Comment submitted by Paul J. Mellons, President, Novetas Solutions LLC

Dear Sir or Madam My name is Paul Mellon, President of Novetas Solutions. We market and sell an industrial abrasive product, New Age Blast Media® produced from 100% recycled glass. I am responding to the request for comment by the EPA on the new national standards for Emissions of HAPs. Docket ID No. EPA-HQ-OAR-2006- 0306 Upon reading the document and the recap ( listed below ) of the proposed standards I do have a question regarding the focus of the EPA on reducing HAPs in the area of Dry Abrasive Blasting. The key rationale for the standard apparently is to reduce and control the amount of hazardous air pollutants (HAPs) in various industrial sectors. The EPA is then making the decision to focus on dust generation via high PM as the primary means to mitigate against these HAPs. The document itself makes the following statement: This proposed rule would require owners or operators of affected new and existing dry abrasive blasting operations that blast substrates greater than 8 feet in any dimension to comply with the following management and pollution prevention practices to minimize MFHAP emissions from the processes: (1) Do not perform blasting outside when wind velocity is greater than 25 miles per hour; (2) switch from high PM-emitting blast media (e.g., sand) to low PM-emitting blast media (e.g., steel shot, aluminum oxide), whenever practicable; (3) do not blast substrates having coatings containing lead (>0.1 percent lead), unless enclosures, barriers, or other PM control methods are used to collect the lead particles; and (4) do not re-use the blast media unless contaminants (i.e., any material other than the base metal, such as paint residue) have been removed by filtration or screening so that the abrasive material conforms to its original size and makeup. The question I have is that the focus on High PM –emitting blast media as a signicant HAP control measure is not what OSHA recommends in their 2006 OSHA Guidance Document on Dry Blasting. In fact, OSHA specifically addresses the fact that the Abrasive Media Choice or Substitution is a KEY factor in the creation of HAPs. OSHA’s 2006 Guidance for Blasting to the Maritime Industry very clearly states the easiest way to reduce HAPs in abrasive blasting is as follows: CONTROL MEASURES* Exposure to hazardous air contaminants during abrasive blasting can be controlled through the combined use of the following control measures: engineering controls; work practices; personal hygiene; waste management and prevention programs; and personal protective equipment (PPE); A. ENGINEERING CONTROLS: 1. Substitution -- The easiest way to eliminate hazardous air contaminants associated with abrasive media is to select a safer abrasive blasting agent. * please click on the attached link for the full OSHA Guidance http://www.osha.gov/dts/maritime/standards/guidance/shipyard_guidance.html Furthermore, OSHA lists several sources in their Index of this Guidance to back up their comments in regards to the importance of choosing a safe abrasive media that does not contain high levels of HAPs. The Guidance repeatedly cites various slag ( coal, copper, nickel ) products as having significant issues with high levels of HAP compounds most of which the EPA also cites in their new standards. As stated in the Executive Summary by OSHA “ The levels of heavy metals in non-silica abrasives are highly variable depending on the type of raw material sources and/or the manufacturing processes used to make the abrasives. (5) Abrasive blasting media from coal slag will typically contain nickel and vanadium and a variety of other metals depending on the source of the coal used to make the slag. Copper slag from primary smelters contains significant levels of barium, cobalt, copper, chromium (trivalent), and nickel; whereas copper slag from secondary smelters might contain significant levels of arsenic and lead. Nickel slag typically contains elevated levels of copper, chromium (trivalent), and nickel and lower levels of cobalt and vanadium. (6)” The attached, government funded, study by Taylor Francis was specifically included by OSHA in their Guidance report . The study was titled: Airborne Exposure to Heavy Metals and Total Particulate During Abrasive Blasting Using Copper Slag Abrasive On Page 6 of the document the authors made the below conclusions • Use of either source A or B copper slag abrasive generates total particulate aerosols that exceed the OSHA PEL-TWA within 15 minutes of blasting; • ² Use of either source A or B copper slag abrasive generates arsenic and lead metal aerosols that exceed OSHA PEL-TWAs within 63 minutes of blasting; On Page 7 of the document, the authors state: The results listed above indicate that abrasive blasting using copper slag abrasive as a substitute for silica sand can generate total particulate and metal aerosols above the OSHA PEL-TWA in a relatively short period of time. There are numerous non-silica abrasives used on the market to include crushed glass, garnet, walnut shells, etc. OSHA repeatedly chooses to single out slags as examples of media that contain compounds that produce high HAPs. The current EPA standard fails to address this observation. I think it is clear that the EPA also needs to add the recommendation by OSHA that advocates Media Substitution as an easy means to reduce HAPs for Dry Abrasive Blasting. I would recommend that the EPA strongly consider addressing this issue by adding an additional statement on the choice of abrasive media as a source of controlling the impact of HAPs in the workplace. Example Statement: * switch from blast media containing high levels of HAP compounds (e.g.,coal,copper,nickel slag ) to blast media containing low levels of HAP compounds (e.g., crushed glass, specular hematite* ), whenever practicable; Rational for these products in contained in the NIOSH study report which is the foundation for much the new OSHA Guidance on Blast Media. http://www.cdc.gov/niosh/pdfs/ab_p1rep.pdf • Pg 142 “ Substitution of crushed glass and specular hematite for silica sand in abrasive blasting should also reduce the airborne concentrations for most of the hazardous, health related agents studied. In addition, glass abrasives also now appear on the EPA Grit Blasting Procurement Guidelines which are also attached to this email. I would further note that on page two of the same EPA guidelines, the EPA itself makes the following statement on the use of slag products: • EPA recommends that procuring agencies exercise OSHA or other required standard safety practices when using blasting grit, particularly when using blasting grit containing slag materials. Thank you for allowing me the opportunity to submit my comments on these very important new standard by the EPA on the reduction of HAP’s in the workplace. At Novetas, we are committed to producing products that are manufactured to the standards set forth by the EPA and OSHA to help reduce the amount HAP’s emitted into the environment and workplace. If you have any questions concerning my comments or require additional documentation, please contact me at the below numbers or via email. Regards, Paul J. Mellon Jr. Novetas Solutions LLC PO Box 5658 Deptford, NJ 08096 Phone: ( 888 ) 889 - 3833 Cell: ( 609 ) 820-4395 Fax: ( 856 ) 218-8305 Web: www.newageblastmedia.com