The chamber was accessed through a decontamination entrance"hallway,"

which extended into

the test chamber due to space limitations in the loading dock room.. This hallway had a zip

entry into the test chamber, and provided a location where technicians could remove anyclothing or other potentially contaminated equipment prior to exiting to the loading dock area.A diagram of the test chamber showing the work area and area sampling locations is shown in

Figure L

The AER in the test chamber during testing was determined using American Society for TestingMaterials (ASTM) M.ethod E741, using tracer gas dilution. This test method covers techniques

forusing tracer-gas dilution to determine a single zone's air exchange with the outdoors, as

induced by weather conditions and by mechanical ventilation. Carbon dioxide (CO2) was either

dispersed into the chaniberTrom a high‡russùre tank and allowed to stabilize at a concentration

below 5,000 ppm or at the completion of the morning and afternoon test periods, CO2 was

sufficiently elevated from the workers to determine air exchange rates, A CO2 data-logging

device, TSI, Inc. Model Q-Trak with CO2, was used to monitorthe decline in CO2 over a

suitable period. CO2 concentration declination was also monitored at the end of each simulation

task and after the study team left the chamber, The air exchange was then calculated using a

regression analysis based on the observed concentration decay, During the September 26 and

28, 2007 test days, average AERs of 0.44/hr and 0.41/hr were calculated respectively (Table 3).

AERs in this range are typical for basements, but would significantly increase around the boiler

when the flue pipe is disconnected from the chimney during boiler installation or removal, The

CO2 level in the chamber, which was monitored continuously throughout the testing regime,reached as high as 3,000 ppm, indicating that the AERs in the test chambercharnbei' were marginallyadequate for this study with respect to preventing excessive build-up of CO2. Air velocity,temperature and relative humidity inside the chamber were also monitored, Airflow was

negligible in the work area. Temperature and relatively humidity gradually elevated during the

work periods.

Bulk Material Testing

The Peerless residential boiler was shipped to Exponent's Farmington Hills, Michigan, office

and placed in the constructed test chamber. Prior to conducting the exposure simulation,suspected asbestos-containing materials present in the boiler were identified. To determine

whether asbestos was present in these components, a preliminary analysis was conducted on

four samples, on September 7, 2007, to evaluate the asbestos type and content. These four

samples represented a gasket, a flue rope, a section rope, and insulation All bulk samples were

placed in resealable plastic bags and hand delivered to Bureau Veritas North America, Inc., in

Novi, Michigan, where they were analyzed for asbestos content using polarized light

microscopy (PLM). Specifically, samples were analyzed using U.S. Environrnental Protection

Agency (EPA) Method EPA/500/R-93/1I6, the appropriate method for bulk analysis using

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asbestos,'asbestos,'

October 31, 2007

PLM. Use of EPA/600/R-93/116 satisfied the applicable requirements of EPA's Interim

Method for the Determination of Asbestos in Bulk Insulation Sample, BPA-600/M4-82-020,dated December 1982, and published as Appendix E to Subpart E of 40 Code of Federal

Regulations 763. Eight additional bulk samples were collected from the boiler after its arrival in

Michigan, Results of the bulk analysis were reported as percentages based on visual estimation,with a reliable quantification limit of 1%. Results from the first four samples indicated the

following: gasket, 55% chrysotile asbestos; flue rope, 65% chrysotile asbestos with 2%

cellulose and 25% synthetic fiber; section rope, 55% chrysotile and 35% synthetic fiber; and

insulation, 90% fibrous glass and <1% cellulose, with no asbestos fibers detected, All bulk testresults are shown in Table 4, Results of the 8 samples taken after the exposure simulation was

completed showed the following: paper gasket at burner assembly, 55% chrysotile asbestos;rope gasket flue collector lower seal, 60% chrysotile asbestos; rope gasket at firebox cover, 70%

chrysotile asbestos; and rope gasket boiler core section, 50% chrysotile asbestos.. The

following samples had non-detectable asbestos concentrations using PLM analysis: firebox,rope gasket at burner assembly, rope gasket flue collector upper seal, and new rope gasket

(Table 4).

Test-Room Air Sample Collection and Analysis

During the work tasks described above, various air samples were collected. All samples were

shipped to Bureau Veritas North American, Inc., in Kennesaw, Georgia, using chain-of-custodyprocedures.

The total number of samples collected during this exposure simulation is broken down as

follows:

• Sixteen long-term personal (breathing-zone) samples

• Four short-term personal samples during various work tasks

• Fifteen area samples collected inside the test chamber during the work tasks

• Two ambient air samples outside the loading dock room

• Eight baseline samples prior to work tasks.

Personal air samples were collected from the breathing zone of the worker by placing the

sampling devices over the right and left shoulders, as shown in Photo 10. The samples were

collected on 0,8-µm (pore size), 25-mm diameter mixed cellulose ester (MCE) filters, housed in

a carbon-impregnated polyethylene cassette, Personal air samples were collected at a flow rate

.of approximately 2 to 3 L/min using calibrated personal sampling pumps. The industrial

hygienists calibrated the airflow to the sampling trains before and after each sampling event.

Five area air samples were simultaneously collected during each morning and afternoon work

periods. During each test day, one area sample was collected outside the leading dock room to

measure the concentration of asbestos in the ambient air outside of the test room. This air was

previously determined by smoke tube testing to be the primary source of the air that was

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October 31, 2007

entering the loading dock room and test chamber from an adjacent high-bay garage. Five areasamples were located inside the test chamber (shown in Figure I). These area samples werealso collected on 0.8-µm (pore size), 25-mm diameter MCE filters at a flow rate of

approximately 8 L/min. All area samples were positioned at a height of 58 inches

(approximately 1.5 m) abovethe floor.

Baseline area samples were also collected in the testing room, five prior to placing the boiler

inside the test chamber, and three in the test chamber after the boiler was unwrapped from its

shipping package, These samples also were collected on 0.8-pm (pore size) MCE filters,25 mm in diameter. Samples were collected for 2 hours at a flow rate of 10 L/min,

corresponding to an air volume equal to or greater than 1,200 L

Air samples collected during testing were analyzed according to standard methods from the

National Institute for Occupational Safety and Health (NIOSH) using an accredited laboratory.

All area and personal samples collected during testing were analyzed by phase contrast

microscopy (PCM) using NIOSH Method 7400 (NIOSH 1994a) and by transmission electron

microscopy (TEM) using NIOSH Method 7402 (NIOSH 1.994b), Those fibers greater than

5 µni, withTengthito-width ratios greater than 3:1, were counted, The TEM analyses provided

numerical counts of both asbestos and non-asbestos fibers;fibers,'

thus, the ratio of asbestos fibers to

total fibers (fiber ratio) was calculated. In accordance with NIOSH Method 7402, this ratio was

applied to the total fiber concentration by PCM to derive an equivalent PCM-asbestos

concentration (PCM-E).

Calculation of 8-Hour TWA Concentrations

In accordance with NIOSH Method 7402, the total fiber concentration obtained by PCM was

converted to a PCM-E asbestos concentration using the asbestos-to-total-fiber ratio obtained byTEM. The PCM-E represents the fraction of PCM total fibers that is asbestos fibers, as opposed

to other non-asbestos fibers such as cotton or fiberglass fibers. The PCM-E concentrations were

then used to calculate 8-hour TWA exposure concentrations to estimate the airborne

concentration during a typical workday. Eight-hour TWAs were calculated to allow for direct

comparison to current and historical occupational exposure limits or guidelines.

The estimated 8-hour TWA was calculated using the following equation:

"

Z(cz)(tr)

(Eq, 1)

where:

n = the total number of activities evaluated in a particular scenario

(e.g., handling of asbestos rope, gaskets, or other boiler components)

ef = PCM-E asbestos concentration measured during activity i (in fibers/cc)= duration of activity i performed by a worker (in hours),

When calculating the 8-hour TWA, the sum of all tf must equal 8 hours,

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DryCalDryCal

October 31, 2007

Quality Assurance and Quality Control

Applicable NIOSH quality assurance and control methods for PCM and TEM analyses were

followed during testing. The Bureau Veritas North America laboratories (both in Novi,

Michigan, and in K.ennesaw, Georgia) are accredited by the American Industrial Hygiene

Association for airborne fiber (No, 100651) The National Voluntary Lab Accreditation

Program-Lab Code 101125-0, also accredits these laboratories, Ten blank 25-mm diameter

MCE filter cassettes were also submitted to the laboratory for quality assurance. All samplingpumps were calibrated prior to and after sampling using a Bios International Corporation modelDryCal®

DC-1 primary airflow meter. The meter was factory calibrated on November 8, 2006,

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October 31, 2007

3 Results

The tests described in the previous section were conducted at Exponent's facility in Farmington

Hills, Michigan, between September 26 and 28, 2007, The following section describes the

results.

The baseline (pre-test) area sample results are presented in Table 5, No asbestos fibers were

detected with all samples reporting below the analytical limit of detection.

The personal and area sample results for disassembly and reassembly work tasks are presented

in Tables 6 and 7, respectively, The first short-term sample for the Master Plumber was

collected during the first part of task 1 on September 26, 2007 and indicated an airborne

asbestos fiber exposure of 0.013 asbestos f/ce, which is below the Master Plumbder's full shift

average concentration for all three tasks conducted on this day (0.026 f/cc) and well below

current OSHA 30 min STEL of 1.0 f/ce. The sampling period included the removal of external

components on the boiler and disconnection of the-water and flue connections, These tasks are

typically done during boiler replacement or installation and do not involve exposure to the

asbestos rope material used to seal the flue collector or sections of the boiler core, The short-

tenn sample taken on the plumber's helper at the same time (September 26, 2007) was 0.0047

asbestos fibers/ce, well below the Master Plumber's exposure and well below the current OSHASTEL

The second short term sample on September 26, 2007 for the Master Plumber was taken duringthe second half of task 1 when the interna] components of the boiler were disassembled and the

boiler core was separated into two sections. Asbestos rope gasket was disturbed during this task.

The measured short term exposure value was 0.024 f/ce. This result was also well below the

current OSHA STEL

The third short-term sample taken on the Master Plumber on September 26, 2007 was collected

during task 2, reassembly of the boiler core, including cutting and placement of the asbestos

rope, The airborne asbestos exposure measured during this sample, 0.09 f/ce, was the highest

exposure measured during this sampling day, but still well below current OSHA STEL. Full

work period (all three tasks) asbestos fiber concentrations for the Master Plumber, plumber's

helper and bystander were 0,026 f/ce, 0.046 f/cc and 0.022 f/ce, respectively, Area samples

ranged from 0.014 to 0.087 f/ce for samples collected during tasks 1 and 2 and 0.003 to 0.016

f/ce for samples taken during task 3, The outside the dock room sample result was below the

analytical limit of detection (<0,0007 f/ce). Personal and area sample results for the burner

and total boiler disassembly (tasks 4 and 5), worked performed on September 28,

2007 are reported in Tables 8 and 9, respectively. A short-term sample taken on the Master

Plumber during burner assembly replacement indicated an asbestos exposure below the

analytical limit of detection (<0.022 f/ce). The concentrations for the plumber's helper and the

bystander are similar to those previously reported for September 26, 2007 with values rangingfrom 0.0081 to 0.071 f/ce. Area samples taken during tasks 4 and 5 ranged from 0.018 to 0,055

f/ce. The outside the loading dock room sample result was again below the analytical limit of

detection,

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October 31, 2007

The sample period and calculated 8-hour TWA concentration for the two workers and the

bystander are presented in Table 10. The.8-hour TWA concentrations for the Master Plumber

and plumber's helper ranged from 0.0008 to 0,018 and 0.007 to 0.016 f/ce, respectively. The 8-

hour TWA concentration for the bystander ranged from 0.008 to 0.015 f/ce, Laboratory data

reports are provided in the following appendices:

A. Reports of Bulk Sample Analyses

B. PCM & TEM Reports and Chain-of-Custody Fonns.

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October 31, 2007

4 Discussion and Conclusions

Based on the test results obtained during installation, servicing, and dismantling of the Peerless

residential boiler in a small room, one would expect that the release of asbestos fibers indoors in

a residential setting (most likely a basement) from any similarly constructed boiler would result

in exposures well below current the OSHA 30-minute STEL of 1 0 f/co, or the ACGIH TLV and

OSHA PEL of 0,1 f/oc as an 8-hour TWA for a plumber, plumber's helper, or bystander .bystander,'

The

study results indicate the following:

• Asbestos-containing materials in the Peerless boiler were made exclusivelyfrom chrysotile asbestos fiber and were found in rope seals and in a paper

gasket. Bulk asbestos concentrations in these materials ranged from to 50%

to 70% chrysotile,

* Separating a factory-assembled sectional boiler block prior to installation,

were it ever to be performed indoors in a residential setting, produces

airborne asbestos exposures well below the current OSHA PEL of 0.1 f/ce 8-

hour TWA. Furthermore, based on the findings in this study, similar work

performed outdoors would likely produce no measurable exposure to asbestos

fiber.

• Handling and manipulating an estimated 27 feet of asbestos rope, cutting this

rope and scraping an asbestos gasket from a Peerless residential boiler that

had been in service for more than 30 years, resulted in airborne exposure well

below the current OSHA STEL of 1.0 f/ce and PEL of 0.1 f/ce 8-hour TWA.

* Boiler reassembly and final installation work tasks resulted in airborne

exposures well below the current OSHA PEL for the workers and bystander.

• Total disassembiy of a Peerless sectional boiler with asbestos-containingmaterials also resulted in airborne exposures well below the current OSHA

PEL.

• Cleanup of debris by dry sweeping after boiler disassembly likewise resulted

in airborne exposures below the current OSHA PEL.

* Historically, workers performing work tasks similar to those tested in this.

study would not be occupationally exposed to airborne asbestos

concentrations. Expected TWA concentrations would likely be on the order

The current OSHA PEL for airborne asbestos fiber, effective as of October 1994, is 0.1 f/ce (OSHA 2005).

This value is also the current ACGIH TLV (ACGIH 2007). Both the PEL and the TLV are used to assess 8-

hour TWAs. The Peerless boiler was manufactured in 1973, and at that time, the OSHA PEL was 5 flec(effective in June 1972) (Marconik et al, 2001). Starting in 1946, the ACGIR TLV for asbestos was reported as5 million particles per cubic foot Between 1968 and 1969, the ACGlH issued a notice of intended change forthe TLV to 12 f/ce. In 1970, the ACGIH again issued a notice of intended change for the TLV to 5 f/cc. Thisintended change to 5 f/ce was adopted in 1974

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October 31, 2007

of 2,500 times below the ACGIH TLV of 5 million particles per cubic foot

(equivalent to approximately 30 f/ce) that was in place from 1946 to 1971,1,000 times below the 1971 OSHA PEL of 12 f/ce and 400 times below the

1972 PEL of 5 f/ce.

0701900.00080T01007DM5 13.decee ee e derre



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October 31, 2007

5 References

ACGIH, 2007, 2007 TLV8 and BEls based on the documentation of the threshold limit values

for chemical substances and physical agents & biological exposure indicators. American

Conference of Governmental Industrial Hygienists, Cincinnati, OH.

Murray, D.M., 1997. Residential house and zone volumes in the United States: Empirical and

estimated parametric distributions. Risk Analysis, 17: 439-446.

Martonik, J.F., E. Nash, and E. Grossman. 200L The history of OSHA's asbestos rulemakings

and some distinctive approaches that they introduced for regulating occupational exposure to

toxic substances. Am. Ind. Hyg. Assoc. J. 62:208-217.

NIOSH. 1994a, NIOSH Method 7400, Asbestos and other fibers by PCM. N1OSH Manual of

Analytical Methods, Fourth Edition. August 15, 1994. National Institute for Occupational

Safety and Health.

NIOSH. 1994ab NIOSH Method 7402, Asbestos by TEM. NIOSH Manual of Analytical

Methods, Fourth Edition. August 15, 1994. National Institute for Occupational Safety and

Health,

OSHA. 2005. OSHA Regulations: Asbestos. U.S. Department of Labor, Occupational Safetyand Health Administration, Code of Federal Regulations, 29 CFR 1910.1001. Accessed online

at http://www.osha.gov on January 25, 2005,

. . . .

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Figure 1. Test chamber layout showing area sample locations

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Table 0 Work log, boiler disassembly and reassembly, Septernber 26, 2007

Task Description Time

Task 1 : Boiler Disassembly 10:36-11:27 AMDisconnect electrical supply 10:35-10:39 AMPulf out pressure/temperature gage and water temperature relay 10:30-10:40 AMRemove oil burner assembly 10:41-10:44 AMScrape gasket from burner assembly 10:44-10:46 AMRemove fire box cover 10:46-10M8 AMRemove flue pipe 10:49-10:52 AMRemove top plate of sheet-metal jacket 10:52-10:54 AMRemove front, sides, and rear of sheet-metal Jacket or cover 10:54-11:01 AMBreak-change cassettes, stack boiler components, send in additional tools 11:01-11:12 AM

Remove refractoryliner from fire box of boiler 11:12-11:14 AMRernove flue collector 11:14-11:16 AMRemove asbestos rope gasket from flue collector 11:16-11:17 AMBegin disassembly of boiler sections 11:17 AMRemove tie bolts holding boiler sections together 11:17-11:19 AMRemove coverpigte for tankless water heater section 11:19-11:20 AMSeparate boiler sections at center seal, 11:20-11:27 AM

Task 2: Boiler Reassembly 2:02-2:50 PM

Put sections of boiler back together 2:02-2:16 PMPut refractory liner back into the fire box 2:16--2:17 PMCut asbestos rope and reinstall flue collector 2:17-2:24 PMInstall sheet metal cover over the boffer 2:25-2:40 PMInstall cover plate over tankless water heater section 2:40-2:41 PMInstal( cover plate over firebox 2:42-2:44 PM

burner onto cover plate over fire box 2:44-2:48 PMInstall temp and flame sensor 2:48-2:49 PMConnect burner to electrical supply 2:49-2:50 PM

Task 3 Complete Boiler installation 2:54-3:40 PMConnect flue 2:54-3:00 PM

Connect power supply 3:00-S:10 PMConnect circulating pump and heating-water lines 3:10-3:20 PMConnect thermostat 3:21-3:28 PMConnect fuel fine 3:29-3:40 PM

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Table 2. Work log, burner replacement and total boiler disassembly, September 28, 2007

Task Description TIme

Task 4: Burner Replacement 10:51-11:14 AM

Work set up - gather tools and supplies 10'.51-11:00 AMDisconnect electrical supply to burner 11:00-11:02 AMRemove oil burner assembly 11:02-11:04 AMInstall new gasket and burner assembly 11:08-11:12 AMReconnect electrical supply to new burner 11:12-11:14 AM

Task 5: Total Boiler Disassembly 11:18 AM-12: 20 PMRemove fuel line 11:18-11:20Remove burner assembly 11:20-11:22 AMRemove flue duct 11:22-11:23 AMDisconnect electrical supply and thermostat, wire and thermostat 11:23-11:25 AM

Remove electrical controls 11:25 AM

Remove water circulation pump 11:26 AMRemove water piping connected to boiler 11:27 AMRemove pressure/temperature gage 11:28 AM .

Rernove.sheet-metal jacket covering exterior of boiler 11:28-11:31AM.'3'IRemove inspection door to fire box 11:30 AM

Remove top piece of flue collector 11:31-11:33 AM

Rernove asbestos rope gasket from top section of flue collector 11:33-1 f :34 AM

Remove bottom section of flue collector 11:35 AM

Remove fire box cover plate . 11:36-11:38 AM

Scrape gasket off the inside of fire box cover plate 11:39 AM

Remove refractory finer from fire box of boiler 11:40-11:41AM

Begin disassembly of boiler sections and remove tie bolts holding boiler 11:41-11:42 AM

sections together

Start chiseling cast iron boiler core apart 11:43 AM

Remove first section 11:40 AM

Remove second section . 11:50 AM

Scrape off asbestos rope and bag asbestos rope. Also place two cast tron . 11:50 AM-12:00 PM

sections of boiler core into bags for storage

Separate last two boiler sections at joint between them. These are the last 12:00-12:05 PM

two sections of this four-section boiler.

Scrape off asbestos rope from last two sections of boiler. The rope is coming 12:05-12:10 PM

off largely Intact; with minimal shredding.

Start cleanup; stop one sampler on bystander and helper, and one area 12:10-12:26 PM

sample, before sweeping, and bag rust and waste off floor

. .

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Table 3. Test-room air exchange rates

AirExchange Daily

Test No. Date Tirne Rate/hr Average

1 9/26/2007 8:56 -9:23 AM -0,334

2 9/26/2007 12:57-1:59 PM -0.267443

3 9/26/2007 3:55-4:26 PM -0.504

4 912612007 5:2-0-5:59 PM -0.657

6 9/28/2007 12:45-1:31 PM -0.584 -0.407

6 9/28/2007 2:10-2:28 PM -0.230

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Table 4. Bulk sample results

Bulk Sample PLM" Asbestos Boiler Location During SampleSample No. Description Sampling Date (Percent) Coffection

NA Gasket 0/6/2007 65, Chrysotile Pennsylvania

NA Flue Rope 9/6/2007 65, Chrysotile Pennsylvania

NA Section Rope 9/6/2007 55, Chrysotile Pennsylvania

NA Insulation 9/6/2007 None Detected Pennsylvania

B-1 Firebox 9/26/2007 None Detected Michigan

B-2 Rope Gasket at 9/28/2007 None Detected MichiganBurner Assembly

B-3 Paper Gasket-at 9/28/2007 55, Chrysotife MichiganBurner Assembly

!B-4 Rope Gasket Flue 9/28/2007 None Detected Michigan

Collector Upper Seal

B-5 Rope Gasket Flue 9/28/2007 60, Chrysotile Michigan

Collector Lower Seal

B-6 Rope Gasket at Fire 9/28/2007 . 70, Chrysotile Michigan

Box Cover

B-7 Rope Gasket Boiler 9/28/2007 50, Chrysotile Michigan

. Core Section

B-8 New Rope Gasket 9/28/2007 None Detected Michigan

Note:PLM - polarized fight microscopy

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Sample

Table S. Pretest baseline area sample results, September 19-21, 2007

.. . ...... . ..... .... ..... ----- ....

volume PCM Equivalent PCMSample No. Description Start Stop Total Minutes (L) (f/cc) (f/cc)176832 Center of test room prior to 12:55 PM 3:00 PM 125 1,408 0.002 0, BDL

placement of boiler, 9-19-07

176843 South side of test room prior to 2:33 PM 4:53 PM 140 1,428 0.0023 0, BDL


176834 East side of test room prior to 2:33 AM 4:53 AM 140 1,386 0.0047 0, BDL


176831 West side of test room prior.to 2:33 AM 4:53 AM 140 1,303 0.0031 0, BDL

placement of boiler, 9-204)7

176826 North side of test room prior to 2:33 AM 4:53 AM 140 1,487 <O.0013 0, BDL


176833 West side of test room with 3:34 AM 5:a4 AM 130 1,321 0.004 0, BDL

boiler in place, 9-21-07

176836 South side of test room with 3:34 AM 5:44 AM 130 1,275 0,0051 0, BDLboiler in place, 9-21-07

176821 Northeast side of test room with 3:34 AM 5:44 AM 130 1,348 0.003 0, BDL

boiler in place, 9-21-07

Note: BDL - below detection limit of approximately 0.001 f/cc for these samples

PCM - phase contrast microscopy; all fibers counted according to NIOSH 7400

Equivalent PCM is the concentration of asbestos fibers based on NIOSH 7402 Transmission Electron Microscopy analysis

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Sample Photo No.

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Table 6, Personal sample results, boiler disassernbly and reassembly, September 26, 2007

Total volume PCM Equivalent PCMSample No, Description Start Stop Minutes. (L) (f/cc) (f/cc)190126 Plumber's Helper, fun work period: Tasks 1, 2, 3 10:33 AM 11-35 AM 62 346 0.19 0.046 11 to 55

1:58 AM 3:43 AM 105167

176829 Master Plumber, full work period: Tasks 1, 2, 3 10:32 AM 11:34 AM 62 332 0 21 0.026 11 to 55PM 3:45 PM 104

166

176850 Master Plumber, Task 1, dismantle boiler . 10:32 AM 11:36 AM 64 128 0.2 0.029 11 to 41

190122 Bystander, full work period: Tasks 1, 2, 3 10:34 AM 11:35 AM 61 360 0-19 0.022 11 to 552:00 AM 3:47 AM 107

168

190123 Master Plumber, STEL 1 (short-term sample), first half of 10:32 AM 11:03 AM 31 94.2 0.029 0.013 11 to 24Task 1. remove external components and sheet-metalcover off boiler, including burner, sensors, flue and

plumbing connections

190125 Bystander, Task 1 10:34 AM 11:3S AM 61 184 0.17 0.057 11 to 41

190124 Plumber's Helper, STEL Task 1 (short-term sample) 10:33 AM 10:43 AM 27 73.4 <0.026 0.0047 11 to 12,Note: pump stopped and was restarted during sampleperiod 11:14 AM 11:31 AM 25 to 41

190131 Master Plumber, STEL 2 (short-term sample), second 11:04 AM 11:34 AM 30 902 0.25 0,024 25 to 41half of Task 1, separate intermal section of boiler intotwo sections

190137 Plumber's Helper, Task 2 1:58 PM 2:33 PM 35 79.1 0.49 0 019 42 to 52

190138 Master Plumber, STEL 3 (short-term sample) taken 201 2:35 34 103 0.66 009 42 to 52during assembly of boiler core, including cutting andplacement of asbestos rope gasket between boilersections

190139 Master Plumber, Tasks 2 & 3 2:01 3:45 104 208 D.56 0.035 42 to 55

190140 Bystander, Tasks 2 8 3 2:00 3:47 107 323 0.35 0.033 42 to 55

190132 Plumber's Helper, Task 3; note that filter was missing 2:33 3:43 70 158 void void 53 to 55from cassette when received at lab

190141 Master Plumber, Task 3 2:36 3:45 69 210 02 ___ 53 to 55

Note: PCM - phase contrast microscopy'microscopy; aff fibers counted according to NIOSH 7400STEL - short-term exposure fimitEquivalent PCM is the concentration of asbestos fibers based on NIOSH 7402 Transmission Electron Microscopy analysis

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Table 7. Area sample results, boiler disassembly and reassembly, September 26, 2007

.. ...--.-.. --Sample Equivalent Photo No

volume PCM PCM

Sample No. Description Start Stop Total Minutes (L) (f/cc) (f/cc)176839 Simulation chamber, southeast of 10:29 AM 12:52 PM 143 1,131 0,089 0.024 7

boiler

176842 Simulation chamber, southwest of 10:29 AM 12:52 PM 143 1,017 0.12 0.022 8

boiler

176845 Simulation chamber, west of boiler 10:29 AM 12:52 PM 143 1,051 0.12 0.024 8

176844 Simulation chamber, northeast of 10:29 AM 12:52 PM 143 1,021 0.089 0.014 5 and 6

boiler

176830 Simulation chamber, east and 10:29 AM 12:52 PM 143 1,134 0,08 0.087 9

above boiler

176827 Outside test room, south 10:29 AM 12:52 PM 143 2,645 0 0035 0, BDL NA

1:12 PM 4:12 PM 180323

190136 Simulation chamber, southeast of 1:12 PM 4:12 PM 180 1,424 0.075 0.003 7boiler

190130 Simulation chamber, southwest of 1:12 PM 4:12 PM 180 1,280 0.081 0.0056 8boiler

190129 Simulation chamber, west of 1:12 PM 4:12 PM 180 1,323 0,088 0.0082 8boiler

190127 Simulation chamber, northeast of 1:12 PM 4:12 PM 180 1,285 0.098 0.016 5 and 6boiler

190128 Simulation chamber, east and 1:12 PM 4:12 PM 180 1,427 0.073 0,013 9above boiler

BDL - below detection limit of 0-0007 f/ce for this samplePCM - phase contrast microscopy-

microscopy; all fibers counted according to NIOSH 7400Equivalent PCM is the concentration of asbestos fibers based on NIOSH 7402 Transmission Electron Microscopy analysis

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Table 8. Personal sample results, burner replacement and total boiler disassembly, September28,2007

. . ..... .Sample Equivalent Photo No.

Total volume PCM PCM

Sample No. Description Start Stop Minutes (L) (f/cc) (f/cc)190158 Bystander, during Task 4, Task 5 and cleanup at 10:51 AM 1225 PM 94 310 0.21 0,045 56 to 70

completion

190161 Plumber's Helper, during Task 4, Task 5 and clean up at 10:48 AM 12:26 PM 98 202 0.31 0.071 56 to 70

completion

190159 Plumber's Helper, during Task 4 and Task 5 but not 10:48 AM 12:18 PM 90 203 0.25 0.035 56 to 69

clean up

190160 Master Plumber, during Task 4 and first part of Task 5 - 10:50 AM 1t35 AM 45 89.6 0.13 0.0081 56 to 63

disassemble external components and sheet metaljacket of boiler

190157 Bystander,during Task 4 and Task 5 but not clean up 10:51 AM 12 18 PM 87 185 0.19 0.048 56 to 69

190153 Master Plumber, Task 4 , Task 5 and clean up at 10:50 AM 12:20 PM 90 180 0.25 0.055 56 to 70

completion

190152 Master Plumber, STEL, during Task 4 - burner 10:50 AM 11:18 AM 28 86 0.093 0, BDL 56 to 62

assembly replacement and scrape asbestos gasket on

assembly mounting

190154 Master Plumber, Task 5- disassemble boiler and clean 11:18 AM 12:26 PM 68 209 0.26 0.053 63 to 70

up at completion of task _

Note: BDL - below detection limit of 0.022 f/cc for this sample

PCM - phase contrast microscopy-microscopy, aff fibers counted

EquivaÍent PCM is the concentration of asbestos fibers based on NIOSH 7402 Transmission Electron Microscopy analysis

Task 4 is removal and replacement of burner assembly, including scraping asbestos gasket off mounting surfaces where burner assemblyattaches to metal plate over fire box

Task 5 is complete disassembly of Peerless JO-4 boiler and boiler core, including separating core into four component sections.

Cleanup activities model typical cleanup after boiler repair, which included dry sweeping and bagging of debris.

0705990.Mf7MIVatady taQi



Table 9. Area sample results, burner replacement and total boiler disassembly, September 28, 2007

Sample

Total volume PCM Equivalent PCM

Sample No, Description Start Stop Minutes (L) (f/cc) (f/ce)190146 Simulation chamber, southeast of boiler - 10:46 AM 12:23 PM 97 755 0.13 0.049

sample stopped before sweeping

190145 Simulation chamber, northeast of boiler 10:46 AM 12:33 PM 107 749 0.17 0.054

190144 Simulation chamber, east and above boiler 10:46 AM 12:33 PM 107 836 0.12 0.055

190147 Outside test room, south 10:46 AM 12:33 PM 107 767 <D.0025 0, BDL

190149 Simulation chamber, west of boiler 10:46 AM 12:33 PM 107 764 0.15 0.026

190148 Simulation chamber, southwest of boiler. 10:46 AM 12:33 PM 197 824 013 0.018

Note: BDL - below detection limit of 0.0025 f/cc for this samplePCM - phase contrast microscopyEquivalent PCM is the concentration of asbestos fibers based on NIOSH 7402 Transmission Electron Microscopy analysis

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Table 10, Personal sample results, calculated time-weighted average concentrations, September 26 and 28, 2007

Cumulative Sample period Calculated-8-hour

Sample Period TWA TWASarnple Numbers Sample Description (minutes) (f/ce) (f/cc)

September 26, 2007

176829 Master Plumber pump 1, Tasks 1, 2, 3 166 0.026 0.009

178850, 190139 Master Plumber pump 2, Tasks 1, 2, 3 168 0.033 0,012

. 190123, 190131, Master Plumber pump 3, Tasks 1, 2, 3 164 0 _038038 0.013

190138, 190141

190126 Plumbers Helper pump 1, Tasks 1, 2, 3 167 0.046 0.016

190122 Bystander pump 1. Tasks 1, 2, 3 168 0.022 0.008

190125, 190140 Bystander pump 2, Tasks 1. 2, 3 168 0.042 0.015

September 28, 2007. 190153 Master Plumber pump 1, Task 4 , Task 5 and clean up 90 0 055 0 011

at completion

190160 Master Plumber pump 23 Task 4 - and first part of 45 0.0081 0.0008

. . Task 5 - did not include disassembly of boiler core

190152, 190154 Master Plumber pump 3, Task 4 and 5 and cleanup 96 0.091 0.018

190161 Plumber's Helper pump 1, during Task 4 and 5 including 98 0.071 0.015

cleanup

190159 Plumber's Helper pump 2, during Task 4 and 5, but not 90 0.035 0.007

during cleanup

190158 Bystander pump 1, during Task 4, Task 5 and cleanup 94 0.045 0.009at completion

190157 Bystander pump 2, during Task 4 and 5, but not during 87 0.048 0.009

. . . .. cleanup

Note: All values calculated from Equivalent PCM results

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Installation Dismantling of a Peerless Residential Boiler I

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