Group I, Phase II

       Development Document for
    Effluent Limitations Guidelines
and New Source Performance Standards
                for the

       TEXTILE, FRICTION  MATERIALS
          AND SEALING DEVICES

             Segment of the

    ASBESTOS MANUFACTURING

         Point Sour ,e Category
                       •&
                  +L PRtf


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

               December 1974

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,.-*

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                 DEVELOPMENT DOCUMENT

                           for

            EFFLUENT  LIMITATIONS GUIDELINES

                           and

           NEW SOURCE PERFORMANCE STANDARDS

                         for the

    TEXTILE, FRICTION MATERIALS AND SEALING  DEVICES
                    SEGMENT OF THE
     ASBESTOS MANUFACTURING POINT SOURCE CATEGORY
                    Russell  E. Train
                      Administrator

                      James  L. Agee
         Assistant  Administrator for Water  and
                  Hazardous Materials
                       Allen Cywin
        Director,  Effluent Guidelines Division

                    Richard T. Gregg
                     Project Officer
                     December  1974
             Effluent  Guidelines Division
        Office of Water and Hazardous Materials
         U. S. Environmental  Protection Agency
               Washington,  D.  C.  20460
For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, D.C. 20i02 - Price $1.70

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                              ABSTRACT
This document presents the findings of an extensive study of part of
the asbestos manufacturing industry by the Environmental  Protection
Agency for the purpose of developing effluent limitations guidelines
and Federal standards of performance, for the industry, to implement
Sections 304, 306, and 307 of the "Act."

Effluent  limitations  guidelines  contained  herein  set  forth the
degree of effluent reduction attainable through the  application  of
the  best practicable control technology currently available and the
degree of effluent reduction attainable through the  application  of
the  best available technology economically achievable which must be
achieved by existing point sources by July  1,  1977,  and  July  1,
1983,  respectively.   The  Standards of Performance for new sources
contained herein set forth the degree of effluent reduction that  is
achievable   through   the   application   of   the  best  available
demonstrated control technology, processes,  operating  methods,  or
other alternatives.

The  development  of data and recommendations in the document relate
to a portion of the asbestos manufacturing category in  which  water
usage  is  limited.   This segment was subdivided into four subcate-
gories on the bases of raw waste loads, quantities  of  waste  water
discharged,   and   applicability  of  control  measures.   Separate
effluent limitations were developed  for  each  subcategory  on  the
bases  of  the  level  of  raw  waste loads as well as the degree of
treatment achievable by  suggested  model  systems.   These  systems
include  sedimentation   (with  coagulation, as necessary), neutrali-
zation, biological treatment, carbon adsorption, substitution of dry
air pollution control equipment, and certain in-plant changes.

Supportive data  and  rationale  for  development  of  the  proposed
effluent  limitations  guidelines  and  standards of performance are
contained in this report.
                                 ill

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              TABLE OF CONTENTS
SECTION

     I

    II

   III
    IV
    VI
   VII
Conclusions

Recommendations

Introduction

      Purpose and Authority
      Summary of Methods
      Genera] Description of the Industry
      Location of Manufacturers
      Manufacturing Processes
      Textile Products
      Friction Materials
      Gaskets, Packing, and Sealing Devices
      Current Status of the Industry

Industry Categorization

      Introduction and Conclusions
      Factors Considered

Water Use and Waste Characterization

      Textile Coating
      Solvent Recovery
      Vapor Absorption
      Wet Dust Collection
      Dispersion Process
      Plant Descriptions

Selection of Pollutant Parameters

      Major Pollutants
      Other Pollutants

Control and Treatment Technology

      Introduction
      In-Plant Control Measures
      Treatment Technology
      Industry Subcategories
PAGE

  1

  3

  5

  5

  8
 11
 15
 15
 17
 23
 24

 25

 25
 25

 29

 29
 30
 30
 31
 32
 32

 37

 37
 39

 47

 47
 48
 49
 50

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SECTION                                                       PAGE

  VIII     Cost,  Energy,  and Non-Water Quality Aspects         53

                 Representative Plants                         53
                 Cost Information                              55
                 Control  Technologies with Costs               56
                 Energy Requirements of Control Technologies   65
                 Non-Water Quality Aspects of Control
                   Technologies                                66

    IX     Effluent Reduction Attainable Through
             Application  of the Best Practicable Control
             Technology Currently Available - Effluent
             Limitations  Guidelines                            69

                 Introduction                                  69
                 Effluent Reduction Attainable Through
                   the Application of Best Practicable
                   Control Technology Currently Available      70
                 Identification of Best Practicable
                   Control Technology Currently Available      70
                 Rationale for the Selection of Best
                   Practicable Control Technology
                   Currently Available                         71

     X     Effluent Reduction Attainable Through
             Application  of the Best Available
             Technology Economically Achievable -
             Effluent Limitations Guidelines                   75

                 Introduction                                  75
                 Effluent Reduction Attainable Through
                   Application of the Best Available
                   Technology Economically Achievable          75
                 Identification of Best Available
                   Technology Economically Achievable          76
                 Rationale for the Selection of Best
                   Available Technology Economically
                   Achievable                                  77

    XI     New Source Performance Standards                    79

                 Introduction                                  79
                 Effluent Quality Achieved Through
                   Implementation of New Source Performance
                   Standards                                   79
                 Identification of New Source Performance
                   Standards                                   79
                               VI

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SECTION
   XII
  XIII
   XIV
Acknowledgments
References
Glossary
PAGE
 83
 85
 89
                                  vil

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                              FIGURES
NUMBER
  1
  2
Asbestos Textiles Manufacturing Operations
Dry-Mixed Molded Brake Linings Manufacturing
  Operations
Wet-Mixed Molded Brake Linings Manufacturing
  Operations
Molded Clutch Facings Manufacturing Operations
Woven Clutch Facings Manufacturing Operations
PAGE
 16

 19

 20
 21
 22
                                 IX

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                               TABLES
NUMBER

  1


  2



  3


  4


  5


  6


  7
  9


 10



 11



 12
Locations of Asbestos Manufacturing Plants •
  Phase II

General Description of Known Waste Water
  Sources Asbestos Manufacturing Plants -
  Phase II

Representative Manufacturing Plants Used in
  Developing Cost Estimates

Water Effluent Treatment Costs - Asbestos
  Textile Coating

Water Effluent Treatment Costs - Solvent
  Recovery

Water Effluent Treatment Costs - Vapor
  Absorption

Water Effluent Treatment Costs - Wet Dust
  Collection - Small Plant

Water Effluent Treatment Costs - Wet Dust
  Collection - Medium Plant

Water Effluent Treatment Costs - Wet Dust
  Collection - Large Plant

Effluent Reduction Attainable Through
  Application of Best Practicable Control
  Technology Currently Available

Effluent Reduction Attainable Through
  Application of Best Available Technology
  Economically Achievable

Standards of Performance for New Sources
PAGE


 12



 34


 54


 57


 58


 60


 62


 63


 64



 68



 74

 80

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                             SECTION I

                            CONCLUSIONS
That part of the asbestos industry covered in this  document  (Phase
II)   includes  the  manufacture of asbestos textiles, friction mate-
rials, and asbestos gaskets, packings, and sealing devices.  In most
of the plants in this part of the industry, water is not used in the
manufacturing processes and waste waters are not  generated.   In  a
few   plants,   process-related   waste   waters  are  generated  by
manufacturing operations or by air pollution control equipment.  The
industry  covered  in  this  document  is   classified   into   four
subcategories.  The factors in this subcategorization were raw waste
loads,   volumes  and  rates  of  discharge  of  waste  waters,  and
differences in applicable in-plant control measures and  end-of-pipe
treatment technologies.

The subcategories are for the following operations:

     1.    Coating, or finishing, of asbestos textiles,

     2.    solvent recovery,

     3.    Vapor absorption, and

     1.    Wet dust collection.

The waste waters resulting from the first  three-  subcategories  are
similar in that the primary pollutants are synthetic organic resins,
elastomers,  and/or  solvents,  but  they  differ in composition and
concentration.   The  wastes  from  the  wet  dust  collectors   are
characterized by high suspended solids levels.

About  half  of  the  plants that generate waste waters discharge to
municipal sewerage  systems,  with  or  without  pretreatment.   The
remaining  plants  provide  at  least  lagoon sedimentation prior to
discharge to surface waters.  None of the plants  included  in  this
study   provide  treatment  designed  to  remove  dissolved  organic
pollutants.

Recommended effluent limitations to be achieved by July 1, 1977, and
July 1, 1983, are summarized in Section II.  It  is  estimated  that
the  investment cost of achieving the 1977 limitations and standards
by all plants in the industry is approximately  $200,000,  excluding
costs  of  additional  land  acquisition.  The cost of achieving the
1983 level is estimated to be less than $800,000 for  the  industry,
i.e.t an additional $600,000 over the 1977 level.

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                             SECTION II

                          RECOMMENDATIONS


Recommended  control and treatment technologies for this part of the
asbestos  industry  were  developed  for  each   subcategory.    The
discharge  of  pollutants  from  asbestos textile coating to surface
waters can be eliminated through  in-plant  measures;  i.e.,  elimi-
nation  of  dumps  and  spills  and  substitution  of  dry  cleaning
techniques for wet  clean-up  methods.   The  discharge  of  organic
pollutants from solvent recovery and vapor absorption operations can
be reduced or eliminated by biological treatment, carbon adsorption,
and/or  substitution  of  dry  air pollution control equipment.  The
discharge of suspended solids from wet particulate collectors can be
controlled by sedimentation and eliminated by substituting dry  dust
collection devices for the wet scrubbers.

The   recommended   effluent  limitations  as  30-day  averages  for
parameters of major significance and standards  of  performance  for
plants within the four subcategories are summarized as follows:

Best Practicable control Technology Currently Available

                    Textile      solvent     Vapor        Wet Dust
                    Coating      Recovery* Absorption    Collection**

COD                  zero         0.150       zero          NA
Suspended Solids     zero         0.090       zero          2.50
pH                   	          6-9         6-9           6-9

        Best Available Technology Economically Achievable

                    Textile      Solvent     Vapor        Wet Dust
                    Coating      Recovery* Absorption    Collection

COD                  zero         0.150      zero         zero
Suspended Solids     zero         0.090      zero         zero
pH                   	          6-9         	          	

            Standards of Performance for New Sources

                    Textile      Solvent     Vapor        Wet Dust
                    Coating      Recovery* Absorption    Collection

COD                  zero         0.150      zero         zero
Suspended Solids     zero         0.090      zero         zero
pH                   	          6-9         	          	

     *COD and ss as lb/1000 of finished asbestos products,
    **NA - Not Applicable.  SS as Ib/MM std cu ft  of air scrubbed,.

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More  detailed  explanations  of  these limitations are presented in
Sections IX, X, and XI of this document.

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                            SECTION III

                            INTRODUCTION
PURPOSE AND AUTHORITY

Section 301(b) of the Act requires the achievement by not later than
July 1, 1977, of effluent limitations for point sources, other  than
publicly  owned  treatment works, which are based on the application
of the best practicable control technology  currently  available  as
identified  by  the  Administrator pursuant to Section 304(b) of the
Act.  Section 301(b) also requires the achievement by not later than
July 1, 1983, of effluent limitations for point sources, other  than
publicly  owned  treatment works, which are based on the application
of the best available technology economically achievable which  will
result  in  reasonable  further progress toward the national goal of
eliminating the  discharge  of  all  pollutants,  as  determined  in
accordance  with regulations   issued by the Administrator pursuant to
Section 304 (b) of the Act.  Section 306  of  the  Act  requires  the
achievement by new sources of a Federal standard of performance pro-
viding for the control of the discharge of pollutants which reflects
the  greatest  degree of effluent reduction which the Administration
determines to be achievable through  the  application  of  the  best
available  demonstrated  control  technology,  processes,  operating
methods, or other  alternatives,  including,  where  practicable,  a
standard permitting no discharge of pollutants.

Section  304(b)  of  the  Act  requires the Administrator to publish
within one year of  enactment  of  the  Act,  regulations  providing
guidelines  for  effluent  limitations  setting  forth the degree of
effluent reduction attainable through the application  of  the  best
practicable control technology currently available and the degree of
effluent  reduction  attainable  through the application of the best
control measures and  practices  economically  achievable  including
treatment  techniques,  process and procedure innovations, operation
methods and other alternatives.  The regulations proposed herein set
forth effluent limitations guidelines pursuant to Section 304(b)  of
the  Act  for  certain  subcategories  of the asbestos manufacturing
source category,  relating  to  textiles,  friction  materials,  and
sealant  devices.  They include coating of textile products, solvent
recovery, vapor absorption, and wet dust collection.

Section 306 of the Act requires the Administrator, within  one  year
after a category of sources is included in a list published pursuant
to   Section   306 (b) (1) (A)  of  the  Act,  to  propose  regulations
establishing Federal standards of performance for new sources within
such  categories.   The  Administrator  published  in  the   Federal
Register  of  January  16,  1973  (38 F.R. 1624), a list^of 27 source
categories.  Publication of the list constituted announcement of the
Administrator•s  intention  of  establishing,  under  Section   306,
standards  of  performance  applicable  to  new  sources  within the
asbestos manufacturing industry  subcategory  as  delineated  above,
which was included with the list published January 16, 1973.   —^

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SUMMARY  OF METHODS USED FOR DEVELOPMENT OF THE EFFLUENT LIMITATIONS
GUIDELINES AND STANDARDS OF PERFORMANCE

Purpose and Authority

The effluent limitations guidelines  and  standards  of  performance
proposed  herein  were developed in the following manner.  The point
source category was first categorized for the purpose of determining
whether separate  limitations  and  standards  are  appropriate  for
different  segments  within  a point source category.  Such subcate-
gorization was based  upon  raw  material  used*  product  produced,
manufacturing  process  employed,  and other factors.  The raw waste
characteristics for each subcategory  were  then  identified.   This
included  an  analysis of  (1) the source and volume of water used in
the process employed and the sources of waste and waste water in the
plant; and (2) the constituents  (including  thermal)  of  all  waste
waters;  including  toxic  constituents and other constituents which
result in taste, odor, and color in water or aquatic organisms.  The
constituents of waste waters which should  be  subject  to  effluent
limitations guidelines and standards of performance were identified.

The full range of control and treatment technologies existing within
each subcategory was identified.  This included an identification of
each  distinct  control and treatment technology, including both in-
plant and end-of-process technologies, which are existent or capable
of being  designed  for  each  subcategory.   It  also  included  an
identification  in  terms  of  the amount of constituents (including
thermal)  and the chemical, physical, and biological  characteristics
of  pollutants, of the effluent level resulting from the application
of each of the treatment and control  technologies.   The  problems,
limitations and reliability of each treatment and control technology
and  the  required  implementation  time  was  also  identified.  In
addition, the non-water quality environmental impact,  such  as  the
effects of the application of such technologies upon other pollution
problems,  including air, solid waste, noise and radiation were also
identified.  The energy requirements of  each  of  the  control  and
treatment  technologies  were  identified  as well as the cost of the
application of such technologies.

The information, as outlined above, was then evaluated in  order  to
determine   what   levels   of   technology  constituted  the  "best
practicable control technology currently available," "best available
technology  economically  achievable,"  and  the   "best   available
demonstrated  control  technology,  processes, operating methods, or
other alternatives."   In  identifying  such  technologies,  various
factors   were   considered.   These  included  the  total  cost  of
application of technology in  relation  to  the  effluent  reduction
benefits  to be achieved from such application, the age of equipment
and facilities  involved,  the  process  employed,  the  engineering
aspects  of  the  application of various types of control techniques
process changes, non-water quality environmental  impact  (including
energy requirements) and other factors.

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Sources of Data

The   waste  waters  associated  with  asbestos  manufacturing  have
received almost  no  attention  in  the  engineering  and  pollution
control  literature.   Very  few plants have collected any extensive
data about the characteristics of the waste waters discharged.   The
information  used  in  this  document  was  derived from a number of
sources.  Some of the sources were  published  literature  on  manu-
facturing  methods,  EPA  technical  reports  on  the  industry, and
consultation with qualified personnel.  Additional  information  was
obtained from plant visits; plant records, where available; and from
the  few  RAPP  applications  that  have  been  filed.   Most of the
information  was  developed  through  direct  contact  by  the   EPA
contractor, with some additional material derived from a preliminary
questionnaire  distributed  to  its  membership by the Fluid Sealing
Association  (formerly the Mechanical Packing Association),

Thirty-six companies or corporations at 51 plant  locations  in  the
United  States  provided  information  for  this  document.  Another
thirteen companies, exclusive of those receiving  the  questionnaire
distributed by FSA, were contacted and found not to be manufacturers
of products covered by this study.  The 36 companies include most of
the large- and medium-sized manufacturers and what is believed to be
a representative cross-section of the small organizations.

The  products  covered by this study can be grouped into three types
as shown below.  The 51 plants  included  in  this  study  are  dis-
tributed among the product types as follows:

           Asbestos Textile Products               10 plants
           Friction Materials                      25
           Asbestos-Containing Gaskets,
             Packings, and Sealing Devices         11
           Multi-Products Plants                    5

At three of the multi-product plants, two Phase II product types are
manufactured.   All  three  Phase  II  product types are made at two
plants.  In addition, at ten of the 51 plants, non-Phase II products
are also manufactured.  At three of these locations, the other prod-
ucts are asbestos items covered  in  the  Phase  I  study.   At  the
remaining seven plants, non-asbestos product manufacturing generates
waste  waters  that are much more significant in terms of quantities
and types of pollutant constituents.  The wastes from asbestos manu-
facturing are combined with  these  stronger  wastes  for  treatment
and/or discharge.  The combined effluents should be regulated by the
guidelines developed for the other non-asbestos products.

As  noted  above, a voluntary questionnaire was distributed to those
members of the FSA not contacted directly  by  the  EPA  contractor.
The  questionnaire  was  distributed  in order to locate for further
study those asbestos-containing sealant  manufacturing  plants  that
discharge process waste waters.  It also provided an opportunity for
companies  that  were  not  contacted directly to participate in the
study, if they wished.  A copy of this preliminary questionnaire  is

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presented  on  the  following pages.  All manufacturers of asbestos-
containing sealing devices that completed  and  returned  the  ques-
tionnaire  indicated  that  no process waste waters are generated in
their operations.

Of the 28 questionnaires distributed,  eight  were  returned.   This
return  of close to 30 percent is believed to be reasonably success-
ful in light of the fact that many members of  the  FSA  manufacture
non-asbestos sealing devices and, hence, would have little incentive
to return the questionnaire.

GENERAL DESCRIPTION OF THE INDUSTRY

Although known as a curiosity since biblical times, asbestos was not
used in manufacturing until the latter half of the 19th century.  By
the  early  years  of the 20th century, much of the basic technology
had been developed, and the industry has grown in this country since
about that time.  Canada is the world's largest producer  of  asbes-
tos,  with  the USSR and a few African countries as major suppliers.
Mines in four  states:  Arizona,  California,  North  Carolina,  and
Vermont,  provide  a  relatively  small  proportion  of  the world's
supply,

Asbestos is normally combined with other materials  in  manufactured
products,  and consequently, it loses its identity.  It is a natural
mineral fiber which is very strong and  flexible  and  resistant  to
breakdown  under  adverse  conditions, especially high temperatures.
One or more of these properties are exploited in the  various  manu-
factured products that contain asbestos-

Asbestos  is actually a group name that refers to several serpentine
minerals having different chemical compositions, but  similar  char-
acteristics.   The most widely used variety is chrysolite.  Asbestos
fibers are graded on the basis of length,  with  the  longest  grade
priced 10 to 20 times higher than the short grades.

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                         QUESTIONNAIRE FORM
Company Name

Plant Address
Name of Contact at Plant

Telephone Number at Plant

Product(s) Manufactured _
Operating Schedule;	Hours per Day 	 Days per Week

Number of Employees 	

Are there other plants in this company that manufacture asbestos-
containing products?  Yes 	 No 	


1.   Do any of the products manufactured or fabricated at this
     plant contain asbestos?  Yes 	 No 	
     If wno", please stop here and return questionnaire.
     If "yes", please continue below.

2.   Is water used in any way in the manufacturing or auxiliary
     operations?  Yes	No 	
     If "no", please stop here and return questionnaire,
     If "yes11, please complete below.

3,   Is any waste water  (other than sanitary) discharged from
     plant?  Yes	No 	

4.   Is waste water treated before leaving plant  property?
     Yes	No	

5.   Is waste water  (with or without treatment) discharged  to:
     public sewer    	
     stream or lake  	
     lagoon          	

     other (please describe)  	

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INDIVIDUAL PLANT QUESTIONNAIRE
6.   Is information available about the quantities of waste waters
     discharged?  Yes 	 No 	
     About the waste water characteristics?  Yes 	 No 	
     If "yes", please describe type of information:
7.
Has a discharge permit application been filed for this plant?
Yes       No
                               10

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On  a  world-wide basis, asbestos-cement products materials and pipe
currently consume about 70 percent of the asbestos  mined.   In  the
United States in 1971, the consumption pattern was reported to be;

           Vinyl-Asbestos Floor Tile                      19.2%
           Asbestos-Cement Pipe                           18.7
           Paper and Felt, including Roofing              14.7
           Friction Materials                             10.7
           Asbestos-Cement Building
             Materials                                     6.7
           Packing Materials                               3.3
           Textiles                                        2.9
           Asbestos Insulation                             2.1
           Spray-on Asbestos Materials                     2.0
           All Other Asbestos Products                    19.0
                                                         100.OX

These  figures  do  not  accurately reflect the production levels of
these products because the asbestos content varies from about 10  to
almost 100 percent among the different manufactured products.

The asbestos manufacturing industry is classified in two SIC groups:
3292,  Asbestos  Products;  and  3293,  Gaskets, Packing and Sealing
Devices.  The products covered in the earlier Phase I study of  this
industry were:

                    Asbestos-Cement products.
                    Asbestos Paper and Felt,
                    Asbestos Millboard,
                    Asbestos Roofing Products,
                    Asbestos Floor Tile, and
                    Asbestos Block Insulation.

This  Phase II document includes the remaining products in these  SIC
groups.  They may be  grouped as follows:

           Textile Products  -  yarn, cord, rope, thread, tape,
                                wicks, and various fabrics.

           Friction Materials - brake linings, clutch facings,
                                and related items.

           Gaskets, seals, washers, and packings that contain asbestos

LOCATION OF MANUFACTURERS

The locations of the  51 plants that  were  contacted  in  connection
with this study are listed in Table 1.  This listing includes all of
the  known  manufacturers  of  asbestos textiles, most of the plants
engaged primarily in  manufacturing friction materials, and  what  is
believed  to  be  a   large,  representative sampling of producers of
asbestos-containing gaskets, packings, and sealing devices.
                               11

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                                                       TABLE 1




                                LOCATIONS OF ASBESTOS MANUFACTURING PLANTS - PHASE II
H

State
Alabama
California
Connecticut
Georgia
Illinois
Indiana
Kentucky
Massachusetts
Michigan
New Hampshire
City
Prattville
Fuller ton
Stratford
Hogansville
Glenwood
Waukegan
Crawfordsville
Logansport
New Castle
Warsaw
Danville
Lawrence
North Brookf ield
Hartford
Saginaw
St. Joseph
Trenton
Meredith
Company
Molded Industrial Friction Corp.
Raybestos-Manhattan
Raybestos-Manhattan
Uniroyal, Inc.
Jas. Walker Packing Company, Inc.
Johns-Manville
Raybestos-Manhattan
National Friction Products Corp.
World Bestos Company
Gatke Corporation
Royal Industries Brake Products
Auto Friction Corporation
Gatke Corporation
Auto Specialties Manufacturing Co.
General Motors Corporation
Auto Specialties Manufacturing Co.
Chrysler Corporation
Amatex Corporation
Products
FM
FM
*FM, S
*T
i
m
FM
FM
FM
FM
FM
FM, T, S
*FM
*FM
T

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                                                   TABLE 1 (cant)




                                LOCATIONS OF ASBESTOS MAMJFACTURING PLANTS - PHASE II
H

State
New Jersey








New York

North Carolina


Ohio




Pennsylvania






City
Cranford
Manville
Newark
New Brunswick
North Brunswick
Patterson
Trenton
Trenton

Green Island
Palmyra
Charlotte
Laurinberg
Marshville
Boydsville
Chagrin Falls
Dayton
Dayton
Paulding
Ambler
Manheim
Norristown
North Wales
North Wales
Philadelphia .
Ridgway
Company
Chempro, Inc.
Johns-Manville
Redd away
Metallo Gasket Company
Johns-Manville
Brassbestos Manufacturing Corp.
Mercer Rubber Company
Thiokol Chemical Corporation

Bendix Corporation
Garlock, Inc.
H. K. Porter, Inc.
Johns-Manville
Raybestos-Manhattan
Wheeling Brake Block Mfrg. Company
Hollow Center Packing Company, Inc.
General Motors
General Motors
Maremont Corporation
Nicolet
Raybestos-Manhattan
Amatex Corporation
Atlas Textile Company
Greene, Tweed & Company
Asten-Hill Manufacturing Company
Carlisle Corporation
Products
*s
T
FM
S
S
FM
S
FM
-x-
FM
T, S
T
FM
T
FM
S
FM
FM
FM
*T, S
FM, T, S
T
T
S
T
FM

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-p-
                                                   TABLE  1  (cont)

                                LOCATIONS OF ASBESTOS MANUFACTURING PLANTS - PHASE II

State
South Carolina
Tennessee
Texas
Virginia
City
Bennetsville
North Charleston
Cleveland
New Port
Houston
Houston
Houston
Winchester
Company
H. K. Porter, Inc.
Raybestos-Manhattan
Bendix Corporation
Detroit Gasket & Manufacturing Co.
Lamons Metal Gasket Company
Standee Industries
Standee Industries
Abex Corporation
Products
T
T
m
S
Q
m
•s
FM
         KEY:   FM - Friction Materials
                S - Sealants (Gaskets, Packings, etc.)
                T - Textiles
          Waste waters from manufacture of products not covered by this study are more significant at these
          plants.

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At only ten of the listed plants are process-associated waste waters
generated, and at five of these the waste waters emanate  only  from
wet air pollution control equipment.  In most cases, the manufacture
of the products in this study is a "dry" process and does not result
in the generation of process waste waters.

MANUFACTURING PROCESSES

The  basic  manufacturing  processes  for  the products in the three
groups covered are outlined  below  with  sources  of  waste  waters
indicated.  As noted previously, water is not normally used directly
in  the  manufacturing  operations,  and  the waste waters from this
segment of the asbestos industry are  generated  in  a  few  special
operations not common to the industry generally,

TEXTILE PRODUCTS

The  primary  reasons  for  the  use  of  asbestos  fiber in textile
products are its properties of durability and  resistance  to  heat,
fire,  and  acid.  Asbestos is the only mineral that can be manufac-
tured into textiles using looms and other  textile  equipment.   The
asbestos textile products are primarily used for friction materials,
industrial packing, electrical insulation, and thermal insulation.

Figure  1  illustrates  the  steps in the manufacture of the various
asbestos textile products.  The textile plants receive the  asbestos
fiber  by  railcar  in 100-pound bags.  The bags are opened, and the
fibers passed over vibrating screens or trommel screens  for  clean-
ing.   The  fibers  are  lifted  from the screens by air suction and
graded.  After preparation, the fiber is mixed and  blended.   Chry-
solite  is  the predominant fiber used in textiles.  Crocidolite and
amosite asbestos fibers may also be added to the chrysolite.   Small
percentages  of cotton, rayon, and other natural or synthetic fibers
serve as carriers or supports for the shorter asbestos  fibers,  and
they  improve the spinnability of the fiber mixture.  Typically, the
organic fiber content is between 20 and 25  percent.   The  blending
and  mixing  operations  are  primarily  done  during carding of the
fibers, but can also be performed in multi-hopper blending units.

In the carding operation, the fibers are arranged  by  thousands  of
needle-pointed  wires  that  cover  the  cylinders  of  the  carding
machine.  The fibers are  combed  by  passing  between  the  carding
machine  main  cylinder  and  the  worker  cylinders rotating in the
opposite direction.  The carding machine forms a continuous  mat  of
material.    The  mat  is  divided  into  strips,  or  slivers,  and
mechanically compressed between oscillating surfaces into  untwisted
strands.   The  strands  are  wound  on  spools  to form the roving.
Roving is the asbestos textile product from which asbestos  yarn  is
produced.

The roving is spun into yarn in a manner similar to that employed to
manufacture  cotton  and  wool  yarns.   The  strands  of roving are
converted into a single yarn by the twisting and pulling  operations
of  a  spinning machine.  The yarn produced by spinning and twisting
                               15

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RAW MATERIALS
STORAGE


FIBER PREPARATION


BLENDING

MIXI






+ 1


, 	 , 1
TWISTING SMGLE V
WISTEO ROPE
w •
BRAIDING I
*
BRAIDED
ROPE
1
^ 	



NG —
r
NG
r
NG

^
r
r*
r ^^
*
1 BRAIDING | WE
t
	 RAYON. COTTON
I OR OTHER FBER


	 ^-NON-WOVEN FELTS
LIGHT GAUGE WHE
+


1 1
PLIED YARNS d«TAUJC YARNS
i i


^COATtJG |_ DRYING _^. TREATED
• i • OVEN YARNS
I^WASTE WATER
TWISTING L^TWISTED CORD

^
EAVING
^
            r~—   i       i      i
          BRAIDED  BRAIDED BRAIDED  TAPE  WOVEN  CLOTH
          TUBING   CORD   ROPE         TUBING
                                                         SOLVENT
                                                COATING
                                           CLOTH
                                                                ^TREATED

                                                                 FABRIC
                                                       IASTE WATER
FIGURE  1-ASBESTOS  TEXTILE MANUFACTURING OPERATIONS
           (From handbook of Asbestos Textiles)
                               16

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is the basic component of several other asbestos  textile  products.
Asbestos  twine or cord is produced by twisting together two or more
yarns on a spinning frame  similar  to  those  used  to  manufacture
cotton cord.  Braided products are made by a series of yarn-carrying
spindles,  half  traveling in one direction and half in the opposite
direction to plait the yarn together and form a braided product.

Asbestos yarn can also be twisted or braided into various shapes  to
form  packing  and gaskets.  The braided material can be impregnated
with different compounds.  Graphite is commonly used  to  impregnate
braided   packing   material,  the  graphite  serves  to  lower  the
frictional and binding properties of the packing.

Asbestos cloth is woven from yarn on looms that operate in a  manner
similar to those used for the manufacture of other textile products.
The  warp  yarn  is threaded through the heddles and the reed of the
loom and the filler yarn is wound on quills and placed in a shuttle.
The cloth is woven as the filler yarn in the shuttle interweaves the
warp yarn transversely.  Following weaving, the  asbestos  cloth  is
inspected for strength, weight, and asbestos content.

Asbestos  yarn  or cloth may be coated for fabrication into friction
materials and special  textile  products.   The  material  is  drawn
through  one or more dip tanks and the coating material is spread by
rollers, brushes, or doctor blades.  The coated textile product then
passes through a drying oven where the solvent is evaporated.

Water Usage

Water is not normally used  in  an  asbestos  textile  manufacturing
plant.   Two  exceptions are the addition of moisture during weaving
or braiding and the coating operations.  Waste  water  is  generated
only in the latter process.

Operating Schedule

A  typical  asbestos  textile plant operates two or three shifts per
day and five days per week.

FRICTION MATERIALS

Molded Products

The manufacturing steps  typically  used  in  dry-mix  molded  brake
lining  manufacture  are  shown  in  Figure  2.  The bonding agents,
metallic constituents, asbestos fibers, and  additives  are  weighed
and  mixed in a two-stage mixer.  The mix is then hand-tamped into  a
metal mold.   The  mold  is  placed  in  a  preforming  press  which
partially  cures  the  molded asbestos sheet.  The asbestos sheet is
taken from the preforming press, and put in a steam preheating  mold
to soften the resin in the molded sheet.  The molded sheet is formed
to  the  proper  arc  by a steam-heated arc former, which resets the
resin.  The arc-formed sheets are then cut  to the proper size.  The
lining is then baked in compression molds to retain  the  arc  shape
                                17

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and  convert  the  resin to a thermoset or permanent condition.  The
lining is then finished and, after  inspection,  is  packaged.   The
finishing  steps  include  sanding  and  grinding  of  both sides to
correct the thickness, edge grinding,  and  drilling  of  holes  for
rivsts.    Following   drilling,   the   lining  is  vacuum-cleaned,
inspected, branded, and packaged,

Figure 3 shows the major  steps  in  the  manufacture  of  wet-mixed
molded  brake linings.  The name "wet mix" process is a misnomer and
refers to the use of a  solvent.   The  ingredients  of  the  molded
lining  are actually relatively dry.  After weighing, they are mixed
in a sigma blade mixer.  The mixed  ingredients  are  then  sent  to
grinding  screens  where  the  particle  size of the mixture is cor-
rected.  The mixture is conveyed to a hopper and is forced from  the
hopper  into  the nip of two form rollers which compress the mixture
into a continuous strip of friction material.  The strip is cut into
the proper lengths and then arc-formed on a round  press  bar.   The
cutting  and arc forming operations are done by separate units.  The
linings are then placed in racks and either air-dried or  oven-dried
to  remove the solvent.  An alternative process is to place the arc-
formed linings in metal molds for  baking  in  an  oven.   From  the
ovens, the linings are finished, inspected, and packaged.

Molded  clutch  facings are produced in a manner similar to the wet-
mixed process.  The rubber friction compound, solvent, and  asbestos
fibers are introduced into a mixer churn.  After the churn mixes the
ingredients, the mixture is conveyed to a sheeter mill which forms a
sheet  or slab of the materials.  The sheet is then diced into small
pieces by a rotary cutter.  The pieces are placed  in  an  extrusion
machine  which  forms  sheets of the diced material.  The sheets are
cut into the proper size and then  punch-pressed  into  doughnut-shaped
sheets.   The  scraps  from  the  punch  press  are  returned to the
extrusion machine.  The punched sheets are placed on racks and  sent
to a drying oven and then a baking oven for final curing and solvent
evaporation.    The  oven-dried  sheets  are  finally  sent  to  the
finishing  operations.   Figure  4  illustrates  the  steps  in  the
manufacture of molded clutch facings.

Woven Products

Woven  clutch  facings  and  brake linings are manufactured of high-
strength asbestos fabric that is frequently  reinforced  with  wire.
The  fabric  is predried in an oven or by an autoclave to prepare it
to be impregnated with resin.  The fabric can  be  impregnated  with
resin  by  several  techniques:  1) immersion in a bath of resin, 2)
introducing  the  binder  in  an  autoclave   under   pressure,   3)
introducing  dry  impregnating  material  into  carded  fiber before
producing yarn, and U) imparting binder into  the  fabric  from  the
surface  of  a  roll.   After  the  solvents are evaporated from the
fabric, it is made into brake  linings  or  clutch  facings.   Brake
linings are made by calendering or hot pressing the fabric in molds.
The  linings are then cut, rough ground, placed in molds, and placed
in a baking oven for final curing.  Following curing, the lining  is
finished,  inspected,  and  packaged.   The composition by weight of
                               18

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RAW MATERIALS
STORAGE
PROPORTIONING


                           MIXING
                         PREFORMING
                           PRESS
     COOLING WATER     STEAM
     COOLING WATER     STEAM
                                                WATER
                                       •CONDENSATE
                        ARC FORMER [
^•COOLING WATER
^CONDENSATE
                            .
                           CUTTING
                      COMPRESSION MOLD
                        BAKING OVEN


INSPECTION
PACKAGING
STORAGE
                         CONSUMER
FIGURE 2-DRY-MIXED BRAKE LINING MANUFACTURING OPERATIONS
                            19

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                           RAW MATERIALS
                              STORAGE
                           PROPORTIONING
                               MIXING
                              GRINDING
                              SCREENS
                             TWO-ROLL
                              FORMING
                                I
                             I CUTTING I



                            ARC FORMING
                             AIR DRYING
                                                 SOLVENT
                                                 SOLVENT
                            DRYING OVEN
                             FINISHING
    A

• DUST
                             INSPECTION
                             PACKAGING
                             STORAGE
                             CONSUMER
FIGURE 3-WET-MIXED MOLDED BRAKE LINING MANUFACTURING OPERATIONS
                                 20

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  COOLING WATER
                        RAW MATERIALS
                           STORAGE
                        PROPORTIONING
                          | MIXING |
STEAM
~^4-

TWO-ROLL FORMING]
(SHEETER MILL) |


                                              COOLING WATER

                                              CONDENSATE
                        ROTARY CUTTER
EXTRUSION MACHINE
                                       |   •
                          [CUTTING |
                                            (RECYCLED SOLIDS)
                        | PUNCH PRESS H™ "•
                                            SOLVENT
                        | DRYING QVENJ
                                            SOLVENT
                         | BAKING OVEN~[
                           |pRESS|
                         [FINISHING^™*^ DUST


INSPECTION
PACKAGING
STORAGE
                             4-
                          CONSUMER
FIGURE 4- MOLDED CLUTCH FACINGS MANUFACTURING OPERATIONS
                              21

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                    I TREATED FABRIC |
                        SLITTING
                        PREFORM
                        WINDING
  COOLING WATER     STEAM
                         PRESS
                     | BAKING OVEN |
FINISHING


INSPECTION
PACKAGING
STORAGE
                     COOLING WATER
                     CONDENSATE
                                             DUST
                       CONSUMER
FIGURE 5-WOVEN CLUTCH FACINGS MANUFACTURING OPERATIONS
                           22

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woven brake linings ranges from 40 to 60 percent asbestos, 10 to  20
percent cotton, 20 to UO percent wire, and 5 to 20 percent binder.

Figure  5  illustrates the manufacture of woven clutch facings.  The
treated fabric is cut into tape-width strips by a slitting  machine.
The  strips are wound around a mandrel to form a roll of the fabric.
The roll is pressed in a steam-heated press and  then  baked  in  an
oven  to cure the resin in the clutch facing.  Following curing, the
clutch facing is finished, inspected, and packaged.
Water does not mix with the ingredients of friction materials and is
not used in the manufacturing processes.  Haste waters are generated
in a few friction materials plants in  solvent  recovery  operations
and  in wet dust collection equipment used to control the quality of
the air from the finishing areas.  Most plants in this industry  use
dry dust collection equipment.

Operating Schedule

Friction  materials  plants  typically operate two or three shifts a
day on a five- or six-day per week schedule.

GASKETS, PACKING, AND SEALING DEVICES

The gaskets, packings, and sealing devices  group  includes  a  wide
variety of products, many of which contain metallic components.  The
asbestos  content  of  these products varies widely from one type to
another.  The typical plant making these products  is  a  fabricator
rather  than a manufacturer, purchasing materials that are ready for
cutting and assembly.  There are many specialized hand operations in
some plants in this category.  Gaskets and packings may be made from
asbestos paper, felt, and millboard; yarn, cloth,  wick,  and  rope;
and  sheet  gasket  material.   The  waste  waters  associated  with
asbestos paper, felt, and millboard were  covered  in  the  Phase  I
document.

The variety of materials and forms comprising this group of products
is  so  wide  that  it  precludes  general  descriptions  of typical
manufacturing processes.

Water Usage

In this study, no plant was found that used water in the manufacture
of gaskets, packing, and/or sealing  devices.   The  manufacture  of
sheet  gasket  material  may  involve  cooling  and solvent recovery
operations that produce waste waters.  Among the plants contacted in
this study, only one was found that generated  waste  water  from  a
sheet  gasket  production  facility,  and  this was from the solvent
recovery operations.

In summary, the fabrication of  asbestos-containing  gaskets,  pack-
ings,  and sealing devices does not normally result in process waste
                              23

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waters, although the manufacture of some of the  raw  materials  may
result in process-associated wastes.

Operating Schedule

Sealant  manufacturing plants normally operate one or two shifts for
five days a week.

CURRENT STATUS OF THE INDUSTRY

There has long been concern about the industrial hygiene aspects  of
the  dust and fiber emitted to the air in the asbestos manufacturing
industry.  Asbestos was among the first materials to be  declared  a
hazardous  air  pollutant under the Clean Air Act Amendment of 1970.
Some of the waste waters generated in this portion of  the  asbestos
industry  result  in  part  from measures to eliminate or reduce the
hazards.  Asbestos textiles are coated to  make  them  safer  during
fabrication and when used by the consumer.

The  most significant effect of the recently increased concern about
asbestos is  the  trend  toward  substitution  of  other  materials,
especially  among  users  of textile products.  New uses and markets
for asbestos will be more difficult to develop in the future  unless
means  are  found  to  reduce  the  potential  hazards.  Despite the
declines in some  areas,  however,  the  unique  characteristics  of
asbestos  plus new developments within the industry make the outlook
for future growth favorable in the textile, friction materials,  and
sealant manufacturing segments of the industry.
                               24

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                             SECTION IV

                      INDUSTRY CATEGORIZATION
INTRODUCTION

In  developing  effluent  limitations  guidelines  and  standards of
performance for new sources for a given  industry,  a  judgment  was
made  by  EPA  as  to  whether  different  effluent  limitations and
standards were appropriate for different  subcategories  within  the
industry.   In  the  final  analysis,  the  underlying  distinctions
between the various subcategories are based on the  methods  of  air
pollution  control,  solvents  recovery  and  resulting  waste water
characteristics.  The factors considered in determining whether such
subcategories  were  justified  for  this  part  of   the   asbestos
manufacturing industry were:

     1.    Product,
     2.    Raw Materials,
     3.    Manufacturing Process,
     4.    Characteristics and Treatability of Waste Waters,
     5.    Air Pollution Control Equipment,
     6.    Plant Size,
     7.    Plant Age, and
     8.    Geographic Location.

Based  on review of the literature, plant visits and interviews, and
consultation with industry representatives, the above  factors  were
evaluated  and  it  was  concluded  that  this  part of the asbestos
manufacturing industry (Phase II) should be divided into  four  sub-
categories:

     1.    Coating, or finishing, of asbestos textiles,
     2.    Solvent recovery operations,
     3.    Vapor absorption equipment  (fume scrubber) , and
     U.    Wet particulate  (dust) collectors.

In  addition to the above, it should be noted that there is a poten-
tial source of waste water in this part of  the  asbestos  industry;
namely,  the  manufacture of yarn by the dispersion process.  At the
time of this study, two plants in the country  have  pilot-plant  or
experimental manufacturing operations using this process.  The level
of  production  is extremely limited today, but it could increase in
the future.  While these operations are too limited to be considered
in this study, it was determined that, even with in-plant  controls,
the  associated waste waters can be expected to contain both organic
and inorganic pollutants.   If  this  process  becomes  operational,
separate  effluent  limitations  guidelines  might  be developed, if
required.

FACTORS CONSIDERED
                               25

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Product

The products included in this segment of the asbestos industry cover
a wide range of manufactured items and materials, many of which  are
related  only  in  that  they contain asbestos fibers.  Textiles are
manufactured into many special-use articles and are  also  converted
into  friction  materials  and sealing devices.  Some plants consume
all of their textile  production  in  manufacturing  brake  linings,
clutch  facings,  and  other friction products.  Non-fabric friction
materials and gaskets are also produced in large quantities, in some
cases, in the same plants manufacturing textile-based  counterparts.
In sum, categorization by product would tend to confuse, rather than
clarify, understanding and analysis of the industry.

Raw Materials

Many  raw materials are used in this industry and most have a marked
influence on the nature and treatability of  the  wastes.   However,
because  of  the small number of waste water sources, categorization
in terms of raw materials is not useful.  In other words, where  the
raw  materials  result in distinctive differences in the wastes, the
individual plants are not  similar.   Categorization  based  on  raw
materials  would result in several categories with only one plant in
each.

Manufacturing Process

Within this industry, there are two  fully  developed  manufacturing
processes that may result in the generation of waste waters.  One is
the coating of asbestos textiles to be made into industrial belting,
friction  materials, special articles, etc.  Waste waters may result
from the cleaning of  the  preparation  and  application  equipment,
dumps,   and   from   the   housekeeping   operations.    The  other
manufacturing operation that may  result  in  waste  waters  is  the
recovery  of  solvents  from drying oven exhaust air using activated
carbon.  The solvents are removed from the exhaust air by absorption
on the carbon, recovered from the carbon  by  steam  stripping,  and
then decanted or distilled from the condensate.  The resulting waste
water  may  contain  residual  solvent or other materials evaporated
from the product during drying.  Solvent recovery is not unique with
the asbestos textile industry, but is used to a  limited  degree  in
the  manufacture  of  friction  materials  and sheet gasketing.  The
presence  or  absence  of  this  operation  provides  a  basis   for
categorizing plants in the industry.

Characteristics and Treatability of Waste Waters

The  term  "characteristics" is used here to include both the inten-
sive and  extensive  properties  of  the  waste  waters,  i.e.,  the
chemical  and physical parameters plus the volumes of wastes and the
rates of discharge.  Most of the significant waste water  pollutants
from  this  industry  fall  broadly  into  two categories; dissolved
organic materials  (COD)  from the textile  coating  and  the  solvent
recovery  and vapor absorption operations; and suspended solids from
                               26

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the wet particulate collectors.  While the  organic  materials  have
some  similarities,  they  vary  in  their  amenability  to  various
treatment technologies.  The rates of discharge  are  so  dissimilar
that   different  control  measures  and  effluent  limitations  are
indicated.  In one case  (textile coating), a very small quantity  of
concentrated  waste  is  discharged irregularly.  In the second case
(solvent recovery), a steady flow of moderate  volume  results.   In
the  third   (vapor  absorption),  a larger volume of dilute waste is
discharged, but only intermittently.  The different  characteristics
make  different control and treatment technologies appropriate.  The
quality of the discharge from the dust collectors  varies  with  the
type  of equipment and the degree of water recirculation, as well as
the particulate load in the air stream.

While categorization based on the  waste  water  characteristics  is
useful,  this factor cannot be fully utilized.  As noted in the dis-
cussion on raw materials above, there is  only  a  small  number  of
sources in this industry and each produces an effluent that is truly
unique.  There is little benefit in classifying plants if the result
is only one plant in each category.

Air Pollution Control Equipment

In  most  of  the plants in this industry, particulate emissions are
controlled by baghouses or other dry devices.  In a few plants,  wet
dust collectors are used and a waste water results.

Where  small  quantities  of  solvents  are used, they may be wasted
rather than    recovered.  Among the techniques used for controlling
the emissions of vaporized materials is absorption in  water,  which
may result in a waste water effluent.

The  type  of  air pollution control equipment used in this industry
provides a useful basis  for categorization.

Plant Size

The plants in this industry that generate waste  waters  range  from
the  small   (50  to  70  employees)  to  the  medium  in  size  (1000
employees) .  As pointed out previously, the characteristics  of  the
waste waters are independent of the level of production, and some of
the  small  plants generate more waste than larger ones.  Plant size
has no significant effect on the  quality  or  treatability  of  the
waste waters.

Plant Age

The  ages  of  the plants in this part of the asbestos manufacturing
industry range from a few to 50 or more  years.   The  manufacturing
equipment  is  normally  younger than the building housing the plant.
Plant age, like plant size, could not be correlated with operational
efficiency, quality of housekeeping, or waste water characteristics.
Plant age is not an appropriate  basis  for  categorization  of  the
industry.
                                27

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Geographic Location

As  presented  in Section III, almost all of the plants in this part
of the asbestos manufacturing  industry  are  located  east  of  the
Mississippi  River.   A  few  plants  are  located in California and
Texas.   The  basic  manufacturing  processes   used   are   similar
throughout  the industry, and geographic location does not influence
the processes or the waste water characteristics.  Location does not
provide a basis for categorizing this industry.
                                  28

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                             SECTION V

                WATER DSE AND WASTE CHARACTERIZATION
Other than for steam generation and noncontact cooling, water is not
widely used in the manufacturing  processes  in  this  part  of  the
asbestos  industry.   In  a  few individual plants, water is used in
process-related operations and waste waters are discharged from  the
plant  property.   The  water  usage  and  waste characteristics are
described in detail in this section.

It should be noted that there are manufacturing processes  that  are
termed  "wet"  within this industry, but are actually dry in that no
waste water is generated.  Examples include the "wet mixed"  methods
for  manufacturing  molded  friction products*  Solvents are used to
make the mix more pliable during the rolling,  extruding,  or  other
molding  operation.   Another example is the addition of moisture to
asbestos yarn during weaving to produce a tighter fabric.   This  is
accomplished  by  mist  sprays or by running the yarn through water.
In the textile mills that "wet" weave, no excess water is used, and,
in fact, there are no floor drains in the weaving areas.

For each of the subcategories in  this  industry,  the  waste  water
characteristics are described below.  Because only a small number of
plants  generate  process-related waste waters, the data base is not
large.  Each plant is unique and the information presented  here  is
based on all data that are available about these waste waters.

TEXTILE COATING

Waste  waters  result  from  the coating of asbestos textiles at two
plants in the country at the present time.  Where  textile  products
are  coated  (impregnated)  in the manufacture of friction materials
and sealing devices, water is not used and no waste  water  is  gen-
erated.

Water Usage

The volume of waste generated in the coating of asbestos textiles is
estimated  to be no more than 750 liters  (200 gallons) per day.  The
coating of asbestos textiles is not presently a full-time  operation
at  either  of  the  two  plants.   The waste results from dumps and
cleanup at the end of a run, the amount of which is dependent on the
number and length of the runs.

Waste Characteristics

Coated asbestos textiles are used in a variety  of  products;  e.g.,
pipe  lagging,  paper machine felts, ironing board covers, etc.  One
of the purposes of coating is to encase the fibers, thereby reducing
the potential health hazards in  fabricating  and  using  the  final
products.   The coating has additional functions and its composition
is normally specified by the fabricator.  Consequently, the chemical
                              29

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constituents of the coating material, and subsequently those of  the
waste  water,  vary  at each of the plants.  The ingredients include
resins, elastomers, pigments, solvents, and fillers.  The wastes are
high in COD and suspended and dissolved solids.  In addition to  the
organic  components,  trace  quantities of heavy metals, phosphates,
and fluorides may be present.

At both of the plants that coat asbestos textiles, the waste  waters
are  discharged to municipal sewerage systems, one with pretreatment
and the other without,  other than knowing  the  quantities  of  raw
materials used, neither plant has information on the characteristics
of its waste waters.

SOLVENT RECOVERY

waste   waters  are  known  to  be  generated  in  solvent  recovery
operations at two plants in this industry,

Water Usage

The quantity of waste water from solvent recovery operations varies,
depending upon the type and the size of the  equipment.   A  typical
value  is  38,000 liters (10,000 gallons) per day for this industry.
The discharge is normally steady and, although it is a  function  of
the  activated carbon regeneration process, it can be related to the
level of production in the plant,

Waste Characteristics

The waste waters from solvent recovery units  may  contain  residual
solvent  and/or  other  organic materials that are either evaporated
from the product or generated during the recovery  operations.   The
suspended solids level is normally very low, and the waste water may
have  an  elevated temperature.  Typical waste water characteristics
from one solvent recovery operation are as follows:
                    BOD  (5-day)
                    COD
                    Suspended Solids
1125 mg/1
1930 mg/1
   0 mg/1
The waste waters from this plant are discharged  with  the  sanitary
wastes  to the municipal sewerage system.  The waste waters from the
other known plant that recovers solvent  are  combined  with  larger
volumes of industrial waste waters  (covered in the Phase I report on
the asbestos industry) for treatment prior to discharge to a surface
water.   The BOD of the combined, treated effluent from the plant is
less than 20 mg/1.  There are plans  at  this  plant  to  completely
recycle all process-related waste waters.

VAPOR ABSORPTION

At  one  of the two asbestos textile coating plants, a vapor absorp-
tion unit is used to scrub solvent from the drying oven exhaust.
                                30

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Water Usage

The fume scrubber at the single known installation in this  industry
is  operated once or twice a month for a two-shift period each time.
The water usage rate is about 3.8 liters per second  (60 gallons  per
minute)  for  a  total  volume per period of approximately 220 cubic
meters (58,000 gallons).  The scrubber comprises four chambers,  and
water is recirculated within the unit.

Waste Characteristics

The vapor absorption unit is charged with 22.7 kilograms  (50 pounds)
of  sodium  hydroxide in solution for each period of operation.  The
resulting waste water, therefore, contains  this  caustic  plus  the
absorbed  solvent.   The  waste  is pretreated in a two-stage lagoon
prior to discharge to the municipal sewerage system.  There  are  no
records available that describe the characteristics of the raw waste
water  resulting  from  the vapor absorption unit.  It should have a
somewhat elevated pH value and a significant COD content,

WET DUST COLLECTION

At this time, there are known to be four  friction  materials  manu-
facturing  plants  that discharge waste waters from wet dust collec-
tion equipment.  Based on the results of this study, it is estimated
that the total number of such plants in the country is no more  than
eight.   At  all of the known plants, the waste waters are clarified
before discharge to surface waters.  At one of the four,  the  wastes
are  combined  with  metal-finishing  wastes  in a physical-chemical
treatment facility,

Water Usage

The water use rate in wet dust collectors varies from  0.06  to  1.3
liters per second per cubic meter per minute of air scrubbed  (0.5 to
10 gpm per 1000 scfm) ,  The plant air systems that are served by wet
scrubbers  that discharge waste waters from the plant property range
from 280 to 7000 cubic meters per minute  (10,000 to  250,000  scfm),
resulting  in  waste  water  discharges  of from 190 to 21,000 cubic
meters   (50,000  to  750,000  gallons)  per  day.   The   units  that
incorporate  recirculation discharge a settled slurry.  In addition,
the contents of the settling tank are dumped, usually once per week.
As noted above, the wastes are discharged to a  settling  lagoon  in
all known cases.

Waste Characteristics

The  waste  waters  from the wet dust collectors are slurries of the
dust emanating from the grinding and  drilling  operations  used  in
finishing  friction  products.   The principal parameter  for charac-
terizing the wastes is suspended solids.  Because friction materials
are specifically designed to shed water, it  is  unlikely that  the
dust is solubilized to any measurable degree.  The COD test provides
                                 31

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a convenient means of detecting and monitoring this phenomenon if it
is suspected.

The  quantity  of  friction  material  that is lost in the finishing
operations may be as much as 30 percent.  It  is  significant  that,
even with the relatively high price of asbestos fiber, this material
is  not  recovered  for reuse.  Once the resin has set up, it is not
regarded as economical to break it down to salvage the fiber.

DISPERSION PROCESS

As noted in Section IV, there are two known experimental pilot-plant
operations in the country where asbestos yarn is being  produced  in
very  limited  quantities  by  the  dispersion process.  While these
operations are too limited for inclusion as  subcategories  in  this
industry,  it  is  deemed appropriate to include what information is
available about the waste waters for use when  and  if  this  method
becomes operational and is more widely used.

Water Usage

The water use rate is in the order of 20 to 60 cubic meters  (5000 to
15,000  gallons)  per  day in these pilot-plant operations.  Because
these facilities are very small, water  usage  based  on  production
cannot be realistically extrapolated to plant-scale operations.  The
water  passes through save-alls in the process and there is at least
a  potential  for  recycle  of  water.    Because   of   the   waste
characteristics, it is not feasible at this time to completely reuse
all water in this process.

Waste Character!stics

The  waste  waters  from the two plants that are developing the dis-
persion process differ significantly, in part because the  processes
are  not  exactly  the  same.   It  is possible that the wastes will
change significantly as the processes  are  refined  and  developed.
Some  of  the  parameters that should be measured are total and sus-
pended solids; COD and BOD;  hexane  extractables;  MBAS;  zinc  and
other metals; and the plant nutrients, nitrogen and phosphorus.

PLANT DESCRIPTIONS

Forty-five  manufacturing plants representing 30 different companies
or corporations were contacted directly in this study.   Information
was  collected  from  six additional plants through a questionnaire.
This coverage is believed to include better than 80 percent  of  all
the  plants  that  are  properly  within the two SIC classes, and it
represents an accurate picture  of  this  segment  of  the  asbestos
manufacturing  industry.   A  total  of  ten  plants were found that
discharge process-related waste waters.  These plants are  described
individually in Table 2.

In  reviewing  Table  2, it should be noted that the discharges from
the two plants using the dispersion process for making asbestos yarn
                                32

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are included, even though these operations are experimental and  not
yet  classified as subcategories of this industry.  Of the remaining
eleven waste  streams,  seven  result  from  air  pollution  control
equipment   and   only   four   from  manufacturing  and  associated
operations.
                                33

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                                      TABLE 2

                 GENERAL DESCRIPTION OF KNOWN WASTE WATER SOURCES
                     ASBESTOS MAMJFACTURING PLANTS  -  PHASE  II

Plant
A
B
it
C
D
Product
Textiles
Textiles
n
Textiles
Textiles
Waste Water Source
Coating
Coating
Fume Scrubber
Dispersion Process
Dispersion Process
Treatment Provided
None
Two-Stage Lagoon
it ii
Filtration
None/Lagoon
Effluent Discharged To
Municipal Sewer
Municipal Sewer
n tt
Municipal Sewer
Municipal Sewer/
Sheet Gasketing

Friction Materials

Friction Materials

Friction Materials

Friction Materials
Solvent Recovery

Dust Scrubber

Dust Scrubber

Dust Scrubber

Dust Scrubber
Lagoon

Lagoon

Sedimentation

Two-Stage Lagoon

Lagoon
 Surface Water
Surface Water

No Discharge

Surface Water

Surface Water

Surface Water

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                                  TABLE 2 (cent)

                 GENERAL DESCRIPTION OF KNOWN WASTE WATER SOURCES
                     ASBESTOS MANUFACTURING PLANTS -  PHASE  II

Plant
I
Product
Friction Materials
M ' II
Waste Water Source
Solvent Recovery
Dust Scrubber
Treatment Provided
None
Lagoon
Effluent Discharged To
Municipal Sewer
No Discharge
Friction Materials
Dust Scrubber
Chemical Precipi-
 tation with Other
 Wastes
Surface Water

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                             SECTION VI

                 SELECTION OF POLLUTANT PARAMETERS


The chemical, physical, and biological parameters  that  define  the
pollutant  constituents  in  process-related  waste waters from this
part of the asbestos manufacturing industry are the following:

           COD  (or TOC)
           Suspended Solids
           PH
           Temperature
           BOD
           Dissolved Solids
           Heavy Metals
           Phenols
           Nitrogen
           Phosphorus

The first two listed parameters are the most significant and  useful
in  characterizing  the  wastes  from this industry.  The others are
included because they  may  also  be  significant  in  one  or  more
subcategories   or  because they supplement and support the first two
listed parameters.   The  rationale  for  selection  of  the  listed
parameters is given below.

Pollutants  in  non-process waste waters, such as noncontact cooling
water, boiler blowdown, steam  condensate,  and  wastes  from  water
sanitary facilities, are not included in this document.

MAJOR POLLUTANTS

The  reasons  for  including the above listed parameters are briefly
presented below.  The reader is referred to other  sources  (Section
XIII) for detailed descriptions of the parameters and procedures for
measuring them.

Chemical Oxygen Demand

Chemical  Oxygen  Demand   (COD) provides a measure of the equivalent
oxygen required to chemically  oxidize  the  organic  and  inorganic
material  present  in  a  waste water.  In this part of the asbestos
industry, the COD serves as the primary parameter for measuring  the
organic materials in the raw and treated wastes, including solvents,
resins,  elastomers, and fillers.  COD values in excess of 1000 mg/1
occur in the wastes from the textile coating  and  solvent  recovery
subcategories.   In order to be most meaningful when used to monitor
solubilization  in wet dust collection subcategory, the sample should
be filtered prior to COD analysis.

If desired, the Total Organic Carbon  (TOC)  parameter  may  be  sub-
stituted  for COD, with the appropriate adjustments in values.  This
                               37

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instrumental  technique  yields   results   in   terms   of   carbon
concentrations, rather than oxygen.

Suspended Solids

The  suspended  solids parameter is especially useful with the waste
water from the wet dust collectors and textile  coating  subcategor-
ies.   The  suspended solids level in the raw wastes may range up to
the very high values, exceeding  10,000  mg/1,  depending  upon  the
operational mode of the equipment, i.e., the level of dilution used.
The  suspended  solids in the waste waters from the solvent recovery
and vapor absorption  subcategories  should  be  negligible  if  the
equipment is properly operated.

Suspended  solids include both organic and inorganic materials.  The
inorganic components include sand,  silt,  and  clay.   The  organic
fraction  includes  such  materials  as grease, oil, tar, animal and
vegetable fats, various fibers, sawdust, hair, and various materials
from sewers.   These  solids  may  settle  out  rapidly  and  bottom
deposits  are  often a mixture of both organic and inorganic solids.
They adversely affect fisheries by covering the bottom of the stream
or lake with a blanket  of  material  that  destroys  the  fish-food
bottom  fauna  or  the spawning ground.of fish.  Deposits containing
organic materials may deplete bottom  oxygen  supplies  and  produce
hydrogen sulfide, carbon dioxide, methane, and other noxious gases.

In  raw  water sources for domestic use, state and regional agencies
generally specify that suspended solids  in  streams  shall  not  be
present  in  sufficient  concentration  to  be  objectionable  or to
interfere with normal  treatment  processes.   Suspended  solids  in
water  may  interfere  with  many  industrial  processes,  and cause
foaming in boilers, or encrustations on equipment exposed to  water,
especially   as   the   temperature  rises.   Suspended  solids  are
undesirable  in  water  for  textile  industries;  paper  and  pulp;
beverages;  dairy  products; laundries; dyeing; photography; cooling
systems; and power plants.  Suspended  particles  also  serve  as  a
transport  mechanism  for  pesticides and other substances which are
readily sorbed into or onto clay particles.

Solids may be suspended in water for a time, and then settle to  the
bed  of the stream or lake.  These settleable solids discharged with
man's wastes  may  be  inert,  slowly  biodegradable  materials,  or
rapidly decomposable substances*  While in suspension, they increase
the  turbidity of the water, reduce light penetration and impair the
photosynthetic activity of aquatic plants.

Solids in  suspension  are  aesthetically  displeasing.   When  they
settle  to  form sludge deposits on the stream or lake bed, they are
often much more damaging to the life in water, and they  retain  the
capacity  to  displease  the  senses.   Solids,  when transformed to
sludge deposits, may do a  variety  of  damaging  things,  including
blanketing  the stream or lake bed and thereby destroying the living
spaces for those benthic organisms that would otherwise  occupy  the
habitat.   When  of  an  organic  and therefore decomposable nature,.
                                 38

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solids use a portion or all of the dissolved oxygen available in the
area.  Organic materials also serve  as  a  seemingly  inexhaustible
food source for sludgeworms and associated organisms.

Turbidity is principally a measure of the light absorbing properties
of  suspended  solids.  It is frequently used as a substitute method
of  quickly  estimating  the  total  suspended   solids   when   the
concentration is relatively low.


OTHER POLLUTANTS

pH, Acidity,and Alkalinity

Normally, waste waters in the four subcategories fall in the neutral
pH  range,  i.e., 6 to 9.  In the vapor absorption subcategory, how-
ever, alkali is used in the scrub water and the pH may be  above  9.
Because this parameter is readily measurable and because it provides
an  indication  of  changes  or upsets, it should be included in the
list of regularly monitored parameters.

Acidity and alkalinity are reciprocal terms.  Acidity is produced by
substances that yield hydrogen ions upon hydrolysis  and  alkalinity
is  produced  by  substances  that  yield  hydroxyl ions.  The terms
"total acidity" and "total alkalinity" are often used to express the
buffering capacity of a solution.   Acidity  in  natural  waters  is
caused  by  carbon dioxide, mineral acids, weakly dissociated acids,
and the salts of strong acids and weak bases.  Alkalinity is  caused
by strong bases and the salts of strong alkalies and weak acids.

The  term  pH  is  a  logarithmic expression of the concentration of
hydrogen ions.  At  a  pH  of  7,  the  hydrogen  and  hydroxyl  ion
concentrations  are  essentially  equal  and  the  water is neutral.
Lower pH  values  indicate  acidity  while  higher  values  indicate
alkalinity.   The  relationship between pH and acidity or alkalinity
is not necessarily linear or direct.

Waters with a pH below 6.0 are corrosive to water works  structures,
distribution lines, and household plumbing fixtures and can thus add
such  constituents  to drinking water as iron, copper, zinc, cadmium,
and lead.  The hydrogen ion concentration can affect the "taste"  of
the  water.   At  a  low  pH  water tastes "sour".  The bactericidal
effect of chlorine is weakened  as  the  pH  increases,  and  it  is
advantageous  to  keep  the pH close to 7.  This is very significant
for providing safe drinking water.

Extremes of pH or rapid pH changes can exert  stress  conditions  or
kill aquatic life outright.  Dead fish, associated algal blooms, and
foul  stenches  are   esthetic  liabilities  of  any waterway.  Even
moderate  changes  from  "acceptable"  criteria  limits  of  pH  are
deleterious  to some species.  The relative toxicity to aquatic life
of  many  materials  is  increased  by  changes  in  the  water  pH*
Metalocyanide  complexes  can  increase  a thousand-fold in toxicity
with a drop of 1.5 pH units.   The  availability  of  many  nutrient
                                39

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substances  varies with the alkalinity and acidity.  Ammonia is more
lethal with a higher pH.

The lacrimal fluid of the human eye has a pH  of  approximately  7.0
and  a  deviation  of  0.1  pH  unit from the norm may result in eye
irritation for  the  swimmer.   Appreciable  irritation  will  cause
severe pain.

Temperature

The  waste  waters associated with the solvent recovery category may
be hot, with temperatures as high as 80°C  if distillation is used to
separate the solvent from the  condensed  steam.   Because  elevated
water   temperatures   influence   the   efficiency   of   treatment
technologies and are harmful to aquatic life, the temperature of the
raw wastes should be monitored.

Temperature is one of  the  most  important  and  influential  water
quality  characteristics.  Temperature determines those species that
may be present; it activates the hatching of young, regulates  their
activity, and stimulates or suppresses their growth and development;
it  attracts, and may kill when the water becomes too hot or becomes
chilled   too   suddenly.    Colder   water   generally   suppresses
development.  Warmer water generally accelerates activity and may be
a  primary cause of aquatic plant nuisances when other environmental
factors are suitable.

Temperature is a prime regulator of  natural  processes  within  the
water  environment.  It governs physiological functions in organisms
and, acting directly or indirectly in combination with  other  water
quality  constituents,  it  affects  aquatic  life with each change.
These effects include chemical reaction rates, enzymatic  functions,
molecular  movements,  and  molecular  exchanges  between  membranes
within and between the physiological systems and the  organs  of  an
animal.

Chemical reaction rates vary with temperature and generally increase
as  the  temperature is increased.  The solubility of gases in water
varies with temperature.  Dissolved oxygen is decreased by the decay
or decomposition of dissolved organic substances and the decay  rate
increases  as  the  temperature  of  the  water increases reaching a
maximum at about 30°C  (86°F).  The temperature of stream water, even
during  summer,  is  below  the  optimum  for   pollution-associated
bacteria.   Increasing the water temperature increases the bacterial
multiplication rate when the environment is favorable and  the  food
supply is abundant.

Reproduction  cycles  may  be  changed  significantly  by  increased
temperature because  this  function  takes  place  under  restricted
temperature   ranges.    Spawning  may  not  occur  at  all  because
temperatures are too high.  Thus, a fish population may exist  in  a
heated   area  only  by  continued  immigration.   Disregarding  the
decreased reproductive potential, water temperatures need not  reach
lethal  levels  to  decimate  a  species.   Temperatures  that favor
                                40

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competitors, predators, parasites, and disease can destroy a species
at levels far below those that are lethal.

Fish food organisms are altered severely when temperatures  approach
or   exceed   90°F,    Predominant  algal  species  change,  primary
production is decreased, and  bottom  associated  organisms  may  be
depleted   or  altered  drastically  in  numbers  and  distribution.
Increased water temperatures may cause aquatic plant nuisances  when
other environmental factors are favorable,

Synergistic  actions  of  pollutants are more severe at higher water
temperatures.  Given amounts of domestic  sewage,  refinery  wastes,
oils,  tars,  insecticides, detergents, and fertilizers more rapidly
deplete oxygen in water at higher temperatures, and  the  respective
toxicities are likewise increased.

When  water temperatures increase, the predominant algal species may
change from diatoms to green algae, and finally at high temperatures
to blue-green algae, because of species  temperature  preferentials.
Blue-green  algae  can  cause serious odor problems.  The number and
distribution of benthic organisms decreases  as  water  temperatures
increase  above  90°F, which is close to the tolerance limit for the
population.  This could seriously affect certain fish that depend on
benthic organisms as a food source.

The cost of fish being attracted to heated water  in  winter  months
may  be  considerable,  due to fish mortalities that may result when
the fish return to the cooler water.

Rising temperatures stimulate the decomposition of sludge, formation
of sludge gas, multiplication  of  saprophytic  bacteria  and  fungi
{particularly   in   the   presence  of  organic  wastes),  and  the
consumption of oxygen by putrefactive processes, thus affecting  the
esthetic value of a watercourse.

In  general,  marine  water temperatures do not change as rapidly or
range as widely as  those  of  freshwaters.   Marine  and  estuarine
fishes,  therefore,  are  less  tolerant  of  temperature variation.
Although this limited tolerance is greater in estuarine than in open
water marine species, temperature  changes  are  more  important  to
those  fishes  in  estuaries  and  bays than to those in open marine
areas, because of the nursery and  replenishment  functions  of  the
estuary  that  can  be  adversely  affected  by  extreme temperature
changes.

Biochemical Oxygen Demand  (BOD)

The Biochemical Oxygen Demand  (BOD) technique provides  a  means  of
estimating  the  usefulness  of  biological  treatment processes for
controlling the discharge of organic pollutants.  It  also  provides
an  indication  of the effect of the waste on the oxygen budget in  a
receiving water.  For this part of the asbestos  industry,  the  BOD
parameter extends the COD results and is useful when biotreatment is
under  consideration.   Some of the organic materials present in the
                               41

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waste waters are not readily biodegradable, however,
respond in the test.
and  will  not
Biochemical oxygen demand  (BOD) is a measure of the oxygen consuming
capabilities  of  organic  matter.  The BOD does not in itself cause
direct harm to a water system, but it does exert an indirect  effect
by  depressing  the  oxygen  content of the water-  Sewage and other
organic effluents during their processes of  decomposition  exert  a
BOD,  which  can  have  a  catastrophic  effect  on the ecosystem by
depleting the oxygen  supply.   Conditions  are  reached  frequently
where  all  of  the  oxygen is used and the continuing decay process
causes the production of noxious gases such as hydrogen sulfide  and
methane.    Water   with  a  high  BOD  indicates  the  presence  of
decomposing organic matter and subsequent high bacterial counts that
degrade its quality and potential uses.

Dissolved oxygen (DO)  is  a  water  quality  constituent  that,  in
appropriate  concentrations, is essential not only to keep organisms
living but also to sustain  species  reproduction,  vigor,  and  the
development  of populations*  Organisms undergo stress at reduced DO
concentrations that make them less competitive and able  to  sustain
their  species within the aquatic environment.  For example, reduced
DO concentrations have been shown to interfere with fish  population
through delayed hatching of eggs, reduced size and vigor of embryos,
production   of   deformities   in  young,  interference  with  food
digestion, acceleration of blood clotting,  decreased  tolerance  to
certain  toxicants,  reduced  food  efficiency  and growth rate, and
reduced maximum sustained swimming speed.  Fish food  organisms  are
likewise affected adversely in conditions with suppressed DO.  Since
all  aerobic  aquatic organisms need a certain amount of oxygen, the
consequences of total lack of dissolved oxygen due to a high BOD can
kill all inhabitants of the affected area.

If a high BOD is present,  the  quality  of  the  water  is  usually
visually degraded by the presence of decomposing materials and algae
blooms  due  to  the  uptake  of  degraded  materials  that form the
foodstuffs of the algal populations.

Dissolved Solids

The dissolved solids content, when coupled with the suspended solids
value, provides a measure of the total quantity of foreign  material
present  in  a  waste  water.  With the wastes in this industry, the
dissolved solids parameter is useful in corroborating  the  accuracy
of  the  COD  results.   Since  the  analytical  procedure  involves
evaporation, some organic materials, e.g., certain solvents, may not
be detected.

In natural waters the dissolved solids consist mainly of carbonates,
chlorides, sulfates, phosphates, and possibly nitrates  of  calcium,
magnesium, sodium, and potassium, with traces of iron, manganese and
other substances.
                               42

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Many  communities  in  the  United states and in other countries use
water supplies containing 2000 to 4000 mg/1 of dissolved salts, when
no better water is available.  Such waters are  not  palatable,  may
not  quench  thirst,  and  may  have a laxative action on new users.
Waters containing more than 1000 mg/1 of total salts  are  generally
considered unfit for human use, although in hot climates such higher
salt  concentrations  can  be tolerated whereas they could not be in
temperate  climates.   Waters  containing  5000  mg/1  or  more  are
reported  to  be bitter and act as bladder and intestinal irritants.
It  is  generally  agreed  that  the  salt  concentration  of  good,
palatable water should not exceed 500 mg/1.

Limiting concentrations of dissolved solids for fresh-water fish may
range  from  5,000  to  10,000  mg/1, according to species and prior
acclimatization.  Some fish are adapted to  living  in  more  saline
waters,  and  a  few species of fresh-water forms have been found in
natural waters with a salt concentration of 15,000 to  20,000  mg/1.
Fish  can  slowly become acclimatized to higher salinities, but fish
in waters of low salinity cannot survive  sudden  exposure  to  high
salinities,  such  as  those  resulting  from discharges of oil-well
brines.  Dissolved solids may influence the toxicity of heavy metals
and organic compounds to fish  and  other  aquatic  life,  primarily
because of the antagonistic effect of hardness on metals.

Waters  with  total  dissolved  solids over 500 mg/1 have decreasing
utility as irrigation water.  At 5,000 mg/1 water has little  or  no
value for irrigation.

Dissolved  solids  in industrial waters can cause foaming in boilers
and cause interference  with  cleanliness,  color,  or  taste  of  many
finished  products.   High contents of dissolved solids also tend to
accelerate corrosion.

Specific conductance is a measure of the capacity of water to convey
an  electric  current.   This  property  is  related  to  the  total
concentration  of ionized substances in water and water temperature.
This property is frequently used as a substitute method  of  quickly
estimating the dissolved solids concentration.

Heavy Metals

Some  of  the additives used in the textile coating subcategory con-
tain heavy metals, generally in the form of inert particulates.  The
raw wastes should be monitored for any metals that are suspected  to
be  present  in  soluble  forms  in  the  raw materials to ascertain
possible need for controls,

Phenols

The waste waters from one solvent recovery operation  are  known  to
contain  about 12 mg/1 of phenol.  This material is derived from the
material  used  to  impregnate  woven  friction  materials  and   is
evaporated  from  the product in the drying oven.  Phenols, however,
are only a very minor portion of the  total  organic  materials  and
                               43

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should  not  require  specific controls and limitations beyond those
applicable to COD.

Phenols and phenolic wastes are derived from  petroleum,  coke,  and
chemical  industries;  wood  distillation;  and  domestic and animal
wastes.  Many phenolic compounds are more toxic  than  pure  phenol;
their  toxicity  varies  with the combinations and general nature of
total wastes.  The effect  of  combinations  of  different  phenolic
compounds is cumulative.

Phenols  and  phenolic  compounds  are  both acutely and chronically
toxic to  fish  and  other  aquatic  animals.   Also,  chlorophenols
produce  an  unpleasant  taste  in  fish  flesh  that destroys their
recreational and commercial value.

It is necessary to limit phenolic compounds in raw  water  used  for
drinking  water  supplies, as conventional treatment methods used by
water supply facilities do not remove  phenols.   The  ingestion  of
concentrated  solutions of phenols will result in severe pain, renal
irritation, shock and possibly death.

Phenols also reduce the utility  of  water  for  certain  industrial
uses,  notably  food  and  beverage  processing,  where  it  creates
unpleasant tastes and odors in the product.

Nitrogen

The nitrogen levels in  the  waste  waters  from  the  subcategories
covered  here  are  not  known  to be significantly high.  Nitrogen-
containing compounds are used as additives in  the  textile  coating
formulations.   Addition  of  nitrogen may be required for effective
biological treatment.

Phosphorus

Like nitrogen, there are no reliable data as to phosphorus levels in
the wastes in this  part  of  the  asbestos  industry.   Phosphorus-
containing  materials  are  used  in  small  amounts  in the textile
coating formulations, but phosphorus content of waste waters  should
be  very low.  Addition of phosphorus as a nutrient may be necessary
for biological treatment.

During the past 30 years, a formidable case has  developed  for  the
belief  that  increasing  standing  crops  of aquatic plant growths,
which often interfere with water uses  and  are  nuisances  to  man,
frequently  are  caused  by increasing supplies of phosphorus.  Such
phenomena  are  associated   with   a   condition   of   accelerated
eutrophication  or aging of waters.  It is generally recognized that
phosphorus is not the sole cause of  eutrophication,  but  there  is
evidence  to  substantiate  that it is frequently the key element in
all of the elements required by fresh water plants and is  generally
present  in  the  least  amount  relative  to  need.   Therefore, an
increase  in  phosphorus  allows  use  of  other,  already  present.
                               44

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nutrients  for  plant growths.  Phosphorus is usually described, for
this reasons, as a "limiting factor."

When a plant population is stimulated in production  and  attains  a
nuisance  status,  a  large  number  of  associated  liabilities are
immediately apparent.  Dense populations of pond weeds make swimming
dangerous.  Boating and water skiing and,sometimes, fishing  may  be
eliminated  because  of  the  mass  of  vegetation that serves as an
physical impediment to such activities.  Plant populations have been
associated with stunted fish  populations  and  with  poor  fishing.
Plant nuisances emit vile stenches, impart tastes and odors to water
supplies,  reduce  the  efficiency of industrial and municipal water
treatment, impair  esthetic beauty, reduce or restrict resort trade,
lower waterfront property values, cause skin rashes  to  man  during
water  contact, and serve as a desired substrate and breeding ground
for flies.

Phosphorus in the elemental form is particularly toxic, and  subject
to  bioaccumulation  in  much  the  same  way as mercury.  Colloidal
elemental phosphorus will poison marine fish  (causing  skin  tissue
breakdown  and discoloration).  Also, phosphorus is capable of being
concentrated  and  will  accumulate  in  organs  and  soft  tissues.
Experiments  have shown that  marine fish will concentrate phosphorus
from water containing as little as 1 mg/1.
                               45

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                            SECTION VII

                  CONTROL AND TREATMENT TECHNOLOGY
INTRODUCTION

When classified in terms of the major waste water pollutants,  those
segments  of  the  asbestos  manufacturing  industry covered in this
document  fall  into  two  groups:   (1)  textile  coating,  solvent
recovery,  and  vapor  absorption; and  (2) wet dust collection.  The
waste waters from the first  group  contain  significant  levels  of
organic  materials in solution.  The raw wastes from textile coating
may also contain suspended materials that will settle  in  quiescent
conditions.   The  wastes  from  wet  dust  collectors  are entirely
suspended solids with minimal dissolved organic  content.   Some  of
the  in-plant control measures apply to both groups, but the end-of-
pipe treatment technologies are basically different.

Treatment

Within this industry, the only end-of-pipe treatment  technology  in
use is sedimentation, normally in lagoons.  While this operation may
be  adequate  for  waste  waters  from  wet  dust  collectors, it is
inappropriate as the sole method of treatment for the first group of
subcategories.   It  should  be  pointed  out  that  some   friction
materials  manufacturing  plants provide treatment beyond sedimenta-
tion.  These are primarily for  wastes  from  non-asbestos  manufac-
turing,  e.g.,  metal  finishing operations, and wastes from the wet
dust collectors are treated in the same facility.

The control technologies  recommended   here  are  addressed  at  the
principal  pollutant  parameters,  namely COD, suspended solids, and
pH.  There are insufficient data available to ascertain the need for
additional control measures for such dissolved pollutants  as  heavy
metals,  phenols,  and plant nutrients.  In most of the known cases,
the costs of end-of-pipe treatment technologies more  advanced  than
those  recommended  here are so high that alternative solutions will
be used, e.g., substitution of baghouses for wet dust  scrubbers  in
friction   materials   plants.   At  some  of  the  plants,  such  a
substitution  program,  on  a  phased   schedule,  has  already  been
initiated.

Implementation

Based  on  the  available information,  the in-plant control measures
and end-of-pipe treatment technology outlined below  can  be  imple-
mented  as  necessary  within  the  appropriate subcategories of the
industry.  Factors relating to plant  and  equipment  age,  manufac-
turing  process and capacity, and land  availability do not generally
play significant roles in determining whether a given plant can make
the changes.  Because so few plants are actually affected today, the
recommended technology has been defined with all of the known plants
in mind.   Implementation  of  a  particular  control  or  treatment
                               47

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measure  will  involve  approximately the same degree of engineering
and process design skill and will have the  same  effects  on  plant
operations,   product   quality,  and  process  flexibility  at  all
locations.  Each plant is unique, however, and  the  possibility  of
peculiar requirements should not be ignored.

IN-PLANT CONTROL MEASURES

In  some friction materials plants, water is recirculated in the wet
dust collectors.  This is the only in-plant control measure that  is
generally  used  in  this  industry.   Other  in-plant  measures, as
described below, have  been  implemented  at  individual  plants  to
eliminate  the  generation  or  discharge  of  process-related waste
waters,

Raw Material Storage

Raw materials are normally stored indoors and in containers.   There
is  no  widespread  water  pollution  problem related to improper or
inadequate raw material storage practices.

      Water Segregation

In all cases, sanitary sewage should be discharged  separately  from
process-related  waste waters.  Public health considerations as well
as economic factors dictate that sanitary  wastes  not  be  combined
with process-related wastes for on-site treatment.

In  all  four subcategories, the waste waters originate at one point
in the process or the auxiliary operation.  The  wastes,  therefore,
can  be  isolated  for separate control.  In many plants, the wastes
are diluted with cleaner waters, such as  spent  cooling  water  and
steam  condensate.   By  mixing  these streams, the entire discharge
becomes, by definition, a process-related waste subject to  control.
These  clean  water  discharges  should  be  segregated  and managed
separately.

Housekeeping Practices

The only subcategory  where  housekeeping  practices  influence  the
quality  of  the  waste  water  is textile coating.  Since the waste
results primarily from clean-up of equipment and dumps, changes here
can result in significant improvements in the quality of  the  waste
waters.

Water Usage

Attention  should  be directed toward water conservation in all sub-
categories.  In the clean-up operations in asbestos textile coating,
there is a tendency to use more water than is required.   The  water
used in the vapor absorption and dust collection equipment should be
reduced  to  the minimal level dictated by air quality requirements.
Spent  cooling  water,  where  available,  can  be  used  for  these
operations.
                                48

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As  described  below for three of the four individual subcategories,
water usage can be eliminated through  substitution  of  alternative
procedures or equipment.

TREATMENT TECHNOLOGY

Included  with end-of-pipe treatment technologies are those in-plant
modifications that are more than control measures,  e.g.,  substitu-
tion of dry air pollution control equipment for wet scrubbers.  This
is  regarded  as  a  logical  arrangement  because  the  changes are
separate from the manufacturing processes, major  equipment  instal-
lation  is  required, and both relate to protection of environmental
quality through treatment.

Technical Considerations

The recommended control and treatment technologies are  believed  to
be  applicable  to the appropriate subcategories, as outlined below,
and are based on the limited data available.  It is conceivable that
unknown factors would render a particular technology inoperative  at
a  given  plant.   The  steps  described  here cannot, therefore, be
applied  without  careful  analysis  of  each  plant"s  wastes   and
particular requirements.

Application

The  control  and  treatment  technologies  recommended  here can be
applied regardless of plant size  and  capacity,  the  manufacturing
process,  or  plant and equipment age.  The design can be altered to
fit the plant's needs, and the wastes  from  both  large  and  small
plants can be managed efficiently using these technologies.

Land Requirement s

All  of  the  recommended control and treatment technologies require
relatively little land area; less than 0.1 hectare   (0.25  acre)  in
all  cases.   If  more  land  is  available at a given plant, larger
facilities may be employed to reduce operating costs.

The additional land required for disposal  of  containerized  liquid
wastes resulting from the technologies described here are not large.
The  waste  water volumes are relatively small when compared to many
industries, and the volumes of waste generated for land disposal are
also relatively small.

Compatibility of Control Measures

In some  categories,  the  control  technologies  may  be  based  on
treatment  to  reduce  the  pollutants to acceptable levels prior to
discharge or may involve substitution of equipment so that no  waste
water  is  generated.   The  two levels are incompatible in that the
money spent in implementing the first level controls  is  lost  when
the  second  level controls are installed.  Since half of the plants
                                49

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known to  be  generating  process  waste  waters  now  discharge  to
municipal sewerage systems, the decision takes on added dimensions.

INDUSTRY SUBCATEGORIES

The  control measures and treatment technologies that are applicable
to the separate subcategories of this part of the asbestos  industry
are described below.

Asbestos Textile Coating

The  wastes from textile coating result from clean-up and dumping of
unused coating material at the end of a run.  The waste  waters  are
small  in  volume  and relatively concentrated*  Because of the high
cost of treating this waste to make it suitable for discharge  to  a
surface water, the recommended control measure is containment of the
waste  in  undiluted  form  and containerization for salvage or land
disposal.  The required quantities of finishing  material  for  each
run  should  be  estimated  and  prepared  so  that a minimal amount
remains to be disposed of.  Dry cleaning techniques should  be  sub-
stituted  for wet methods.  Measures should be taken to eliminate or
contain spills and dripped material.  The waste should be placed  in
appropriate   containers,  e.g.,  steel  drums,  for  salvage  by  a
commercial waste handling firm, if available, or for disposal  in  a
controlled  sanitary  landfill.   If  no commercial handling firm is
available and  state  or  local  regulations  prohibit  disposal  of
solvents  in sanitary landfills, it may be necessary to employ small
batch incinerators for disposal of the  reduced  volumes  of  waste.
These alternative methods of disposal must be in compliance with the
appropriate regulations affecting such disposal.

Solvent Recovery

At  least  one  plant in this industry recovers solvent without gen-
erating waste water pollutants.  It appears that this  technique  is
not  applicable  at  other  plants  using  different  solvents.  The
solvent recovery waste waters may contain significant organic  loads
and may have an elevated temperature.

If  the  organic  material  is  not refractory, bio-treatment by the
activated sludge process  after  cooling,  as  necessary,  would  be
suitable  for  meeting the limitations.  For the scale of operations
encountered in this industry, i.e., approximately  40  cubic  meters
(10,000  gallons)  per day, the extended aeration variation would be
appropriate.  Excess sludge could be removed by a commercial  hauler
for disposal at a municipal treatment plant.

If the waste is refractory to bio-treatment, adsorption on activated
carbon  is  recommended-   If  properly  designed and operated, this
process should reduce the concentrations  of  organic  materials  to
acceptable  levels.   Because  of  the relatively small volume to be
handled, carbon regeneration by the supplier would probably be  more
economical than on-site thermal regeneration.
                                50

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In preparing to apply either of the treatment technologies described
above,  their  suitabilities  for  a particular waste stream must be
evaluated.  There are standardized  testing  procedures  to  measure
both  the  biodegradability  and  sorptive  characteristics of waste
waters.   In  the  event  that  neither  of  these  technologies  is
feasible, more sophisticated processes, such as reverse osmosis, are
available to achieve the desired results.

Vapor Absorption

The waste water from vapor absorption operations resembles that from
solvent  recovery  in  that  it  contains organic material and has a
negligible suspended solids content.  In this industry, however, the
vapor absorption operations are operated  intermittently,  and  bio-
treatment  processes  are  not  feasible.  All biological facilities
require a reasonably steady inflow of waste to function effectively.
Carbon adsorption should be effective with  these  wastes,  however.
Adjustment  of  the pH to a lower level would probably be beneficial
to increase the efficiency of the carbon.

Since recovery of the solvent is not a goal in vapor  absorption,  a
fume  incinerator  could be substituted to remove the vapor from the
exhaust air.  Both direct-fired and catalytic  types  are  available
and  either  should  be  suitable  for  this  application.  Detailed
information about the design, operation, costs, and applicability of
various types of incinerators is beyond the scope of this report and
is readily available in the technical literature  on  air  pollution
control.  The use of an incinerator would eliminate the discharge of
waste water in this subcategory.

Wet Dust Coll ection

The  waste waters from wet dust collectors are amenable to treatment
by sedimentation, with coagulation as necessary.  There are no  data
available  on the efficiency of plain sedimentation, but there  is no
reason to believe that it would not be effective.

While the dust particles have a significant  organic  content,  they
are  not  treatable  by such processes as bio-treatment or activated
carbon adsorption.  If treatment beyond sedimentation is  indicated,
filtration would be the logical next step and complete removal  could
be  accomplished.   A more appropriate means of solving this problem
is to  substitute dry dust collectors, e.g., baghouses, for  the wet
scrubbers.   This  step, which is already being taken at some of the
plants in this industry, eliminates the discharge of waste water  in
this   subcategory.   Detailed  information  about  the  engineering
aspects  of  the  available  equipment   for   dry   collection  of
particulates  is beyond the scope of this report and is available in
the literature dealing with air pollution control.
                                51

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                            SECTION VIII

            COST, ENERGY, AND NON-WATER QUALITY ASPECTS


An analysis of the estimated costs and pollution control benefits of
alternative control and treatment technologies  applicable  to  this
part  of  the  asbestos  manufacturing  industry  is  given  in this
section.

The cost estimates were developed using data from  various  sources,
including  the  contractor's  files  and  the general information on
costs referenced in section XIII.   There  was  very  little  useful
treatment  cost  data  available  from  the  industry.  The existing
treatment facilities are lagoons of various types and most  of  them
receive  large  volumes of waste waters from sources not included in
this  report,  e.g.,  spent  cooling  water  or  wastes  from  other
manufacturing processes.

REPRESENTATIVE PLANTS

The representative plants used to develop treatment cost information
are  composites rather than actual plants.  Because there are so few
plants that generate waste waters, the composites represent all  the
known  plants  in  the  industry.   The  treatment technologies were
developed for application to effluents discharged to surface waters,
although half of the plants discharge to municipal sewerage systems.
The costs are based  on  typical,  standard  control  and  treatment
technologies  that are either used elsewhere in this industry or are
used with similar wastes from sources outside  this  industry.   The
waste  flows  were  selected  as typical for the plants, and where a
significant range of flows exists, estimates for various  sizes  were
developed.

The  end-of-pipe  control  technologies were designed, for cost pur-
poses, to require minimal space and land area.  It is believed that,
at most plants, no additional land would be required.  At  locations
with  more  land  available,  larger,  more economical facilities of
equal efficiency may be used, e.g., a lagoon may be substituted  for
a mechanical clarifier.

In summary, the cost information is intended to apply to most plants
in  this industry.  Differences in age or size of production facili-
ties, level of implementation of in-plant controls, and  local  non-
water   quality  environmental  aspects  all  reduce  to  one  basic
variable, the volume of waste water discharged.  The  sizes  of  the
representative  composite  manufacturing  plants  used  for the four
subcategories are presented in Table  3.   For  those  subcategories
where  dry  air  pol lution  control  equipment  may  be substituted,
exhaust air flow rates that correspond approximately  to  the  waste
water flows are given.
                                 53

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                              TABLE 3

             REPRESENTATIVE JteNUFACTURING PLANTS USED IN
                      DEVELOPING COST ESTIMATES
     Subcategory

Textile Coating

Solvent Recovery

Vapor Absorption

Wet Dust Collection:

     Small

     Medium

     Large
                              Waste Water Flow
cu m/day
0.8
38
230**
190
380
570
mgd
0.0002
0.01
0.06**
0.05
0.10
0.15
 Exhaust Air Flow
cu m/min     scfm

   NA*        NA

   NA         NA

   570      20,000



   280      10,000

   850      30,000

  1700      60,000
 *  NA = Not Applicable.

**  Total discharge per operating period,
                                 54

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COST INFORMATION

The  investment  and  annual  costs  associated with the alternative
control technologies for the four  subcategories,  as  well  as  the
effluent quality associated with each alternative, are summarized in
Tables 4 through 9.  All costs are reported in August, 1971 dollars.

Investment costs

Investment costs are defined as the capital expenditures required to
bring the treatment or control technology into operation.  Included,
as  appropriate,  are  the costs of excavation, concrete, mechanical
and electrical equipment installed, and piping.  An amount equal  to
from  15  to 25 percent of the total of the above was added to cover
engineering design services, construction supervision,  and  related
costs.   The  lower percentages were used for the larger facilities.
Because most of the control technologies involved external,  end-of-
plant   systems,   no  cost  was  included  for  lost  time  due  to
installation.  It is believed that  the  interruption  required  for
installation  of control technologies can be coordinated with normal
plant shutdown   and vacation periods in most cases.  As noted above,
the control facilities were estimated on the basis of minimal  space
requirements.  Therefore, no additional land costs were included.

Capital Costs

The  capital costs are calculated, in all cases, as 8 percent of the
total  investment  costs.   Consultations  with  representatives of
industry  and  the  financial  community led to the conclusion that,
with the limited data available, this estimate  was  reasonable  for
this industry.

Depreciation

Straight-line  depreciation was used in all cases.  The periods used
were believed to be typical for the particular  technology  and  are
indicated in the footnotes on Tables U through 9.

Operation and Maintenance Costs

Operation  and  maintenance  costs  include  labor, materials, solid
waste disposal, effluent monitoring, added administrative  expenses,
taxes, and insurance.  Manpower requirements were based upon a total
salary  cost  of   $10  per  man-hour  in  all  cases.   The costs of
chemicals used in  treatment were added to  the  costs  of  materials
used  for  maintenance  and  operation.   The  costs  of solid waste
handling and disposal were based primarily upon information supplied
by the representative firms.
Energy and Power Costs

Energy costs were estimated on the basis
hour.
of  $0.025  per  kilowatt-
                                55

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CONTROL TECHNOLOGIES WITH COSTS

The  estimated  costs  and the associated reduction benefits for the
alternative control technologies for each of the  subcategories  are
presented below.

Textile Coating (Table 4)

Alternative A - No Waste Treatment or Control

Effluent  waste  load is a very small volume of concentrated organic
material (COD) and suspended  solids  with  potentially  significant
levels of heavy metals and plant nutrients.  The waste is discharged
on about half of the plant operating days.
           Costs,
None.
           Reduction Benefits.
Alternative B - Zero Discharge
             None
Discharge  of  waste  water  is  eliminated through in-plant control
measures, including the use of dry cleaning methods  and  containment
of  dumped and spilled coating material.  Waste is containerized for
salvage by a commercial waste salvage firm or for disposal in  a  con-
trolled  sanitary  landfill.  Some in-plant control measures are now
in use, e.g., minimizing dumps, but no plant completely retains  all
waste.

           Costs.  Investment cost is approximately $2,000.

           Reduction   Benefits.    Reduction   of   all   pollutant
           constituents of 100 percent.

Alternative c - Zero Discharge, Incineration

This alternative involves temporary storage of  the  waste  residues
followed  by  incineration  in a liquid thermal oxidation unit.  The
inert ash goes to sanitary landfill.

           Cost.    Investment cost is approximately $28,000.

           Reduction Benefits.  Reduction    of    all     pollutant
           constituents of 100 percent.

Solvent Recovery  (Table 5)

Alternative A - No Waste Treatment or Control

Daily  effluent  waste load is estimated to be 75 kg (165 Ib) of COD
and 45 kg  (100 Ib) of BOD for the  typical  plant  at  this  minimal
control  level.  The suspended solids waste load is negligible.  All
known plants in the industry provide only this level of control.
                              56

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                              TABLE 4
                           TYPICAL PLANT
                   WATER EFFLUENT TREATMENT COSTS
                       ASBESTOS MANUFACTURING
                      ASBESTOS TEXTILE COATING
Treatment or Control Technologies:
Investment
Annual Costs:
  Capital Costs
  Depreciation
  Operating & Maintenance Costs
    (excluding energy & power costs)
  Energy and Power Costs
            Total Annual Cost
Effluent Quality:
Effluent Constituents
COD - mg/1
Suspended Solids - mg/1
PH
       *Expected Lifetime - 10 years.
      **Expected Lifetime - 12 years.
(Costs in $1000)
  ABC
        2.0   28
        0.2   2.3
        0.2*  2.4**
        8.0   2.2
       Zero   1.3
        8.4   8.2
Raw
Waste
Load
Variable
Variable
Variable
Resulting Effluent
Levels
Variable
Variable
Variable
Zero Zero
Zero Zero
_ ..
                                 57

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                              TABLE 5

                           TYPICAL PLANT
                  WATER  EFFLUENT TREATMENT  COSTS
                      ASBESTOS MANUFACTURING
                          SOLVENT RECOVERY
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
 (Costs in $1000)
ABC
        73
146
         5.9     11.7

         2.9*    10.5**
12.5
11.0
32.3
20.6
1.0***
43.8
Effluent Quality:
Effluent Constituents
BOD (5-day) - mg/1
COD - mg/1
Suspended Solids - mg/1
pH
Raw
Waste Resulting Effluent
Load Levels
1200 1200
2000 2000
30 30
6-9 6-9
30
50
30
6-9
5
5
5
6-9
  * Expected lifetime - 25 years
 ** Expected lifetime - 14 years
*** Not including carbon regeneration
                               58

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           Costs*  None.

           Reduction Benefits.  None.

Alternative B - Biological Treatment

This alternative involves using the extended aeration variation
of the activated sludge process with removal of excess sludge to
a municipal sewage treatment plant.  The daily effluent waste load
is estimated to be about 2 kg  (5 Ib) of COD and 1.1 kg (2.5 lb)
of BOD with this alternative.

           Costs.  Investment costs are approximately $73,000.

           Reduction Benefits.  Estimated reduction of effluent
             COD and BOD of 97 percent.

alternative C - Carbon Adsorption

This alternative involves treating the effluent from the bio-treatment
process in 2-stage granular activated carbon columns.  The carbon
is regenerated off-site by the supplier.  Costs for filtration
of the bio-treatment process effluent are not included.  The daily
effluent waste load is estimated to be less than 0*2 kg  (0.4 lb)
for both COD and BOD.

           Costs.  The estimated incremental cost for this
             alternative is $146,000.  Total costs are $219,000.

           Reauction Benefits.  Reduction of COD and BOD of
             more than 99.8 percent.

Vapor Absorption  (Table 6)

Alternative A - No Waste Treatment  or Control

Daily effluent waste load is estimated to be 410 kg  (900 lb) of COD
at a pH level above 9.5.  The  suspended solids waste load is neg-
ligible.  Discharge is presently intermittent in this subcategory.

           Costs.  None.

           Reduction Benefits.  None.

Alternative B - Carbon Adsorption

This alternative involves treatment of the raw waste water in  2-stage
granular activated carbon columns.   The raw waste water  is acidulated
as necessary, but does not require  filtration.  The carbon is  regen-
erated off-site by the  supplier.  The daily effluent waste load is
estimated to be about 10 kg  (22 lb)  of COD with the pH value in the
neutral range, 6 to 9.

           Costs.  Investment  cost  is estimated to be $130,000.
                                59

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                               TABLE 6

                            TYPICAL PUNT
                   WATER EFFLUENT TREATMENT COSTS
                       ASBESTOS MANUFACTURING
                         VAPOR ABSORPTION
 Treatment or Control Technologies:

 Investment

 Annual Costs:

   Capital Costs

   Depreciation

   Operating and  Maintenance Costs
     (excluding energy and power costs)

   Energy and Power Costs

           Total  Annual Cost


 Effluent Quality:
 (Costs in $1000)
A  _  	B __     C
      130



       10.4

        9.3*
152



 12.2

 15.2**
        8,7      1.8

        1.0***  16.8

       29.4     46.0
Effluent Constituents
COD - mg/1
Suspended Solide - mg/1
PH
Raw
Waste
1800
30
>9
Resulting Effluent
Levels
1800
30
>9
50
30
6-9
Zero
Zero
_
  * Expected lifetime - 14 years
 ** Expected lifetime - 10 years
*** Not including carl>on regeneration
                                60

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           Reduction Benefits.  Reduction of COD of approximately
             98 percent and neutralization of alkali in effluent.

Alternative c - Zero Discharge

Zero discharge is achieved by replacement of the vapor absorption
unit with a fume incinerator.  No waste water is generated.

           Costs.  Estimated cost for this alternative is
             $152,000.

           Reduction Benefits.  Reduction of all pollutant
             constituents of 100 percent.

Wet Dust collection  (Tables 7, 8, and 9)

Alternative A - No Waste Treatment or Control

Estimated effluent waste load is 380 cu m  (100,000 gal) per day of
concentrated dust slurry.  The dissolved solids level is not sig-
nificantly higher than that of the carriage water.

           Costs.  None.

           Reduction Benefits.  None.

Alternative B - Sedimentation

This alternative comprises sedimentation, with coagulation as
necessary, to remove suspended solids.  Sludge is dewatered for
disposal in a controlled sanitary landfill.  Daily effluent waste
load is estimated to be 11 kg  (25 Ib) of suspended solids.  All
known  plants use this alternative as a minimum level of control*

           Costs.  Investment cost is estimated to be $64,000.

           Reduction Benefits.  Reduction of suspended solids
             of over 95 percent.

Alternative C - Zero Discharge

This alternative comprises substitution of dry dust collection
devices  (baghouses)  for the wet dust scrubbers.  No waste water is
generated in using this control technology.  Most of the friction
materials plants now use such dry equipment.

           Costs.  Estimated investment cost is $94,000.

           Reduction Benefits.  Reduction of all pollutant
             constituents of 100 percent.

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                              TABLE 7

                           TYPICAL PLANT
                  WATER  EFFLUENT  TREATMENT  COSTS
                      ASBESTOS MANUFACTURING

                 WET DUST COLLECTION - SMALL PLANT
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
 (Costs in $1000)
ABC
        44
         3.5
         7.7

         4.0

        17.0
3.4

1.7**


4.3



9.4
Effluent Quality:
Effluent Constituents
COD (Filtrate) - mg/1
Suspended Solids
pH
- mg/1

Raw
Waste
Load
Unknown
Variable
6-9
Resulting Effluent
Levels
Unknown
Variable
6-9
50
30
6-9
Zero
Zero
-
  * Expected lifetime - 25 years
 ** Expected lifetime - 20 years
                               62

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                              TABLE  8

                           TYPICAL PUNT
                  V/ATKR  EFFLUENT  TREATMENT  COSTS
                      ASBESTOS MANUFACTURING
                WET DUST COLLECTION - MEDIUM PLANT
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
 (Costs in $1000)
A       B        C
64



 5.1

 2.6*


12.0

 5.2

24.9
                94
                 7.5
                 6.1
                18.3
Effluent Quality:
Effluent Constituents
COD (Filtrate) - mg/1
Suspended Solids
pH
- mg/1

Raw
Waste
Load
Unlmown
Variable
6-9
Resulting Effluent
Levels
Unknown
Variable
6-9
50
30
6-9
Zero
Zero
-
  * Expected lifetime - 25 years
 ** Expected lifetime - 20 years

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                              TABLE 9

                           TYPICAL PLANT
                  WATER EFFLUENT TREATMENT COSTS
                      ASBESTOS MANUFACTURING

                 WET DUST COLLECTION - LARGE PLANT
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
Effluent Quality:



  Effluent Constituents

  COD (Filtrate) - mg/1

  Suspended Solids - mg/1

  pH
  Raw-
 Waste
  Load

Unknown

Variable

  6-9
                (Costs in $1000)
               JL	B	C_

               -      83     146
                       6.6    11.7

                       3.3*    7.3**


                      16.0     8.5

                       6.5

                      32.7    27.5
  Resulting Effluent
	Levels	

Unknown   50      Zero

Variable  30      Zero

  6-9     6-9
  * Expected lifetime - 25 years
 ** Expected lifetime - 20 years
                               64

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ENERGY REQUIREMENTS OF CONTROL TECHNOLOGIES

The energy required to incinerate the asbestos textile coating waste
is estimated to be about 440 KW (590 hp) per daily batch  of  waste.
(The  textile  coating  waste  is considered to have no heat value.)
The energy requirements for the containment alternative are  minimal
and relate primarily to transportation of the containerized waste to
a salvage facility or a sanitary landfill site.

The additional energy required in the solvent recovery category will
also involve energy for transportation of waste sludge away from the
plant and of activated carbon to and from the site if carbon columns
must   be   employed   for  refractory  wastes.   The  major  energy
requirements will be for pumping and aeration in  the  bio-treatment
unit  and  for  regeneration  of  the activated carbon columns.  The
former requirement is estimated to be about 7.5  Jew   (10  hp) .   The
energy  required to regenerate the carbon off-site at the supplier's
facility cannot be  estimated  without  knowing  the  scale  of  the
operation.  If it is large, the incremental energy required for this
subcategory  will not be significant because of the relatively small
carbon requirements.

The energy requirements for implementation of the  alternatives  for
the  vapor  absorption  subcategory are primarily for fuel to regen-
erate the activated carbon and to operate the fume incinerator.  The
requirement for regeneration cannot be estimated for the same reason
as with the solvent recovery subcategory, except that in this  case,
about  ten  times  as  much  carbon is required per year because the
waste is not pretreated by the biological process and  also  because
no  credit  is  taken for biological activity in the carbon columns.
The energy requirements of the fume incinerator  may  be  relatively
high, but this unit will be operated only one or two days per month.
The  fuel  requirement  depends  upon  the  energy  content  of  the
vaporized solvent.

The energy used in clarifying waste waters from wet dust  collection
is  not  large, 5 kw  (6.7 hp) or less for the sludge removal mecha-
nisms and no more than 20 kw  (25 hp) for pumping.  A  centrifuge  for
dewatering  the  sludge would require 30 to 40 kw  (40 to 53 hp) when
running.  The energy requirements for  the  operation  of  baghouses
should be less than for wet dust collectors.

No  information  was provided by the industry relative to the energy
requirements of individual manufacturing plants.  Most of the  fric-
tion  materials  plants  use large amounts of energy for heating and
curing their products.  The additional energy required to  implement
the  control and treatment technologies is estimated to be less than
10 percent of the requirements for the manufacturing and  associated
operations.  The major potential energy uses are for textile coating
waste incineration, carbon regeneration and fume incineration.
                              65.

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NON-WATER QUALITY ASPECTS OF CONTFOL TECHNOLOGIES

Air Pollution

Three  of  the four subcategories in this industry relate totally or
partially to control of pollutant emissions to the atmosphere.   The
use  of  the  substituted dry control devices would effect equal, or
better, control of the pollutants of interest.  The only significant
potential air pollution problem associated with the  application  of
the  control  technologies  at  a  typical  plant  is the release of
materials from improperly  managed  solid  residues.   For  example,
exposed  accumulations  of  dust  from friction materials plants may
serve as sources of air emissions.

There are no significant odor problems associated  with  implementa-
tion of the waste water control and treatment technologies.  Neither
are  there any unusual or uncontrollable sources of noise associated
with the control measures.

Solid Waste Disposal

The volumes of solid wastes resulting from application of  the  con-
trol  technologies  will  not  be large compared to many industries.
The wastes do not present any unusual problems  in  handling  or  in
disposal.   A  properly  planned,  designed,  and  operated sanitary
landfill with capability for receiving industrial solid  waste  will
be adequate.  The disposal of dust is already practiced at all known
friction   materials   plants  and  implementation  of  the  control
technologies will not create any unusual  problems.   Transportation
of  dust  should be in closed vehicles or the dust should be heavily
dampened to eliminate air emissions.  The containerized  waste  from
textile  coating  does  not pose a health or environmental hazard if
properly disposed of at a licensed landfill site.

There is no known recovery value in any of the  residues  from  this
industry  with the possible exception of use as a fuel substitute.  No
data are available by which to evaluate this possibility.

For those waste materials considered to be non-hazardous where  land
disposal  is  the  choice  for disposal, practices similar to proper
sanitary landfill technology may be followed.   The  principles  set
forth  in  the  EPA1 s  Land Disposal of Solid Wastes Guidelines  (CFR
Title 10,  Chapter  1;  Part  241)  may  be  used  as  guidance  for
acceptable land disposal techniques.

For  those waste materials considered to be hazardous, disposal will
require  special  precautions.   In  order   to   ensure   long-term
protection of public health and the environment, special preparation
and  pretreatment  may  be  required  prior  to  disposal.   If land
disposal is to be practiced, these sites must not allow movement  of
pollutants  such  as  fluoride  and  radium-226  to either ground or
surface water.  Sites should be selected that have natural soil  and
geological  conditions  to  prevent  such  contamination or, if such
conditions do not exist, artificial means  (e.g.,  liners)  must  be


                               66

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provided  to  ensure  long-term  protection  of the environment from
hazardous materials,   where  appropriate,  the  location  of  solid
hazardous materials disposal sites should be permanently recorded in
the  appropriate  office of the legal jurisdiction in which the site
is located.
                                67

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                               TABLE 10
          EFFLUENT REDUCTION ATTAINABLE THROUGH APPLICATION
           OF BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
                              AVAILABLE*
  Subcategory

Solvent Recovery
Textile Coating
Vapor Absorption
Wet Dust Collection
       COD            Suspended Solids
 kg/kkg(lb/1000 Ib)  kg/kkg(lb/1000 Ib) of
of finished asbestos  finished asbestos
     product	product
      0.150                 0.090                  6-9
        No discharge of process waste water pollutants
      zero                  zero                   6-9
       NA                   0.090                  6-9
*Maximum average of daily values for any period
 of 30 consecutive days.
                                    68

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                             SECTION IX

      EFFLUENT REDUCTION ATTAINABLE THROUGH APPLICATION OF THE
      BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
                  EFFLUENT LIMITATIONS GUIDELINES
INTRODUCTION

The effluent limitations which must be achieved by July 1, 1977, are
to specify the degree of effluent reduction attainable  through  the
application  of  the  Best  Practicable Control Technology Currently
Available.  Best Practicable Control Technology Currently  Available
is generally based upon the average of the best existing performance
by  plants  of  various  sizes,  ages, and unit processes within the
industrial category or subcategory.  This average is not based  upon
a  broad  range  of  plants  within  an  industry,  but instead upon
performance levels achieved by exemplary plants.

Consideration must also be given to:

     a.    The total costs of application of this control
           technology in relation to the effluent reduction
           benefits to be achieved from such application,

     b.    energy requirements,

     c.    non-water quality environmental impact,

     d.    the size and age of equipment and facilities involved,

     e.    the processes employed,

     f.    process changes, and

     g.    the engineering aspects of the application of this
           control technology.

Best Practicable Control Technology Currently  Available  emphasizes
treatment facilities at the end of a manufacturing process, but also
includes the control technologies within the process itself when the
latter are considered to be normal practice within an industry,

A  further  consideration  is the degree of economic and engineering
reliability which must be  established  for  the  technology  to  be
"currently available".  As a result of demonstration projects, pilot
plants,  and  general  use,  there  must  exist  a  high  degree  of
confidence in the engineering and  economic  practicability  of  the
technology  at  the  time  of  commencement  of  construction or in-
stallation of the control facilities.
                                69

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EFFLUENT  REDUCTION  ATTAINABLE  THROUGH  THE  APPLICATION  OF  BEST
PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE

Based  on  the information contained in Sections III through VIII of
this document, it has been determined that the degrees  of  effluent
reduction  attainable  through the application of the Best Pollution
Control Technology Currently Available for this part of the asbestos
manufacturing industry are  those  presented  in  Table  10.   These
values   represent   the   maximum  allowable  average  for  any  30
consecutive calendar days.  Maximum daily averages should not exceed
twice the 30-day values.


Oxygen- De manding Materials

Waste waters from the solvent recovery  and  vapor  absorption  sub-
categories  normally  contain  significant  quantities  of dissolved
organic materials that exert an oxygen demand.  While some of  these
organic  components are biodegradable, others are not.  The BOD test
is, therefore, of limited value, and the COD  (or TOC)  parameter  is
recommended.   Application  of  control  technology  will reduce the
concentrations of oxygen-demanding materials by at least 97 percent.

Suspended Solids

Suspended solids are the principal pollutant  constituent  in  waste
waters  from  the  wet  dust collection subcategory.  Application of
control technology  will  reduce  the  suspended  solids  to  levels
comparable to those achieved in the secondary treatment of municipal
waste waters.
The pH level of all waste waters should be in the neutral range from
6 to 9 upon application of this control technology.
IDENTIFICATION
AVAILABLE
OF  BEST  PRACTICABLE  CONTROL  TECHNOLOGY CURRENTLY
The Best Practicable control  Technology  Currently  Available  com-
prises  in-plant  measures  for  the textile coating subcategory and
end-of-pipe treatment technologies for the solvent  recovery,  vapor
absorption, and wet dust collection subcategories.

Textile Coating

The  control  technology  comprises elimination of discharge by con-
tainment of dumped and spilled coating materials, dry techniques for
cleaning of equipment and for housekeeping, and institution of water
conservation practices to minimize the volume of waste.  All  wastes
are containerized for salvage, use as a fuel substitute, or disposal
in   a   controlled   sanitary   landfill,  with  or  without  prior
incineration.  Although this control  technology  is  not  practiced
within  this subcategory, it is believed to be much less costly than
                                70

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providing  treatment  to  render  the  waste  waters  suitable   for
discharge to a surface water.

Solvent Recovery

The  control  technology  comprises  cooling  of  the waste water as
necessary, adding  supplemental  nutrients,  and  treatment  by  the
extended  aeration  version  of  the  activated sludge process.  The
excess sludge is disposed of in a municipal sewage treatment  plant.
Although  no  plant  in this subcategory presently uses this control
technology, the  available  information  on  the  raw  waste  waters
indicates that they are amenable to biological treatment.

Vapor Absorption

For   control   technology  in  the  vapor  absorption  subcategory,
treatment with activated carbon was considered, with  acid  addition
to lower the pH.  The suspended solids level is negligible and prior
filtration  is  not required.  Because of the relatively small scale
of the treatment units, the carbon would be  regenerated  off  site,
probably  by  the supplier.  However, this control technology is not
compatible  with  the   Best   Available   Technology   Economically
Achievable,  complete  elimination  of  pollutants  by means of fume
incineration.  Moreover, fume incineration is the  current  practice
for  much  of the industry.  For these reasons, fume incineration is
considered to be the appropriate control technology.

Wet Dust Collection

For the wet dust collection subcategory, the control  technology  is
sedimentation.   Based  on  the available information, all plants in
this  subcategory  now  provide  at  least  this  level  of  control
technology.

RATIONALE  FOR  THE SELECTION OF BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE

Total Costs of Application

The total investment cost of implementing this control technology is
estimated to be approximately $200,000.  This figure is based on the
known level of control presently provided in this industry  and  the
fact that half of known effluent streams are discharged to municipal
sewerage  systems  where the pollutant constituents are not known to
be incompatible.  If  all  plants  in  this  part  of  the  asbestos
industry  were to discharge directly to surface waters, the costs of
implementing this technology is estimated to be $500,000.  The total
annual costs for all of the known manufacturing plants in  the  four
subcategories are estimated to be $150,000.

Energy Requirements

The   most   significant   energy   requirement  is  fuel  for  fume
incineration in the vapor absorption subcategory.   Since  there  is
                               71

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only  one  known  plant  in  this subcategory, the additional energy
required is not large for the industry as  a  whole.   Other  energy
requirements  include those for possible incineration of the coating
residues, pumping of the waste waters to the  treatment  facilities,
for  aeration  of bio*treatment processes, and for transportation of
wastes and activated carbon.  All of  these  requirements  will  not
increase  the level of energy consumption at a typical plant by more
than 5 percent,

Non-Water Quality Environmental Impact

There is no evidence that application of BPCTCA  control  technology
will result in any unusual air pollution, noise, radiation, or solid
waste  management  problems, either in kind or magnitude.  The costs
of  avoiding  problems  in  these  areas  are  not  excessive.   The
principal  area  for  attention  is  the  disposal  of solid wastes;
sludges, slurries, and other residues.

Size and Age of Equipment and Facilities

Differences in size and  age  of  the  manufacturing  equipment  and
facilities  do  not  influence  the  applicability  of  this control
technology.

Process es Employed

There is no information  available  to  indicate  that  the  control
technology cannot be applied to some plants because of the processes
employed.    However,  each  plant  is  unique,  and  an  individual
evaluation is required at each location to determine the suitability
of the control technology and define any necessary modifications.

Process Changes

No changes in the manufacturing processes are required to  implement
this  control  technology.   There  are  no  anticipated  changes in
production methods in any  of  the  four  subcategories  that  would
lessen the effectiveness of the control technology.  Solvent changes
can  be  compensated  for  by  over-design of the carbon units or by
changes in their operation.

Engineering Aspects of Application

Outside of sedimentation in the wet dust collection subcategory  and
fume incineration in the vapor absorption subcategory, this level of
control  has not been applied in this industry.  The recommended in-
piant control measures and end—of-pipe treatment  technologies  have
been  widely  applied  in other industrial settings, however, and no
technical difficulties are anticipated.   As  noted  elsewhere,  the
data base for this document is not extensive, and evaluation of each
plant"s  particular  wastes  is  necessary  before  implementing any
control  measure.   Of  particular  interest  would  be   the   bio-
degradability of waste waters from solvent recovery facilities.  The
                               72

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need  for  coagulation should be evaluated for the waste waters from
wet dust collectors.
                                73

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                               TABLE 11

          EFFLUENT REDUCTION ATTAINABLE THROUGH APPLICATION
              OF BEST AVAILABLE TECHNOLOGY ECONOMICALLY
                             ACHIEVABLE*
  Subcategory


Solvent Recovery

Textile Coating

Vapor Absorption**

Wet Dust Collection**
       COD
 kg/kkg(lb/1000 Ib)
of finished asbestos
     product	
 Suspended Solids
kg/kkg(lb/1000 Ib) of
 finished asbestos
       product	
pH
      0.150                 0.090                  6-9

        No discharge of process waste water pollutants

        No discharge of process waste water pollutants

        No discharge of process waste water pollutants
*Maximum average of daily values for any period
 of 30 consecutive days.

**Vapor absorption and west dust collection can be
  replaced by non-water contact technologies - see text,
                                     74

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                             SECTION X

        EFFLUENT REDUCTION ATTAINABLE THROUGH APPLICATION OF
       THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
                  EFFLUENT LIMITATIONS GUIDELINES
INTRODUCTION

The effluent limitations that must be achieved July 1, 1983, are  to
specify  the  degree  of  effluent  reduction attainable through the
application  of   the   Best   Available   Technology   Economically
Achievable,  This control technology is not based upon an average of
the   best   performance  within  an  industrial  category,  but  is
determined by  identifying  the  very  best  control  and  treatment
technology  employed  by  a  specific  plant  within  the industrial
category or subcategory, or that is readily  transferable  from  one
industry to another:

Consideration must also be given to:

     a.    The total cost of application of this control
           technology in relation to the effluent reduction
           benefits to be achieved from such application,
     b.    energy requirements,
     c.    non-water quality environmental impact,
     d,    the size and age of equipment and facilities involved,
     e.    the processes employed,
     f.    process changes, and
     g.    the engineering aspects of the application of this
           control technology.

The Best Available Technology Economically Achievable also considers
the  availability of in-process controls as well as in-plant control
measures and  additional  end-of-pipe  treatment  techniques.   This
control  technology  is the highest degree that has been achieved or
has been demonstrated to be capable  of  being  designed  for  plant
scale operation up to and including «no discharge" of pollutants.

Although  economic  factors  are considered in this development, the
costs for this level of control are intended to be  the  top-of-the-
line  of  current  technology  subject  to  limitations  imposed  by
economic  and  engineering  feasibility.   However,   this   control
technology  may be characterized by some technical risk with respect
to performance and with respect to certainty of  costs.   Therefore,
the  control  technology may necessitate some industrially sponsored
development work prior to its application.

EFFLUENT  REDUCTION  ATTAINABLE  THROUGH  APPLICATION  OF  THE  BEST
AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE

Based upon the information contained in Sections III through VIII of
this  document,  a  determination  has been made that the degrees of
effluent reduction attainable through the application  of  the  Best
                                75

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Available  Technology  Economically  Achievable  are those listed in
Table 11.  The values given for the solvent recovery subcategory are
the maximum allowable averages for  30  consecutive  days.   Maximum
daily values should not exceed two times the 30-day averages,


Oxygen-Demanding Materials

Application  of  BATEA control technology will reduce the concentra-
tion of oxygen-demanding materials in the raw waste waters from  the
solvent recovery subcategory by at least 97 percent.

Suspended Solids

The  suspended  solids in the raw waste waters from solvent recovery
facilities, consisting  of  biological  solids  generated  in  waste
treatment, remain the same as those for BPCTCA, but suspended solids
from dust collection are eliminated.

fil

The  waste  waters  discharged following application of this control
technology will have pH values in the neutral range of 6 to 9.

IDENTIFICATION OF BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE

The Best Available Technology Economically Achievable comprises  the
installation  of  advanced  end-of-pipe  treatment technology in the
solvent recovery subcategory and substitution of a different type of
in-plant air pollution control equipment in the wet dust  collection
subcategory.

Textile Coating

The  control  technology  for the textile coating subcategory is the
same as the  Best  Practicable  Technology  Currently  Available  as
presented in Section IX.  No additional control is required.

Solvent Recovery

The  control  technology is the same as the Best Practicable Control
Technology Currently Available presented in Section IX.
Vapor Absorption

No discharge of process wastes is achieved in  this  subcategory
replacement of vapor absorption systems with fume incinerators.

wet Dust Collection
by
The  control  technology  for the wet dust collection subcategory is
replacement of  the  wet  scrubbers  with  baghouses  or  other  dry
particulate  collection devices of equal efficiency.  No waste water
is generated with this control technology.
                               76

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RATIONALE  FOR  THE   SELECTION   OF   BEST   AVAILABLE   TECHNOLOGY
ECONOMICALLY ACHIEVABLE

Total Costs of Application

If all known manuf acturing plants in this part of the asbestos manu-
facturing  industry  implemented this control technology in order to
reduce or eliminate the discharge of pollutants to  surface  waters,
the estimated cost would be $600,000 in addition to the amount spent
to  implement  the  Best Practicable Technology Currently Available.
The additional annual costs for all  known  plants  would  be  about
$150,000.   Since  some  plants  can  be  expected  to  continue  to
discharge to municipal sewerage systems, the actual investment  cost
for  this  control technology is estimated to be closer to $450,000.
The actual combined  cost  for  implementation  of  both  levels  of
control  technologies  is  estimated  to be about $675,000, with the
total annual costs estimated to be about $200,000 for the industry.

Energy Requirement s

Application of this  control  technology  will  result  in  a  minor
reduction   in   energy  requirements  through  replacement  of  wet
scrubbers with dry dust collection systems.

Non-Water Quality Environmental Impact

The  application  of  the  Best  Available  Technology  Economically
Achievable should not create any new air or land pollution problems.
The  replacement  of  wet  air  pollution  control equipment in this
control technology should, in fact, result  in  lower  emissions  of
pollutants  to the atmosphere, since in this industry baghouses have
been found to be slightly more effective than wet scrubbers for  the
removal of participates produced in friction materials manufacturing
plants.

size and Age of Eguipment and Facilities

Differences  in  size  and  age  of  the manufacturing equipment and
facilities do  not  influence  the  applicability  of  this  control
technology.

Processes Employed

since  this  control  technology, is  entirely  related to auxiliary
operations and not to the manufacturing processes, it can be applied
without particular regard to the processes employed.

Process Changes

For the reason noted in the previous paragraph, application of  this
control  technology  does  not  require  any  changes  in any of the
manufacturing processes in any subcategory of  this  industry.   Any
normal  process  changes  would  not lessen the effectiveness of the
control technology.  If different solvents are used,  the  operation
                              77

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of  -the  fume  incinerator  and  the  activated  carbon units can be
modified to compensate for the changes.

Engineering Aspects of Application

Although no insurmountable problems are anticipated in applying this
control technology, an  engineering  evaluation  will  be  necessary
prior  to  implementation  in  each  plant  in  the solvent recovery
subcategory.  If carbon adsorption should  not  be  effective,  more
sophisticated  processes,  e.g., reverse osmosis, might be necessary
to meet the recommended effluent limitations.  In the  design  of  a
fume  incinerator,  the  engineer must consider the auxiliary energy
requirement, if any, and any potential for production of  toxic  by-
products.   Application of the recommended control technology in the
wet dust collection subcategory has already been widely demonstrated
and no unusual engineering problems should arise.
                                78

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                             SECTION XI

                  NEW SOURCE PERFORMANCE STANDARDS
INTRODUCTION

Defined standards of performance are to be achieved by  new  sources
of  waste  waters.   The  term  "new source" is defined to mean "any
source, the construction of which is commenced after the publication
of proposed regulations prescribing a standard of performance."
In defining performance standards
must be given to:
for  new  sources,  consideration
     a.    Costs and energy requirements,
     b.    Non-water quality environmental impact, and
     c.    Process and other operational changes.

EFFLUENT  QUALITY  ACHIEVED  THROUGH  IMPLEMENTATION  OF  NEW SOURCE
PERFORMANCE STANDARDS

Implementation of New Source Performance standards  will  result  ir
the  recommended  effluent  qualities given in Table 12.  The values
for the solvent  recovery  subcategory  are  the  maximum  allowable
averages  for  30 consecutive days.  Maximum daily values should not
exceed twice the 30-day averages.


Pollutant Constituents

Implementation of  the  new  source  performance  standards  in  the
solvent  recovery  subcategory should reduce all pollutant constitu-
ents to  levels  comparable  to  secondary  treatment  of  municipal
sewage.

IDENTIFICATION OF NEW SOURCE PERFORMANCE STANDARDS

In  the  design  and  operation of new manufacturing facilities, in-
plant controls and end-of-pipe technology will be required  to  meet
the recommended standards.

Textile coating

New  sources  in  the textile coating subcategory should be designed
and built to contain all wastes.  Such  design  and  operation  will
involve  minimal  additional  construction  costs  and only moderate
annual costs.  It is recommended that the collected textile  coating
waste   be   disposed  to  a  sanitary  landfill,  with  or  without
incineration, as appropriate.  If  incineration  must  be  employed,
emissions  will  consist primarily of water vapor and carbon dioxide
and  should  not  create   air   pollution   problems.    Initially,
consideration  should  be given to recovery and reuse of the coating
material instead of incineration or land disposal.
                               79

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                               TABLE  12

              STANDARDS OF PERFORMANCE FOR NEW SOURCES*
  Subcategory


Solvent Recovery

Textile Coating

Vapor Absorption**

Wet Dust Collection**
       COD
 kg/kkgOb/1000 Ib)
of finished asbestos
     product	
 Suspended Solids
kg/kkg(lb/1000 Ib)  of
 finished asbestos
 	  product  ___
PH
      0.150                 0.090                  6-9

        No discharge of process waste water pollutants

        No discharge of process waste water pollutants

        No discharge of process waste water pollutants
*Maximum average of daily values for any period
 of 30 consecutive days.

**Vapor absorption and west dust collection can be
  replaced by non-water contact technologies - see text,
                                  80

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Solvent Recovery

The use of biological treatment  is  recommended  to  meet  the  new
source  performance  standards  in the solvent recovery subcategory.
This end-of-pipe technology may  require  cooling  and  addition  of
supplemental  nutrients,  but is generally the least costly means of
reducing the organic concentrations in the waste water.  If  due  to
presence   of  refractory  organic  materials  this  method  is  not
feasible, carbon adsorption,  reverse  osmosis,  or  other  advanced
treatment technology may be used.  The energy requirements are small
for  bio-treatment,  but  increase  for the more advanced processes.
Solvent recovery provides a means of conserving  material  resources
and  eliminating  air  pollution.   The  benefits  derived  must  be
balanced against the increased use of energy resources.

Vapor Absorption

It is recommended that vapor or fume emissions in all new sources be
either recovered for reuse or as fuel substitutes or be removed from
the exhaust air stream by means  other  than  absorption  in  water.
Several  alternative  technologies that do not generate waste waters
are available.  The costs and energy requirements  for  alternatives
such  as fume incineration will probably be slightly higher than for
a wet scrubber.

Wet Dust Collection

It is recommended that dust, or particulate, emissions  in  all  new
sources  be controlled by baghouses or other, equally effective, dry
collection devices.  These have proven to be somewhat more effective
than  wet  scrubbers  in  this  industry,  and  no  waste  water  is
generated.   The costs and energy requirements are comparable to wet
collection.  The use of dry devices does not create any unusual non-
water quality environmental problems.

Dispersion Process

As noted in Sections IV  and  V  of  this  document,  an  additional
subcategory  may  be  created  if  the dispersion process for making
asbestos yarn becomes operational in this industry.  This process is
now in the developmental stages in two plants in the country and  it
is  known  that waste waters are generated.  The scale of operations
are too  limited  to  permit  definition  of  the  possible  control
technologies  and  standards  of performance for these potential new
sources.  It  can  be  predicted,  however,  that  in-plant  control
measures  to  conserve  water  and  materials as well as end-of-pipe
treatment technology to reduce the organic load;  suspended  solids 9
and,   pos sibly,   heavy  metals,  hexane  extractables,  and  plant
nutrients will  be  required.   The  effluent  limitations  and  the
feasibility  of  "no  discharge"  of  pollutants  will  have  to  be
determined in the future.
                               81

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                            SECTION XII

                          ACKNOWLEDGMENTS
The  Environmental  Protection  Agency  wishes  to  acknowledge  the
contributions  to  the  project of Sverdrup   s Parcel and Associates,
Inc., St. Louis, Missouri.  Dr. James  Buz2ell  and  his  associates
conducted  the  detailed  technical  study  and  drafted the initial
report on which this document is based.

Appreciation is extended to many people in the asbestos  manufactur-
ing  industry, especially those persons with the companies listed in
Table 1 of this document who cooperated in providing information and
data for this study.
A special word of thanks is due the
tives:
following  company  representa-
Mr. Ernest C, Bratt and Mr. Larry E. Moody of Thermoid Division
     of H. K. Porter Company, Inc.

Mr. Issac H. Weaver and Mr. Herman F. Anspach of Raybestos-Manhattan
     Inc.

Mr. W. D. Crawford, Mr. Barney Philpot, Mr. Buel Garden,
     Mr. Sid Faress, and Mr. Robert Briggs of Uniroyal Fiber
     and Textile Division of Uniroyal, Inc.

The   assistance  of  Mrs.  Doris  Fagan  of  the  Asbestos  Textile
Institute, Mr. Brent Farber, Jr., of the Fluid Sealing  Association,
and Mr. E. W. Drislane of the Friction Materials Standards Institute
is also gratefully acknowledged,

Special  mention  and  acknowledgement  is  made  to  those  in  the
Environmental Protection Agency who assisted  in  the  project  from
inception  of  the  study  through  preparation  and  review of this
document: Barbara Wortman, Robert J. Carton, John E.  Riley,  Arthur
MaiIon,  and  Richard  Stevenson-   Acknowledgement  is  made of the
overall guidance and direction provided by  Allen  Cywin,  Director,
Effluent  Guidelines Division and Ernst P. Hall, Deputy Director and
others within the Agency who provided many helpful  suggestions  and
comments.
                                 83

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                            SECTION XIII

                             REFERENCES
1,   Anon., "Asbestos Health Question Perplexes Experts*1, Chemical
           S Engineering News* p. 18, December 10, 1973

2-   Asbestos. Stover Publishing Company, Willow Grove, Pennsylvania

3.   Blecker, H- G., et al., Capital and Operating Costs of
           Pollution Control Equipment Modules, 2 Vols., No.
           EPA-R5-73-023,  (a and b), U.S. EPA, July, 1973

4.   Bowles, O., The Asbestos Industry. U.S. Bureau of Mines,
           Bulletin 552

5.   Clifton, Robert A., "Asbestos", Bureau of Mines Minerals
           Yearbook* U.S. Department of the Interior, 1971

6.   Danielson, J. A. Ed., Air Pollution Engineering Manual.
           U.S. Department of Health, Education and welfare.
           Public Health Service, No. 999-AP-40, Cincinnati, Ohio, 1967

7.   Development Document for Proposed Effluent Limitations Guide-
           lines and New Source Performance standards for the
           Building, Construction, and Paper Segment of the
           Asbestos Manufacturing Point Source Category, No.
           EPA 4*0/1-73/017, U.S. EPA, October, 1973

8.   DuBois, Arthur B., Airborne Asbestos, U.S. Department
           of Commerce, 1971

9-   Handbook of Asbestos Textiles, 3rd Ed., Asbesots Textile
           Institute, Willow Grove, Pennsylvania, 1967

10.  Impact of Proposed OSHA standards for Asbestos, report to
           U.S. Department of Labor by Arthur D. Little, Inc., 1972

11*  Industrial Waste study Report; Flat Glass, Cement, Lime,
           Gypsum, and Asbestos industries, report to Environmental
           Protection Agency by sverdrup Ł Parcel and Associates, Inc.,
           1971

12.  Knapp, Carol E., "Asbestos, Friend or Foe?", Environmental
           Science and Technology, Vol. 4, No. 9, 1970

13.  May, Timothy C., and Lewis, Richard W., "Asbestos", Bureau
           of Mines Bulletin 650« Mineral Facts.and Problems,
           U.S. Department of the Interior, 1970

14.  McCrone, W. C., and Stewart, I. M., "Asbestos", American
           Laboratory, p. 13, April, 1974
                                85

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15.  McDermott, James H. , "Asbestos in Water11, Memorandum to
           Regional Water Supply Representatives, U.S. Environmental
           Protection Agency, April 24, 1973

16.  McDonald, J. Corbett, McDonald, Alison D., Giffs, Graham W. ,
           Siemiatycki, Jack and Rossiter, M. A., "Mortality in the
           Crysotile Asbestos Mines and Mills of Quebec", Archive
           of Environmental Health, Vol. 22, 1971

17.  Measurement of Airborne Asbestos Fiber by the Membrane
           Filter Method* Asbestos Textile Institute, Willow
           Grove, Pennsylvania, 1971

18.  Methods for Chemical Analysis of Water and Wastes.
           Environmental Protection Agency, National Environmental
           Research Center, Analytical Quality Control Laboratory,
           Cincinnati, Ohio, 1971

19.  National Inventory of .Sources and Emissions: Cachnium. Nickel
           and Asbestos, report to National Air Pollution Control
           Administration, Department of Health, Education and
           welfare, by w. E. Davis 6 Associates, 1970

20,  Occupational Exposure to Asbestos - Criteria for a Recommended
           Standard. U.S. Department of Health, Education and
           Welfare, Public Health Service, HSM 72-10267, 1972

21*  Patterson, W. L. and Banker, R. F., Estimating Costs and
           Manpower Requirements for Conventional Wastewater
           Treatment Facilities, Black and Veatch, Consulting
           Engineers for the Office of Research and Monitoring,
           Environmental Protection Agency, 1971

22.  Rosato, D. V., Asbestos;  Its Industrial Applications.
           Reinhold Publishing Corporation, New York, New York, 1959

23.  Sawyer, G. N. and McCarty, P. L,, Chemistry for Sanitary
           Engineers. 2nd Ed., McGraw-Hill Book Company,
           New York, 1967

24.  Selikoff, Irving J., Hammond, E. Cuyler and Seidman, Herbert,
           Cancer Risk of Insulation workers in the United States,
           International Agency for Research on Cancer, 1972

25.  Selikoff, Irving J., Nicholson, William J, and Langer,
           Arthur M., "Asbestos Air Pollution", Archives of
           Environmental Health, Vol. 25, American Medical
           Association, 1972

26.  Sewage Treatment Plant and Sewer Construction Cost Indexes,
           Environmental Protection Agency, Office of Water Programs
           operations. Municipal Wastewater Systems Division,
           Evaluation and Resource Control Branch
                                86

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27.   Sinclair, W. E. , Asbestos. Its Origin. Production and
           Utilization, London, Mining Publications Ltd., 1955

28.   Smith, Robert, Cost of Conventional and Advanced Treatment
           of Wastewaters, Federal Water pollution Control
           Administration, U.S. Department of the Interior, 1968

29.   Smith, Robert and McMichael, Walter F,, Cost and Performance
           Estimates for Tertiary Wastewater Treating Processes.
           Federal Water Pollution control Administration, U.S.
           Department of the Interior, 1969

30,   Standard Methods for the Examination of Water and Wastewater.
           13th Ed., American Public Health Association, Washington,
           D.C., 1971

31.   Sullivan, Ralph J.» Air Pollution Aspects of Asbestos.
           U.S. Department of Commerce, 1969

32.   Tabershaw, I. R., "Asbestos as an Environmental Hazard11,
           Journal of Occupational Medicine. 1968

33-   The Asbestos Factbook, Asbestos, Willow Grove, Pennsylvania,
           1970

34.   Villecro, M,, "Technology, Danger of Asbestos", Architectural
           Forum. 1970

35.   Wright, G. W,, "Asbestos and Health in 1969", American
           Review of Respiratory Diseases. 1969
                                87

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                            SECTION XIV

                              GLOSSARY
Those  terms  in  this document that have special definitions within
the asbestos manufacturing industry or the water  pollution  control
field  are  presented  here  for  the  convenience  of  the  reader.
Technical  terms  not  included  here  are  explained  in   standard
dictionaries.

1-   "Act" - The Federal Water Pollution Control Act Amendments
     of 1972.
2.
3.
5.


6.



7.
 8.
     Absorption - the process of taking up or assimilating a gas
     or a liquid, specifically, the solution of a vapor in water.

     Adsorption - the adhesion in an extremely thin layer of
     molecules to the surfaces of solid bodies, specifically
     activated carbon particles.

     Asbestos - not a distinct mineral species, but a commercial
     term applied to fibrous varieties of several minerals
     differing widely in chemical composition and in fiber
     length, strength, and flexibility.  Varieties include:

           Chrysolite  - a hydrated magnesium silicate that is
           the most abundant and the most important of the
           commercial mineral fibers.

           Crocidolite - a complex silicate of iron, magnesium, and
           sodium that is especially resistant to acid attack.

           Amosite - a ferrous silicate in which some of the iron
           is replaced by magnesium.  It is the longest of all
           asbestos fibers and is more resistant to heat than
           the two varieties above.

     Baghouse - a structure housing tubular or envelope-shaped
     bags that filter dust and particulate matter from an air stream.

     Category and Subcategory - divisions of a particular industry
     possessing different traits that affect waste water charac-
     teristics and treatability.

     Coating - the application of various finishing materials to
     textiles to improve their properties and/or to minimize air
     emissions during fabrication and use.

     Chemical Oxygen Demand  (COD) - an indirect measure of the
     organic material present in a water sample.  Most organic
     compounds are measured in this analysis.
 9.  Dissolved Solids - the amount of material remaining after a
                                89

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     filtered water sample is evaporated to dryness at 103°C.

10.  Doctor Blade - a sharp blade for wiping excess material from
     a surface.

11.  Dust Scrubber - a device for removing particulate matter from
     an air stream by collecting it in water,

12.  Friction Materials - a group of products including brake linings,
     brake blocks, clutch facings, and related items.

13.  Fume Incinerator - an air pollution control device that
     thermally oxidizes combustible aerosols, gases, or vapors,
     sometimes termed an afterburner*

14.  Fume Scrubber - an air pollution control device that removes
     pollutant constituents from an air stream by dissolving them
     in a liquid solvent, specifically water.

15.  Hexane Extractables - materials in a water sample that
     respond to analytical procedures designed to measure grease,
     oil, and similar materials.

16.  MBAS - abbreviation for Methylene Blue Active Substances.
     These are the anionic surfactants, or synthetic detergents.

17.  New Source - any source of waste water, the construction of
     which is commenced after publication of the proposed regula-
     tions prescribing a standard of performance.

IS.  Organic Materials - carbon-containing compounds manufactured in
     the life processes of plants and animals, or synthetically.  They
     can be oxidized to carbon dioxide, water, and other simple inor-
     ganic compounds.

19.  pH - a measure of the relative acidity or basicity of a water.

36.  "Water Quality Criteria 1972," National Academy of Sciences and National
           Academy of Engineering for the Environmental Protection Agency,
           Washington, D.C.  1972 (U.S. Government Printing Office Stock No.
           5501-00520).

20.  Sealing Devices - gaskets, packings, seals, washers, and
     similar items, specifically those that contain asbestos.

21.  Suspended solids - non-filterable solids in a water sample, i.e.,
     those materials not in solution.

22.  Textiles - specifically asbestos yarn, cord, rope, thread, tape,
     wick, cloth, and non-woven felts.

23.  Total Organic Carbon  (TOC) - the result of a high temperature cata-
     lytic oxidation procedure for measuring organic materials in water.
                                90

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                                              TABLE 13
MULTIPLY (ENGLISH UNITS)

     ENGLISH UNIT      ABBREVIATION
acre                    ac
acre - feet             ac ft
British Thermal
  Unit                  BTU
British Thermal
  Unit/pound            BTU/lb
cubic feet/minute       cfm
cubic feet/second       cfs
cubic feet              cu ft
cubic feet              cu ft
cubic inches            cu in
degree Fahrenheit       °F
feet                    ft
gallon                  gal
gallon/minute           gpm
horsepower              hp
inches                  in
inches of mercury       in Hg
pounds                  Ib
million gallons/day     mgd
mile                    mi
pound/souare
  inch (gauge)          psig
square feet             sq ft
square inches           sq in
ton (short)             ton
yard                    yd
           METRIC TABLE

         CONVERSION TABLE

          by                TO OBTAIN (METRIC UNITS)

      CONVERSION   ABBREVIATION   METRIC UNIT
       0.405
    1233.5

       0.252
ha
cu m

kg cal
0.555
0.028
1.7
0.028
28.32
16.39
0.555(°F-32)*
0.3048
3.785
0.0631
0.7457
2.54
0.03342
0.454
,785
1.609
kg cal/kg
cu m/min
cu m/min
cu m
1
cu cm
°C
m
1
I/sec
kw
cm
atm
kg
cu m/day
km
(0.06805 psig +1)*  atm
       0.0929       sq m
       6.452        sq cm
       0.907        kkg
       0.9144       m
hectares
cubic meters

kilogram - calories

kilogram calories/kilogram
cubic meters/minute
cubic meters/minute
cubic meters
liters
cubic centimeters
degree Centigrade
meters
liters
liters/second
killowatts
centimeters
atmospheres
kilograms
cubic meters/day
kilometer

atmospheres (absolute)
square meters
square centimeters
metric ton (1000 kilograms)
meter
* Actual conversion, not a multiplier

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U.S. ENVIRONMENTAL PROTECTION AGENCY (A-107)
WASHINGTON. D.C. 20460
           POSTAGE AND FEES PAID
ENVIRONMENTAL PROTECTION AGENCY
                        EPA-335

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