Number range CHAPTERSECTION EIGHT

COPPER ROLLING AND DRAWING MILLS

8.1 PROFILE

Copper rolling, drawing, and extruding mills produce copper and
copper-alloy rod, bar, sheet, strip, plate, piping, tube, and wire. The
metal forming processes used to produce beryllium-copper (Be-Cu)
products are common to other metals and, depending on the product, may
include rolling, extrusion, and hot or cold drawing. Annealing, pickling
or metal cleaning, and slitting or cutting operations may also be
performed.

Table 8-1 shows the 2002 Economic Census statistics for this industry,
NAICS 331421, Copper Rolling, Drawing, and Extruding (U.S. Census
Bureau, 2004). The Census reported 91 firms and 136 establishments,
employing 13,004 production workers, engaged in copper rolling, drawing,
and extruding. The table also shows the industry breakdown by primary
product specialization, with smaller numbers of establishments producing
wire, bars, sheet, tube, and other copper and copper-alloy products.

Census data show, however, that considerably fewer companies in this
industry manufacture products from alloyed copper (as opposed to
unalloyed copper). Only 16 firms (with more than \$100,000 in shipments)
produced copper-alloy wire; 14 firms produced copper-alloy rod, bar, and
shapes; 11 firms produced copper-alloy sheet, strip, and plate; and 8
firms produced copper-alloy pipe and tube (other than plumbing pipe).
Furthermore, beryllium-copper is only one of many copper alloys (e.g.,
brass and bronze) that such firms might produce. A list of
beryllium-copper suppliers maintained by the Copper Development
Association lists eight companies with 12 establishments producing
rolled and drawn beryllium-copper products (CDA, 2002). ERG identified
three additional establishments engaged in redrawing or re-rolling
copper alloy materials. Based on this information, ERG estimates that 15
establishments are currently engaged in rolling, drawing, and extruding
of beryllium-copper products. The 2002 Census shows an average of 96
production workers per establishment in this industry. Assuming that the
15 copper-beryllium establishments are of average size, there are 1,440
production employees in these establishments.

Additional establishments redraw purchased wire to customer
specifications. These establishments are classified by in the NAICS
industry 331422: Copper Wire (Except Mechanical) Drawing. The 2002
Economic Census shows 107 establishments in this industry, employing
11,480 employees and 8,195 production workers. No published data exist
on the number of such establishments that handle copper-beryllium
alloys, but estimates from Brush Wellman's (BW) customer database show
59 such facilities (Kolanz, 2001). If these establishments were typical
in size to the rest of the industry and employ about 77 production
workers, their production employment would total 4,519. The statistics
for NAICS 331422 are also shown in Table 8-1

Based on the distribution of establishments by employment size across
each of the two industries, ERG estimated the number of copper-beryllium
establishments in each size class. These are also shown in Table 8-1.

The technological feasibility analysis identified two occupations where
median exposures exceed the lowest PEL option: wastewater treatment
operators (0.11 μg/m^3^) and bulk pickling and annealing operators (0.12
μg/m^3^). ERG estimated there are typically one wastewater treatment
operator and four pickling and annealing operators per affected
facility. These estimates are consistent with results from the Bureau of
Labor Statistics (BLS) 2002 Occupational Employment Survey (OES) which
found 240 pickling operators and 30 waste treatment plant and system
operators in the much broader four-digit NAICS industry, 3314 (BLS,
2004). The OES data, however, might undercount workers in some specific
job classifications because it cannot identify all workers that might
perform multiple tasks.

ERG also estimated the number of facilities that perform the pickling
and annealing tasks in this sector. The BW customer survey database
shows that among its strip and bulk customers (combined), approximately
three times as many customers perform redrawing as perform pickling
(Kolanz, 2001). ERG used this relationship to estimate the number of
firms and affected workers with these processes. Some facilities,
especially small firms, are believed to perform a smaller range of
activities and might not perform bulk pickling and annealing. Based on
the BW data, ERG estimates that 35 facilities among the beryllium-using
firms in the affected industries perform pickling and annealing. These
were allocated between the two NAICS codes as follows: 15 facilities in
NAICS 331421 and 20 in 331422. ERG also estimated that each
beryllium-using facility in this sector (74; see Table 8-1) also
operates a wastewater treatment facility.

**8.2 COST OF CONTROLS**

**Engineering Controls:** The technological feasibility discussion
focuses on two job categories, bulk pickling and annealing operators and
wastewater treatment operators.

***Pickling and Annealing Operators:*** The largest engineering control
costs will be incurred to reduce exposures to the pickling and annealing
operator. As noted in the technological feasibility discussion, BW
personnel expressed uncertainty about the exact source of these
exposures, although many suspicions focus on beryllium releases from the
bulk pickling tank. Further, based on discussions with project
consultants and BW, the most cost-effective means of reducing exposures
to these workers is not certain.

As a result, the applicability and likely effectiveness of possible
engineering controls for the bulk pickling and annealing operations are
uncertain. Nevertheless, ERG and its consultants used their own
engineering judgments to develop a set of possible controls and to
estimate the costs of installation. In applying the engineering control
costs, ERG assumed that all affected facilities will require controls at
the lowest PEL option level. No control costs are required at the higher
PEL levels because the estimated median exposure level for pickling and
annealing operators is below the all of the optional PELs.

The primary engineering control to limit beryllium release from the
pickling bath is enclosure. Simply covering the bath would, however,
present difficult operational issues, and ERG concluded that a
ventilated tunnel enclosure within the manufacturing facility would work
better. A crane system would be constructed inside the tunnel to move
bulk products into and

+------------+----+-------+-------+-------+-------+-------+-------+
| #          |    |       |       |       |       |       |       |
|            |    |       |       |       |       |       |       |
| # Ta       |    |       |       |       |       |       |       |
| ble 8-1. C |    |       |       |       |       |       |       |
| opper Roll |    |       |       |       |       |       |       |
| ing, Drawi |    |       |       |       |       |       |       |
| ng, and Ex |    |       |       |       |       |       |       |
| truding (N |    |       |       |       |       |       |       |
| AICS 33142 |    |       |       |       |       |       |       |
| 1) -- 2002 |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| # NAICS    | *  | **No. | **To  | **    | **Es  | **Es  | **Es  |
|            | *N | of**  | tal** | Produ | tabs. | tabs. | tabs. |
|            | o. |       |       | ction | with  | with  | with  |
|            | of | **Es  | **E   | Work  | \<    | 20-99 | \> 99 |
|            | ** | tabli | mploy | ers** | 20**  | E     | E     |
|            |    | sh-me | ees** |       |       | mploy | mploy |
|            | *  | nts** |       |       | **E   | ees** | ees** |
|            | *F |       |       |       | mploy |       |       |
|            | ir |       |       |       | ees** |       |       |
|            | ms |       |       |       |       |       |       |
|            | ** |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| 331421     | 91 | 136   | 1     | 1     | 47    | 43    | 46    |
| Copper     |    |       | 6,406 | 3,004 | (35%) | (32%) | (34%) |
| Rolling,   |    |       |       |       |       |       |       |
| Drawing,   |    |       |       |       |       |       |       |
| and        |    |       |       |       |       |       |       |
| Extruding  |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| **By       |    |       |       |       |       |       |       |
| Primary    |    |       |       |       |       |       |       |
| Product    |    |       |       |       |       |       |       |
| Class      |    |       |       |       |       |       |       |
| Spec       |    |       |       |       |       |       |       |
| ialization |    |       |       |       |       |       |       |
| (including |    |       |       |       |       |       |       |
| both Cu    |    |       |       |       |       |       |       |
| and Cu-Be  |    |       |       |       |       |       |       |
| p          |    |       |       |       |       |       |       |
| roducts)** |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| 3314211    | NA | 19    | 1,584 | 1,189 | NA    | NA    | NA    |
| Copper     |    |       |       |       |       |       |       |
| wire, bare |    |       |       |       |       |       |       |
| and tinned |    |       |       |       |       |       |       |
| (non       |    |       |       |       |       |       |       |
| el         |    |       |       |       |       |       |       |
| ectrical), |    |       |       |       |       |       |       |
| made in    |    |       |       |       |       |       |       |
| rolling    |    |       |       |       |       |       |       |
| mills      |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| 3314213    | NA | 24    | 3,334 | 2,468 | NA    | NA    | NA    |
| Copper and |    |       |       |       |       |       |       |
| c          |    |       |       |       |       |       |       |
| opper-base |    |       |       |       |       |       |       |
| alloy rod, |    |       |       |       |       |       |       |
| bar, and   |    |       |       |       |       |       |       |
| shapes     |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| 3314217    | NA | 17    | 4,990 | 3,811 | NA    | NA    | NA    |
| Copper and |    |       |       |       |       |       |       |
| c          |    |       |       |       |       |       |       |
| opper-base |    |       |       |       |       |       |       |
| alloy      |    |       |       |       |       |       |       |
| sheet,     |    |       |       |       |       |       |       |
| strip, and |    |       |       |       |       |       |       |
| plate      |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| 3314219    | NA | 26    | 6,063 | 5,201 | NA    | NA    | NA    |
| Copper and |    |       |       |       |       |       |       |
| c          |    |       |       |       |       |       |       |
| opper-base |    |       |       |       |       |       |       |
| alloy pipe |    |       |       |       |       |       |       |
| and tube   |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
|            |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| 3314221    | 79 | 107   | 1     | 8,195 | 31    | 38    | 38    |
| Copper     |    |       | 1,480 |       | (2    | (3    | (3    |
| Wire       |    |       |       |       | 9.0%) | 8.5%) | 5.5%) |
| (Except    |    |       |       |       |       |       |       |
| M          |    |       |       |       |       |       |       |
| echanical) |    |       |       |       |       |       |       |
| Drawing    |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| #          |    |       |       |       |       |       |       |
|  Estimates |    |       |       |       |       |       |       |
|  of Beryll |    |       |       |       |       |       |       |
| ium-Using  |    |       |       |       |       |       |       |
| Facilities |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| NAICS      | NE | 15    | 1,809 | 1,440 | 5     | 5     | 5     |
| 331421(a)  |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| NAICS      | NE | 59    | 6,330 | 4,519 | 17    | 23    | 21    |
| 331422(a)  |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+
| Source: US |    |       |       |       |       |       |       |
| Census     |    |       |       |       |       |       |       |
| Bureau,    |    |       |       |       |       |       |       |
| 2004.      |    |       |       |       |       |       |       |
|            |    |       |       |       |       |       |       |
| \(a\)      |    |       |       |       |       |       |       |
| Estimated  |    |       |       |       |       |       |       |
| by ERG.    |    |       |       |       |       |       |       |
|            |    |       |       |       |       |       |       |
| NA = Not   |    |       |       |       |       |       |       |
| available. |    |       |       |       |       |       |       |
| NE=Not     |    |       |       |       |       |       |       |
| estimated. |    |       |       |       |       |       |       |
+------------+----+-------+-------+-------+-------+-------+-------+

through the pickling bath. The tunnel would also be equipped with a
video system to allow outside operators to operate and observe the
process. A second set of second engineering controls is needed which
will enclose the coil handling operation as bulk materials are moved
from the annealing furnace to the pickling operation. Finally, ERG
estimates that reaching the 0.1 μg/m^3^ level will also require a
ventilated material handling unit (Hawley Trav-L-Vent equipment) to move
products from the annealing to the pre-treatment operation prior to
pickling. Additional engineering controls were also considered but
judged not to be necessary. These controls include the addition of a
clean air island for the pickling operator station, a tunnel for the
annealing operation, and a secondary hood over the annealing furnace to
capture any leakage of beryllium-carrying emissions.

***Wastewater Treatment Operators:*** For wastewater treatment
operators, enhancements include the development and implementation of
good work practices and effective housekeeping protocols to limit
personal exposure and workplace contamination. ERG judged that because
exposures are slightly over the lowest PEL option, only modest changes
in housekeeping practices, such as incremental cleaning time, are
needed. ERG estimated that 15 minutes per shift is adequate to address
this issue.

Table 8-2 presents the list of controls and costs for the pickling and
annealing task, while Table 8-3 summarizes the resultant costs by PEL
option, affected job category, and industry. As shown in Table 8-3, the
estimated engineering controls per establishment for the bulk
pickling/annealing operators are estimated at \$226,014 for 0.1 μg/m^3^
PEL level, with total costs of \$7.9 million. The annual cost of
additional housekeeping by affected wastewater treatment operators is
estimated as \$1,686 per worker, for a total of \$124,773 at the 0.1
μg/m^3^ PEL level. No costs are associated with the higher PEL option
levels.

![](media/image1.wmf){width="5.0in" height="4.025in"}

![](media/image2.wmf){width="6.5in" height="5.873611111111111in"}

**Program Requirements:** Table 8-4 shows the compliance costs for the
program requirements for the two industries comprising rolling and
drawing sector. A complete discussion of the methodology and underlying
assumptions for estimating program costs is presented in Section 2. As
noted there, rolling and drawing is assumed to be a low-exposure sector
for costing purposes under the 2.0 μg/m^3^ PEL option.

The majority of the program costs are associated with requirements for
protective clothing and hygiene areas and include the costs associated
with employee time for showering and vacuuming clothes at the end of
each shift. Combined, these costs represent 74.2 percent of all
program-related costs at the most stringent PEL level of 0.1 μg/m^3^.
Total annualized program costs range from \$337,753 to \$10.2 million
over all the PEL option levels.

**8.3 AGGREGATE COSTS**

Table 8-5 presents the aggregate compliance costs arrayed by PEL option
and by industry. Costs are significantly higher for the lowest PEL
options due primarily to the additional engineering costs. As noted
previously, there is also considerable uncertainty about eventual cost
of engineering controls necessary for these facilities due to the
limited experience with the effectiveness of engineering controls needed
to control exposures at such low levels.

Program costs are also significant, although the major program-related
costs are not sensitive to the PEL option level. At the highest PEL
option, program costs represent about 54 percent of compliance costs. At
the other option levels, all compliance costs are associated with the
program requirements. Total annualized costs range from \$357,753
million to \$18.2 million per year, from the highest to lowest PEL,
respectively.

![](media/image3.wmf){width="6.5in" height="5.907638888888889in"}

![](media/image4.wmf){width="6.5in" height="2.5972222222222223in"}

**REFERENCES**

BLS. 2004. Bureau of Labor Statistics, Occupational Employment Survey,
2002.

Number range CHAPTERCDA. 2002. Copper Development Association Web site
<http://suppliers.copper.org/fab_frame.htm>. Accessed February 18, 2002.

Kolanz, Mark. 2001. Brush Wellman Customer Data Summary. OSHA
Presentation, July 2, 2001. Washington, DC.

U.S. Census Bureau. 2004. 2002 Economic Census: Copper Wire (Except
Mechanical) Drawing, 2002; Copper Rolling, Drawing, and Extruding, 2002.