May 1985
United States
Environmental Protection
Washington DC 20460

Office of Solid Waste

Waste Management

•  Generation

•  Transport

•  Disposal

1. Introduction	 1
Description of Asbestos	 1
Identifying Asbestos	3
Health Concerns Related to Inhalation	4
Health Concerns From Ingestion and Contact with
Skin	6
Federal Regulatory Programs	6
2. Quantities and Uses of Asbestos	8
Friction Products	  8
Plastic Products	  9
Cement Pipe and Sheet	10
Paper Products	11
Textile Products	12
Insulating and Decorative Products	12
Pipe Insulation	13
Boilers and Hot Water Tanks	14
Other Uses	14
3. Generation of Asbestos Wastes	16
Mining and Milling	16
Manufacturing and Fabricating Asbestos Products . 17
Removal of Asbestos Materials in Buildings	18
4. Transport of Asbestos Waste	22
Recordkeeping	22
Waste  Handling	22
Waste Transport	23
5. Disposal of Asbestos Wastes	24
Selecting a Disposal Facility	24
Receiving Asbestos Waste	25
Waste  Deposition and Covering	25
Controlling Public Access	26
Recordkeeping	27
6. Costs of Handling Asbestos	28
Other Sources of Information on Asbestos	30
A. U.S. Environmental Protection Agency Regional
Asbestos NESHAPs Contacts	31
B. U.S. Environmental Protection Agency Regional
Asbestos Coordinators 	32
    For sale by the Superintendent of Documents, U.S. Government
           Printing Office, Washington, D.C. 20402

                   The Environmental Protection Agency (EPA) and the
                   Occupational Safety and Health Administration
                   (OSHA) have been concerned with the potential health
                   hazards associated with exposure to asbestos since
                   the early 1970s. The concern is based on medical
                   evidence relating to exposure of airborne asbestos by
                   asbestos workers and their families to various types
                   of cancer as well as noncancerous respiratory
                     In recognition of these health hazards, this manual
                   provides guidance on how best to handle
                   asbestos-containing waste materials during
                   generation, transport, and final disposal. Waste
                   handling practices presented include not only those
                   needed to meet current EPA and OSHA requirements,
                   but also additional recommendations reflecting
                   practices needed to further minimize exposure to
                   asbestos. In most cases, the recommendations are
                   consistent with state-of-the-art procedures currently
                   being followed by most knowledgeable asbestos waste
                   handling firms. However,  because state and local
                   requirements may be more restrictive than federal
                   standards, these agencies should be contacted before
                   handling asbestos containing materials.

Description        Asbestos is a naturally occurring family of fibrous
of Asbestos       mineral substance. The typical size of asbestos fibers,
                   as illustrated relative to other substances in Figure 1,
                   is 0.1 to 10(jL in length,  a size that is not generally
                   visible to the human eye.  Somewhat longer  fibers are
                   used in making textile products. When disturbed,
                   asbestos fibers may become suspended in the air for
                   many hours, thus increasing the extent of asbestos
                   exposure for individuals within the area.

                 EPA regulations identify the following types of
               asbestos: chrysotile, amosite, crocidolite,
               anthophyllite, actinolite, and tremolite. Approximately
               95 percent of all asbestos used in commercial
               products is chrysotile. Asbestos became a popular
               commercial product because it is noncombustible,
               resistant to corrosion, has a high tensile strength,
               and a low electrical conductivity. However, asbestos
               had very little use until the early 1900's when it was
               employed as thermal insulation for steam engines.
               Since then, asbestos fibers have been mixed with
               various types of binding materials to create an
               estimated 3,000 different commercial products.
               Asbestos has been used in brake linings, floor tile,
               sealants, plastics, cement pipe,  cement sheet, paper
               products,  textile products, and insulation. The
               amount of asbestos contained in these  products
               varies significantly, from 1 to 100 percent, depending
               on the particular use.
                 The potential of an asbestos-containing product to
               release fibers is dependent upon its degree of
               friability. Friable means that the material can be
               crumbled with hand pressure and, therefore, is likely
               to emit fibers. The fibrous or fluffy spray-applied
               asbestos materials found in many buildings for
               fireproofing,  insulating, sound proofing, or decorative
               purposes are generally considered friable. Pipe and
               boiler wrap are also friable and found in numerous
               buildings.  Some materials, such as vinyl-asbestos
  Figure 1. Asbestos size comparison with other particles.
                                               FINE SAND
                   ASBESTOS  llength)
                      | i 1 1 1 i
                                                I I II
O.Oi          O.I            I             10
                       SIZE RANGE, micromelen
 Source; EPA 450/2-78-014, March 1978.

                floor tile, are considered nonfriable and generally do
                not emit airborne fibers unless subjected to sanding
                or sawing operations. Other materials, such as
                asbestos cement sheet and pipe, can emit asbestos
                fibers if the materials are subjected to breakage or
                crushing in the demolition of structures that contain
                such materials. For this reason, such materials are
                considered friable under the National Emission
                Standards for Hazardous Air Pollutants (NESHAP)
                regulations for the demolition of structures.

Identifying     Only on rare occasions can the asbestos content in a
AsbestOS       product be determined from product labeling or by
                consulting the manufacturer, since most products as
                placed in use are no longer labeled. A description of
                common asbestos-containing products is presented in
                Section 2 of this manual. Further information on
                asbestos content of consumer products is available
                through the Consumer Product Safety Commission
                 Continental United States   1-800-638-2772
                 Maryland only             1-800-492-8363
                 Alaska, Hawaii, Puerto
                 Rico,  Virgin Islands         1-800-638-8333

                 Positive identification of asbestos requires
                laboratory analysis of samples.  Standard laboratory
                analysis using polarized light microscopy (PLM) may
                cost $30 to $60 per sample. For information on
                locating a laboratory capable of performing the
                analysis, contact any of EPA's Regional Asbestos
                Coordinators listed in Appendix B or call EPA's
                toll-free number for assistance:
                 Continental United States   1-800-334-8571
                                            ext. 6741

                For additional technical information and to obtain
                EPA's publication regarding sampling and analysis of
                asbestos entitled "Guidance for Controlling Friable
                Asbestos-Containing Materials  in Buildings" (EPA
                560/5-83-002), contact any of EPA's Regional Asbestos
                Coordinators listed in Appendix B  or call EPA's toll-
                free TSCA hotline:
                 Continental United States   1-800-424-9065
                 Washington, DC only            554-1404

Health Concerns
Related to
Medical studies of asbestos-related diseases have
revealed that the primary exposure route is
inhalation. Also, the studies suggest that there does
not appear to be a safe level of exposure (e.g., a
threshold) below which there would be no chance of
disease. The exposure may be classified as
"occupational exposure" of workers involved, for
example, in mining, milling, manufacturing,
fabricating, construction,  spraying, or demolition
activities; "paraoccupational exposure" of workers'
families due to asbestos on work clothes taken home;
or "neighborhood exposure" of people living or
working near such operations. The following diseases
can result from inhalation of airborne asbestos fibers:

Asbestosis—A noncancerous respiratory disease that
consists of scarring of lung tissues. Symptoms of
asbestosis include shortness of breath and rales, a
dry crackling sound in the lungs during inhalation.
Advanced asbestosis may produce cardiac failure and
death. Asbestosis is rarely caused by neighborhood

Lung Cancer—Inhaled asbestos particles can produce
lung cancer independent of the onset of asbestosis. In
most lung cancer patients, a cough or a change  in
cough habit is found. A persistent chest pain
unrelated to coughing is the second most common

Mesothelioma—This is a rare cancer of the thin
membrane lining of the chest and abdomen. Most
incidences  of mesothelioma have been traced directly
to a history of asbestos exposure. The earlier in life
that one begins inhaling asbestos,  the higher the
likelihood of developing mesothelioma in later life.
Thus, there is concern over exposure of school
children to asbestos. The common symptoms are
shortness of breath, pain in the walls of the chest, or
abdominal  pain. Mesothelioma is always fatal.

Other Cancers—Some medical studies have suggested
that exposure to asbestos  is responsible for some
cancers of internal organs including the esophagus,
larynx, oral cavity, stomach,  colon, and kidney. It is
theorized that inhaled asbestos fibers are absorbed
into the blood stream and carried to these other parts
of the body.

Symptoms  of asbestos respiratory disease generally do
not appear for 20 or more years after the initial
exposure to airborne asbestos. However, early disease

                   detection is possible by a medical examination
                   including a medical history, breathing capacity tests,
                   and a chest x-ray.
                     Most health risk data pertain to groups of asbestos
                   workers with relatively high exposures. A study of
                   mortality for  17,500 asbestos insulation workers is
                   summarized in Figure 2. The study compares death
                   rates among insulation workers exposed to asbestos
                   and other workers not exposed to asbestos. Based on
                   this and other studies, the National Institute for
                   Occupational Safety and Health (NIOSH) has reported
                   that persons  exposed to asbestos may have 5 times
                   the chance of developing an asbestos- related disease,
                   compared to similar nonexposed persons.
 Figure 2. Expected and observed mortality among asbestos insulation workers.
                                                 OBSERVED DEATHS FOR WORKERS
                                                 EXPOSED TO ASBESTOS
                                                 EXPECTED DEATHS FOR NO
                                                 ASBESTOS EXPOSURE

                   Source: ASTM 834, PCN 04- 834000-17, July 1984.
                   Studies have shown that exposure to asbestos and
                   cigarette smoking combine to create a significantly
                   higher risk of developing an asbestos-related disease.
                   Statistics compiled by NIOSH indicate that a smoker
                   exposed to asbestos may have 50 times the chance of
                   developing lung cancer compared to a nonexposed
                   nonsmoker. Some information suggests that quitting
                   smoking can reduce this high risk.

Health Concerns
from Ingestion
and Contact
with Skin
There have been no conclusive studies to date
indicating that ingestion of asbestos in food or water
may result in health hazards. However, because of
concern that there may be potential health impacts
not yet identified, there are federal regulations
specifying asbestos limitations in ambient water and
in products such as food processing filters.
  With regard to asbestos contact with the skin, there
is currently no evidence to indicate that asbestos
fibers can penetrate the skin tissue. Some workers
have indicated that asbestos fibers irritate the skin
resulting in a  rash similar to that experienced with
handling of other fibrous materials such as fiberglass

EPA and OSHA have major responsibility for
regulatory control over exposure to asbestos.
Emissions of asbestos  to the ambient air are
controlled under Section 112 of the Clean Air Act,
which establishes the National Emission Standards
for Hazardous Air Pollutants (NESHAPs). The
regulations  specify control requirements for most
asbestos emissions, including work practices to be
followed to minimize the release of asbestos fibers
during handling of asbestos waste materials. These
regulations  do not identify a safe threshold  level for
airborne asbestos fibers.  For additional  information
about the NESHAPs regulations for asbestos,  refer to
the Code of Federal Regulations (40 CFR Part 61,
Subpart M).
  The OSHA regulations  are established to protect
workers handling asbestos or asbestos-containing
products. The current  OSHA regulations include a
maximum workplace airborne asbestos concentration
limit of 2 fibers/cc on an 8-hour time weighted
average basis, and a ceiling limit of 10 fibers/cc in
any 15-minute period.  The standard includes
requirements  for respiratory protection and other
safety equipment, and work practices to reduce
indoor dust levels. For details regarding the OSHA
regulations, refer to the Code of Federal Regulations
(29 CFR Part  1910).
  EPA has  implemented a separate regulation under
the Toxic Substances Control Act (TSCA) to handle
the problem of asbestos construction materials  used
in schools. This regulation requires that all schools
be inspected to determine the presence and quantity
of asbestos and that the local community be notified
as well as the  building posted. Corrective actions,
such as asbestos removal or encapsulation, are
currently left to the discretion of the school

administrators. EPA provides technical assistance
under this program through the Appendix B contacts
or the toll-free TSCA hotline: 1-800-424-9065
(554-1404 in Washington, DC).  The specific details of
the TSCA program are contained in the Code of
Federal Regulations (40 CFR Part 763, Subpart F).
  The Asbestos School Hazard Abatement Act of 1984
(ASHAA) establishes a $600 million grant and loan
program to assist financially needy schools with
asbestos abatement projects. The program also
includes the compilation and distribution of
information concerning asbestos, and the
establishment of standards for abatement projects
and abatement contractors. Under this program,
centers to train contractors on asbestos handling and
abatement have been established at the Georgia
Institute of Technology, Atlanta, GA, and are
scheduled to open in June 1985 at both  Tufts
University, Medford, MA, and at the University of
Kansas, Lawrence, KN. Additional information can be
obtained through the toll-free ASHAA hotline:
1-800-835-6700 (554-1404 in Washington, DC).
  Wastes containing asbestos are not hazardous
wastes under the Resource Conservation and
Recovery Act (RCRA). However, because state
regulations can be more restrictive than  the federal
regulations under RCRA, some states may have listed
asbestos-containing wastes as hazardous wastes.
Since this will greatly impact on transportation and
disposal of the waste, the state hazardous waste
agency should be contacted. A list of state hazardous
waste agencies may be obtained by calling the RCRA
hotline: 1-800-424-9346 (382-3000 in Washington,
DC). Current nonhazardous waste regulations under
RCRA pertain to facility siting and general operation
of disposal sites (including those that handle
asbestos). Details concerning these RCRA
requirements are contained in the Code of Federal
Regulations  (40 CFR Part 257).
  Other federal authorities and Agencies controlling
asbestos include:  the Clean Water Act, under which
EPA has set  standards for asbestos levels in effluents
to navigable waters; the Mine Safety and Health
Administration, which oversees  the safety of workers
involved in the mining of asbestos; the Consumer
Product Safety Commission; the Food and Drug
Administration; and the Department of
  State and local agencies may have more stringent
standards than the federal requirements; these
agencies should be contacted prior to any asbestos
removal or disposal  operation.

                Quantities  and  Uses
                of Asbestos
                Asbestos has been mined and used commercially in
                the U.S. since the early 1900s. U.S. consumption of
                asbestos increased to a peak of 800,000 tons per year
                in the early 1970s. Since then, consumption has
                dropped by more than 70 percent. However, much of
                the material originally installed in buildings may still
                be present.
                  The potential existence of asbestos in commercial
                products can be assessed first by understanding the
                physical and chemical characteristics of
                asbestos-containing products and their uses. This
                section describes the appearance, composition,
                friability, use, and market share of the most common
                asbestos-containing products.
                  Table  1 summarizes information on these products,
                many of which are still being manufactured. However,
                because of the recognized health risk, the
                manufacture of a few asbestos products has been
                banned. In addition, the concern of industry for
                exposure of their workers and the public, and the
                increased availability of substitute products, has
                rapidly reduced the use of asbestos.

Friction         Asbestos is used in brake linings for  automobiles,
Products       buses, trucks, railcars, and  industrial machinery, and
                in vehicle or industrial clutch linings.
                Asbestos-containing brake linings include drum
                brake linings, disc brake pads, and brake blocks. In
                the past, asbestos linings have accounted for up to 99
                percent of this market. Friction materials are
                generally tough and  nonfriable, but they release
                asbestos dust during fabrication operations. In
                addition, accumulated dust  in a  brake drum from
                lining wear contains high levels of asbestos. Brake
                installation facilities (e.g., city bus service centers,
                tire and brake shops) may generate significant

              quantities of asbestos waste. Substitute nonasbestos
              brake linings have been developed and are beginning
              to replace asbestos lining in some applications.

Plastic       Plastic products include resilient vinyl and asphalt
Products     floor coverings, asphalt roof coatings, and traditional
              molded plastic products such as a cooking pot handle
              or plastic laboratory sink. The products  in this
              category are usually tough and inflexible. The
              asbestos in these products is tightly bound and is not
              released under typical conditions of use. However, any
              sawing, drilling, or sanding of these products during
              installation or removal would result in the release of
              asbestos dust.
Table 1. Summary of Asbestos-Containing Products
Friction products
asbestos Binder
Various polymers
Dates used
Plastic products
  Floor tile and sheet         20
  Coatings and sealants       10
  Rigid plastics              <50
Cement pipe and sheet       20
Paper products
  Roofing felt                15
  Gaskets                    80
  Corrugated paper pipe wrap  80
  Other paper                80
Textile products             90
Insulating and decorative products
  Sprayed coating            50
  Trowelled coating           70
  Preformed pipe wrap        50

  Insulation board            30
  Boiler insulation            10
      PVC, asphalt
      Phenolic resin
      Portland cement

      Various polymers
      Starches, sodium silicate
      Polymers, starches, silicates
      Cotton, wool

      Portland cement, silicates,
      organic binders
      Portland cement, silicates
      Magnesium carbonate,
      calcium silicate
      Magnesium carbonate,
      calcium silicate




Other uses
<50   Many types

                      Vinyl (linoleum) and asphalt flooring are used in
                    many types of construction. Vinyl-asbestos flooring
                    has about a 90 percent share of the resilient floor
                    covering market. These materials are not friable, and
                    asbestos is released primarily through sawing or
                    sanding operations during installation, remodeling,
                    and removal. Asphalt-asbestos coatings, used
                    primarily as roof sealants, generally remain flexible
                    and nonfriable, but can become friable or brittle as
                    they age.

    Cement Pipe   Asbestos-cement (A-C) pipe has been widely used for
    and Sheet      water and sewer mains, and is occasionally used for
                    electrical conduits, drainage pipe, and vent pipes.
                    Asbestos-cement sheet, manufactured in flat or
                    corrugated panels and shingles, has been used
                    primarily for roofing and siding, but also for cooling
                    tower fill sheets, canal bulkheads, laboratory tables,
                    and electrical switching gear panels. Asbestos-cement
                    products are dense and rigid with gray coloration,
                    unless the  material is lined or coated. The asbestos in
                    these products is tightly bound, and would not be
                    released to the air under typical conditions of use.
                    However, any sawing, drilling, or  sanding of these
                    products during installation or renovation would
                    result in release of asbestos dust. In addition, the
                    normal breakage and crushing involved in the
                    demolition of structures can release asbestos fibers
                    from these materials. For this reason they are subject
                    to the NESHAPs regulation during demolition
                    operations. Also, normal use of A-C pipe for water  or
                    sewer mains has been shown to release asbestos
                    fibers to the  fluid being carried.
                      By the late 1970s, A-C pipe had a 40 percent share
                    of the water main market and a 10 percent share of
                    the sewer main  market. However, since A-C pipe has
                    only been in  existence for 50 years, it only accounts
                    for a small fraction of the total pipe in place in the
                    United States.

Paper        Roofing felts, gaskets, and other paper products are
Products     manufactured on conventional papermaking
              equipment using asbestos fibers instead of cellulose.
              The raw asbestos paper produced in this process has
              a high asbestos content (-85 percent), but is typically
              coated or laminated with  other materials in the final
              product. The asbestos fibers in most paper products
              are sufficiently bound to prevent their release during
              normal product use. Cutting or tearing the material
              during installation, use, or removal would result  in
              the release of asbestos dust.

              Asbestos-containing roofing felt has been widely used
              for application of "built-up" roofs. Built-up roofing is
              used on a flat surface, and consists of alternating
              layers of roofing felt and asphalt. The roofing felt
              consists of asbestos paper, saturated and coated  with
              asphalt. Asphalt-asbestos roofing shingles for
              residential structures, made from roofing felt coated
              with asphalt, were reportedly used  for only a short
              time between 1971 and 1974.
                Other asbestos-containing paper  products  include
              pipeline wrap, millboard,  rollboard, commercial
              insulating papers, and a variety of  specialty papers.
              Pipeline wrap is used to protect underground pipes
              from corrosion, particularly in the  oil and gas
              industry. Millboard and rollboard are laminated paper
              products used in commercial construction such as
              walls and ceilings. Commercial insulating papers are
              used for high temperature applications in the metals

              Figure 3. Corrugated asbestos paper pipe wrap.

                   and ceramics industries, for low-grade electrical
                   insulation, and for fireproofing steel decks in building
                   construction. Corrugated asbestos paper was used for
                   pipe coverings (illustrated in Figure 3), block
                   insulation, and specialty panel insulation. Although
                   these uses have generally been discontinued,
                   significant amounts are typically found in older
                   structures. These products are generally considered
Asbestos yarn, cloth, and other textiles are made
using conventional textile manufacturing equipment.
These materials are used to manufacture
fire-resistant curtains or blankets, protective clothing,
electrical insulation, thermal insulation, and packing
seals. The raw textile products have a high asbestos
content (—85 percent). However, they are typically
coated or impregnated with polymers before assembly
into a final product, which is not required to be
labeled as containing asbestos and typically is not so
labeled. These products may release asbestos dust if
cut or torn, or for some products,  during normal use.
There still remains a significant quantity of
non-coated fabrics in use, especially in schools and
fire departments.
 and Decorative
Asbestos-containing thermal insulation generally
refers to sprayed and trowelled asbestos coatings, and
molded or wet-applied pipe coverings. These materials
generally have an asbestos content of 50 to 80
percent. The coatings were commonly applied to steel
I-beams and decks (illustrated in Figure 4),  concrete
 Figure 4.
 Asbestos spray
 insulation on an
 I-beam and
 steel deck.

                ceilings and walls (illustrated in Figure 5), and hot
                water tanks and boilers. The coatings were applied
                primarily for thermal insulation, although in many
                cases the coating also provided acoustical insulation
                and a decorative finish. Sprayed coatings typically
                have a rough, fluffy appearance, while trowelled
                coatings have a smooth finish and may be covered
                with a layer of plaster or other nonasbestos material.
                Both sprayed and trowelled asbestos coatings are
                considered friable in most applications. Most
                spray-applied asbestos coatings were banned for
                fireproofing/insulating in 1973,  and for decorative
                purposes in 1978.
                  Asbestos insulation board was used as a
                thermal/fireproofing barrier in many types of walls,
                ceilings, and ducts or pipe enclosures. This material
                looks like A-C sheet, but is less dense and much more
                friable. High asbestos dust levels have been measured
                for many board handling operations, including simple
                unloading of uncut sheets.

Pipe           Preformed pipe coverings having an asbestos content
Insulation      °f aDout 50 percent were used for thermal insulation
                on steam pipes in industrial, commercial,
                institutional, and residential applications. This
                product is usually white and chalky in appearance
                and was typically manufactured in 3-foot long,
                half-round sections, joined around the pipe using
                plaster-saturated canvas or metal bands. Typical
                examples of preformed pipe  insulation are illustrated
Figure 5. Sprayed asbestos-containing materials being removed from a
        concrete ceiling.

                     in Figures 6 and 7. This covering was applied on
                     straight pipe sections, while wet-applied coatings
                     were used on elbows, flanges, and other irregular
                     surfaces.  The preformed pipe coverings may be
                     slightly more dense than the insulating coatings, but
                     are still very friable. The installation of wet-applied
                     and preformed asbestos insulations were banned in
                     1975, however, significant amounts are  typically
                     found in older structures.
 Boilers and
 Hot Water Tanks
Preformed block insulation was used as thermal
insulation on boilers, hot water tanks, and heat
exchangers (illustrated in Figure 8) in industrial,
commercial, institutional, and residential
applications. These blocks are commonly chalky
white, 2 inches thick, from 1 to 3 feet in length and
held in place around the boiler by metal wires and/or
expanded metal lath. A plaster-saturated canvas was
often utilized as a final covering or wrap. Asbestos
block insulation is friable and rapidly deteriorates in
a high humidity environment or when exposed to
water. The installation of this type of asbestos
insulation was banned by EPA in 1975.
Other uses of asbestos have included: exterior siding
shingles, shotgun shell base wads, asphalt paving
mix, spackle  and joint patching compounds, artificial
fireplace logs for gas-burning fireplaces, and artificial
snow. The use of asbestos as artificial logs in
                    Figure 6. Preformed asbestos pipe insulation with canvas

gas-burning fireplace systems was banned in 1977,
while the use of asbestos as an ingredient in spackle
and joint compounds was banned in 1978. Asbestos
is still used in oil/gas drilling fluids, added at a
concentration of approximately 1 percent.
Figure 7. Preformed block insulation with canvas wrap on
a pipe.
 Figure 8. Asbestos insulation on a heat exchanger.

                   of Asbestos  Wastes
                   Asbestos-containing wastes are generated by a variety
                   of processes including mining and milling asbestos
                   ore, manufacturing and fabricating asbestos
                   products, and removing asbestos building materials
                   prior to demolition or renovation operations. The
                   recommended methods for handling these wastes are
                   discussed below.
      Mining       Asbestos is "manufactured" by mining the ore deposit
      and Milling   and separating the fibers from the nonasbestos rock.
                   There are currently three active asbestos mines in the
                   U.S., at Copperopolis and Santa Rita, California, and
                   at Hyde Park, Vermont. Seven other mines closed in
                   the 1970s: three in Arizona, two in California, and
                   two in North Carolina. Asbestos mines generate a
                   large quantity of waste rock having insufficient
                   asbestos content for additional processing. This waste
                   is typically piled in an area adjacent to the  mine. The
                   Mine Safety Health Administration enforces asbestos
                   exposure limits for mine workers. For additional
                   information, refer to the Code of Federal Regulations
                   (30 CFR Parts 55-57 and 71).
                     The process of separating asbestos fibers from the
                   mined ore, and grading and packaging these fibers
                   according to length, is called milling. Asbestos mills
                   are located at the mine sites in  Copperopolis and
                   Hyde Park, while the Santa Rita ore is hauled to a
                   mill at King City, California. Asbestos mills generate a
                   large quantity of waste rock, called tailings, that
                   contain residual  amounts of asbestos.  Mills also
                   generate asbestos-containing waste from air cleaning
                   control devices used to meet EPA and OSHA
                   requirements. EPA requires all asbestos-containing
                   wastes from mills to be disposed without any visible
                   emissions to the outside air, or certain wetting
                   practices must be used to control emissions. Tailings

and Fabricating
are usually disposed by loading on a conveyor belt
and dumping on an onsite waste pile. Emission
control during transport and dumping is usually
achieved by wetting, although local exhaust
ventilation may occasionally be  used.

Asbestos products are manufactured by combining
the milled asbestos fibers with binders, fillers, and
other materials. The resultant mixture, which may be
either dry or wet, is molded, formed or sprayed, and
then cured or dried. Some products require further
machining or coating operations prior to their sale.
Manufactured products may then be fabricated by
another manufacturer, or by the installer or final
consumer. Manufacturing and fabricating operations
generate the following asbestos-containing wastes:
• Empty asbestos shipping containers;
• Process wastes such as cuttings, trimmings, and
off-specification/reject material;
• Housekeeping waste from sweeping or vacuuming;
• Pollution control device waste from dust capture

Waste Handling and Containerization
Process wastes and housekeeping waste should be
wetted before packaging using a mixture of surfactant
(e.g.,  soap) and water,  in a fine mist. Empty shipping
bags can be flattened and packaged under hoods
exhausting to a pollution control device. Empty
shipping drums are difficult to  thoroughly clean, and
should be sealed and disposed of or used to contain
other asbestos wastes for disposal. Air pollution
control device waste is  usually packaged directly by
connecting a container to the waste hopper outlet.
Vacuum bags or disposable paper filters should not
be cleaned, but rather should be sprayed with a fine
water mist and placed intact into a proper container.
Additional information on waste handling and
containerization is presented under "Removal of
Asbestos Materials in Buildings."

     of Asbestos
     in Buildings
A significant quantity of asbestos-containing waste
may be generated during removal of friable asbestos
materials from buildings. EPA regulations address the
removal of friable asbestos materials prior to
demolition or renovation of buildings in the Code of
Federal Regulations (40 CFR Part 61, Subpart M).
Removal should also be considered for materials that
may potentially become friable during the demolition
or renovation activities. Currently, the federal
regulations apply to larger structures, i.e., structures
with more than four apartments with certain
minimum quantities of asbestos-containing material.
However, some state and local health agencies require
removal of lesser quantities of asbestos from smaller
  Regulatory requirements of EPA and OSHA include
written advance notice to the regional NESHAPs
contact  (See Appendix A) of the planned removal,
posting of warning signs, providing workers with
protective equipment, wetting friable asbestos
material to prevent emissions, monitoring indoor
dust levels, and properly disposing of
asbestos-containing wastes. It is also highly
recommended that the work area be enclosed through
the use  of plastic barriers to prevent contamination of
other parts of the structure. Guidelines for
development of an asbestos removal contract are
presented in a document entitled "Guide
Specifications for the Abatement of Asbestos Release
from Spray- or Trowel-Applied Materials in Buildings
and Other Structures," published by the Foundation
of the Wall and Ceiling Industry, 25 K Street N.E.,
Washington, DC 20002 (202-783-6580).
  Asbestos removal contractors are encouraged to
employ additional safety procedures beyond the
minimum requirements of EPA and OSHA. The use of
a negative air  pressure system, utilizing fans and
filters to exhaust air from the room, and a
shower/decontamination facility for anyone exiting
the area (as illustrated in Figure 9) is highly
recommended. The air filters used in this system are
high efficiency particulate air (HEPA) filters, rated for
99.97 percent removal efficiency for asbestos-size
dust. These safeguards better protect workers and
prevent contamination of the neighborhood. For
additional information, refer to the EPA document
entitled "Guidance for Controlling Friable Asbestos-
Containing Materials in Buildings," (EPA
560/5-83-002), available from any of the Appendix B
contacts or by calling EPA's toll-free TSCA hotline:
1-800-424-9065 (554-1404 in Washington, DC).

                 Waste Handling and Containerization
                 When the asbestos materials are prepared for
                 removal, they are wetted with a water and surfactant
                 mixture sprayed in a fine mist, allowing time between
                 sprayings for complete penetration of the material.
                 Once the thoroughly wetted asbestos material has
                 been removed from a building component, EPA and
                 OSHA regulations require the wastes to be
                 containerized as necessary to avoid creating dust
                 during  transport and disposal. The generally
                 recommended containers are 6-mil thick plastic bags,
                 sealed in such a way to make them leak-tight. When
                 using plastic bags it is important  to minimize the
                 amount of void space or air in the bag. This will help
                 minimize any emissions should the bag burst under
                 pressure.  More thorough containerization may
                 include double bagging, plastic-lined cardboard
                 containers (illustrated  in Figure 10), or plastic-lined
                 metal containers. Asbestos waste slurries can be
                 packaged in leak-tight  drums if they are too heavy for
                 the plastic bag containers. Both EPA and OSHA
                 specify  that the containers be tagged with a warning
                 label. Either the EPA or OSHA label must be used.

                           CONTAINS  ASBESTOS FIBERS
                           CONTAINS  ASBESTOS FIBERS
                              AVOID CREATING DUST
                        MAY CAUSE SERIOUS BODILY HARM
Figure 9.
air pressure
                     WINDOWS AND DOORS
                     COVERED WITH PLASTIC

                       In situations where pipes or other facility
                     components containing asbestos materials are
                     removed as sections without first removing the
                     asbestos, 6-mil plastic can be used to wrap the
                     section sufficiently to create a leak tight container.
                     There are currently no regulatory requirements that
                     govern the time period that waste  can remain on-site
                     before transport to a disposal site. However,
                     recognizing the health risk and potential liabilities
                     associated with accidental exposure, waste should be
                     guarded (i.e., protected against public access, such as
                     by a fence or in a locked building) and transported as
                     soon as possible.
                     Figure 10. Plastic-lined cardboard container with asbestos

After the asbestos-containing materials have been
removed, all plastic barriers should be removed and
the facility should be thoroughly washed. The plastic
used to line the walls, floors, etc., should be treated
as asbestos waste and containerized appropriately.
Cleanup of asbestos debris may be done with a HEPA
vacuum cleaner. Any asbestos-containing waste
collected by the HEPA vacuum cleaner must be
appropriately bagged, labeled, and disposed.
  All areas of the facility that were potentially exposed
to asbestos fibers should be washed down.  Several
washings  should be performed  along with air
sampling and analysis to assure a low airborne
asbestos fiber concentration. Various regulatory
agencies have targeted asbestos fiber concentrations
in the range of 0.001 to 0.0001 fibers/cc as a level
desirable in the building air after cleanup.  For
example, the State of Arizona has specified 0.001
fibers/cc as a level above which additional cleanup is
required, and British researchers have identified a
level of 0.0001 fibers/cc to be attainable after cleanup.
In some cases, it may not be possible to remove all
asbestos due to the irregularity or porosity of the
subsurface materials. In these situations, it may be
necessary to spray an encapsulating paint  over the
surface to eliminate the potential for fiber release. For
further information on encapsulants, contact any of
the Appendix  B Regional Asbestos Coordinators or
call EPA's toll-free TSCA hotline: 1-800-424-9065
(554-1404 in Washington, DC).

Alternate Handling Techniques
Alternative techniques for removing asbestos
materials  from buildings must receive prior approval
from EPA. To  date, the only alternate technique is by
vacuum truck. Vacuum trucks will be reviewed by
EPA on a case-by-case basis. The one system found to
be acceptable by EPA has demonstrated the capability
of removing asbestos materials in a wet condition.
The asbestos material, contained within the truck as
a slurry, is transported to the final disposal site. The
air from the vacuum intake is dried and exhausted
through a fabric filter located on the truck. Final
filtration of exhaust air is through a HEPA filter.

                   of  Asbestos Waste
                   For the purpose of this manual, transport is defined
                   as all activities from receipt of the containerized
                   asbestos waste at the generation site until it has been
                   unloaded at the disposal site. Current EPA
                   regulations state that there must be no visible
                   emissions to the outside air during waste transport.
                   However, recognizing the potential hazards and
                   subsequent liabilities associated with exposure, the
                   following additional precautions are recommended.

   ReCOrdkeeping Before accepting wastes, a  transporter should
                   determine if the waste is properly wetted and
                   containerized. The transporter should then require  a
                   chain-of-custody form signed by the generator. A
                   chain-of-custody form may include the name and
                   address of the generator, the name and address of the
                   pickup site, the estimated quantity of asbestos waste,
                   types of containers used, and the destination of the
                   waste. The chain-of-custody form should then be
                   signed over to a disposal site operator to transfer
                   responsibility for the asbestos waste. A copy of the
                   form signed by the disposal site operator should be
                   maintained by the transporter as evidence of receipt
                   at the disposal site.
   Waste          A transporter should ensure that the asbestos waste
   Handling       is properly contained in leak-tight containers with
                   appropriate labels, and that the outside of the
                   containers are not contaminated with asbestos debris
                   adhering to the container. If there is reason to believe
                   that the condition of the asbestos waste may allow
                   significant fiber release, the transporter should not
                   accept the waste.  Improper containerization of wastes
                   is a violation of the NESHAPs regulation and should
                   be reported to EPA. A list of NESHAPs contacts is
                   provided in Appendix A.

                 Once the transporter is satisfied with the condition
               of the asbestos waste and agrees to handle it, the
               containers should be loaded into the transport vehicle
               in a careful manner to prevent the breaking of the
               containers. Similarly, at the disposal site, the
               asbestos waste containers should be transferred
               carefully to avoid fiber release.

Waste         Although there are no regulatory specifications
Transport     regarding the transport vehicle, it is recommended
               that vehicles used for transport of containerized
               asbestos waste have an enclosed carrying
               compartment or utilize a canvas covering sufficient to
               contain the transported waste, prevent damage to
               containers, and prevent fiber release. Transport of
               large quantities of asbestos waste is commonly
               conducted in a 20-cubic yard "roll off box, which
               should also be covered. Vehicles that use compactors
               to reduce waste volume should not be  used because
               these will  cause the waste containers to rupture.
               Vacuum trucks used to transport waste slurry must
               be inspected to ensure that water is not leaking from
               the truck.

                   of Asbestos  Wastes
                    Disposal involves the isolation of asbestos waste
                    material in order to prevent fiber release to air or
                    water. Landfilling is recommended as an
                    environmentally sound isolation method because
                    asbestos fibers are virtually immobile in soil. Other
                    disposal techniques such as incineration or chemical
                    treatment are not feasible due to the unique
                    properties of asbestos. EPA has established asbestos
                    disposal requirements for active and inactive disposal
                    sites under NESHAPs (40 CFR Part 61, Subpart M)
                    and specifies general requirements for solid waste
                    disposal under RCRA (40 CFR Part 257). Advance
                    EPA notification of the intended disposal site  is
                    required by NESHAPs.

    Selecting       An acceptable disposal facility for asbestos wastes
    a Disposal      must adhere  to EPA's requirements of no visible
    Facility          emissions to  the air during disposal, or minimizing
                    emissions by covering the waste within 24 hours. The
                    minimum required cover is 6 inches of nonasbestos
                    material, normally  soil, or a dust suppressing
                    chemical. In addition to these federal requirements,
                    many state or local governing agencies require more
                    stringent handling procedures. These agencies
                    usually supply a  list of "approved" or licensed asbestos
                    disposal sites upon request. Solid waste control
                    agencies are listed  in local telephone directories under
                    state, county, or city headings. A list of state solid
                    waste agencies may be obtained  by calling the RCRA
                    hotline: 1-800-424-9346 (382-3000 in Washington,
                    DC). Some landfill owners or operators place special
                    requirements on asbestos waste, such as placing all
                    bagged waste into 55-gallon metal drums. Therefore,
                    asbestos removal contractors should contact the
                    intended landfill before arriving with the waste.

Asbestos Waste
A landfill approved for receipt of asbestos waste
should require notification by the waste hauler that
the load contains asbestos. The landfill operator
should inspect the loads to verify that asbestos waste
is properly contained in leak-tight containers and
labeled appropriately. The EPA should be notified if
the landfill operator believes that the asbestos waste
is in a condition that may cause significant fiber
release during disposal. A list of EPA contacts for
disposal is provided in Appendix A. In situations
when the wastes are not properly containerized, the
landfill operator should thoroughly soak the  asbestos
with a water spray prior to unloading, rinse  out the
truck, and immediately cover the wastes with
nonasbestos material prior to compacting the waste
in the landfill.
and Covering
Recognizing the health dangers associated with
asbestos exposure, the following procedures are
recommended to augment current federal
• Designate a separate area for asbestos waste
disposal. Provide a record for future landowners that
asbestos waste has been buried there and that it
would be hazardous to attempt to excavate that area.
(Future regulations may require  property deeds to
identify the location of any asbestos wastes and warn
against excavation.)
• Prepare a separate trench to receive asbestos
wastes. The size of the trench will depend upon the
quantity and frequency of asbestos waste delivered to
the disposal site. The trenching technique allows
application of soil cover without  disturbing the
asbestos waste containers.  The trench should be
ramped to allow the transport vehicle to back into it,
and the trench should be as narrow as possible to
reduce the amount of cover required. If possible, the
trench should be aligned perpendicular to prevailing
• Place the asbestos waste containers into the trench
carefully to avoid breaking  them. Be particularly
careful with plastic bags because when they break
under pressure asbestos particles can be emitted.
• Completely cover the containerized waste within 24
hours with a minimum of 6 inches of nonasbestos
material. Improperly containerized waste is a violation
of the NESHAPs and EPA should be notified.

                    However, if improperly containerized waste is received
                    at the disposal site, it should be covered immediately
                    after unloading. Only after the wastes, including
                    properly containerized  wastes, are completely covered,
                    can the wastes be compacted or other heavy
                    equipment run over it. During compacting, avoid
                    exposing wastes to the air or tracking asbestos
                    material away from the trench.

                    •  For final closure of an area containing asbestos
                    waste, cover with at least an additional 30 inches of
                    compacted nonasbestos material to provide a 36-inch
                    final cover. To control erosion of the final cover, it
                    should be properly graded and vegetated. In areas of
                    the U.S. where excessive soil erosion may occur or the
                    frost line exceeds three feet, additional final cover is
                    recommended.  In desert areas where vegetation would
                    be difficult to maintain, 3-6 inches of well graded
                    crushed rock is recommended for placement on top of
                    the final cover.

   Controlling      Under the current NESHAPs regulation, EPA does not
   Public Access    require that a landfill used for asbestos disposal use
                    warning signs or fencing if it meets the requirement
                    to cover asbestos wastes. However, under RCRA, EPA
                    requires that access be controlled to prevent exposure
                    of the public to potential health and safety hazards at
                    the disposal site. Therefore, for liability protection of
                    operators of landfills that handle asbestos, fencing
                    and warning signs are  recommended to control  public
                    access when natural barriers  do not exist. Access to a
                    landfill should be limited to one or two entrances with
                    gates that can be locked when left unattended.
                    Fencing should be installed around the perimeter of
                    the disposal site in a manner adequate to deter  access
                    by the general public. Chain-link fencing, 6-feet high
                    and topped with a barbed wire guard, should be used.
                    More specific fencing requirements may be  specified
                    by local regulations. Warning signs should be
                    displayed at all entrances and at intervals of 330 feet
                    or less along the property line of the landfill or
                    perimeter of the sections where asbestos waste is
                    deposited. The sign should read as follows:

                            ASBESTOS WASTE DISPOSAL SITE
                               BREATHING ASBESTOS DUST
                         MAY CAUSE LUNG DISEASE AND CANCER

ReCOrdkeeping  For protection from liability, and considering possible
                 future requirements for notification on disposal site
                 deeds, a landfill owner should maintain
                 documentation of the specific location and quantity of
                 the buried asbestos wastes. In addition, the estimated
                 depth of the waste below the  surface should be
                 recorded whenever a landfill section is closed. As
                 mentioned previously, such information should be
                 recorded in the land deed or other record along with a
                 notice warning against excavation of the area.

of Handling  Asbestos
                  The costs of handling asbestos waste are highly
                  variable. This variability is largely due to the range in
                  handling practices, from those required to achieve
                  minimal compliance with regulations to the use of
                  extra safety precautions not required by law.
                  However, to help avoid being charged inflated fees for
                  asbestos handling, all cost data should be compared
                  by considering a detailed description of the work
                  practices associated with each estimate.
                    Costs for disposal of containerized asbestos waste
                  are not well documented. A few disposal sites using
                  special handling techniques have quoted fees ranging
                  from $5 to $50 per cubic yard (about four 55-gallon
                  containers). Other sites may not accept asbestos
                  waste. Costs of hiring a waste hauler for transport of
                  containerized asbestos waste depends on the quantity
                  of waste and distance to an approved disposal site.
                  Also, transportation charges may vary based on the
                  degree of containerization, because rigid containers
                  generally require less careful handling than plastic
                    The overall cost for removal of friable asbestos from
                  buildings, including transport and disposal,  generally
                  varies from $2 to $10 per square foot. About  the same
                  price range applies per linear foot for pipe insulation.
                  Since this is a complicated handling operation, prices
                  are highly dependent on each contractor's work
                  practices. Higher prices are charged for safeguards
                  that reduce the potential for exposure of building
                  occupants, such as: (1) continuous fiber level
                  monitoring, (2)  use of "negative air pressure" systems,
                  (3) special cleanup and air testing at job completion,
                  and (4) treating stripped porous surfaces with
                  encapsulants. Other than dust control methods,  the
                  greatest factor affecting cost is usually the nature of
                  the asbestos-coated surface. For example, a smooth

concrete ceiling is much more easily stripped than a
corrugated metal deck. The cost of asbestos removal
generally includes the price of waste hauling and
disposal, but this should be confirmed on a
case-by-case basis.

  Other Sources
  of Information
  on Asbestos
Brandner, W., Asbestos Exposure Assessment in
  Buildings Inspection Manual, EPA Region 7,
  Kansas City, Missouri, October 1982.

The Foundation of the Wall and Ceiling Industry,
  Washington, DC, Guide Specifications for the
  Abatement of Asbestos Release Jrom Spray-or
  Trowel-Applied Materials in Buildings and Other
  Structures, December 1981.
Kim, K. S., and D. E. Kuivinen, Assessment of
  Potential Exposure to Friable Insulation Materials
  Containing Asbestos, NASA Technical
  Memorandum 81435, April 1980.
Levadie, B., ed., DefinitionsJor Asbestos and Other
  Health-Related Silicates, ASTM, Philadelphia,
  Pennsylvania. ASTM Special Technical Publication
  834, PCN 04-834000-17, July 1984.

Natale, A., and H.  Levins, Asbestos Removal and
  Control, Source Finders and Information Corp.,
  Voorhees, NJ, 1984.
Piper, S.  and M. Grant, NESHAPs Asbestos
  Demolition and Renovation Inspection Report,
  GCA Corporation, Bedford, MA, under EPA
  Contract No. 68-02-3961, August 1984.
U.S. Department of Commerce, National Bureau of
  Standards, Guidelines Jor Assessment and
  Abatement of Asbestos-Containing Materials in
  Buildings, Center for Building Technology,
  Washington, DC, NBSIR-83-2688, May 1983.
U.S. Department of Health, Education and Welfare,
  Asbestos Exposure,  National Cancer Institute,
  Bethesda, Maryland, DHEW Publication No. (NIH)
  78-1622, May 1978.
U.S. Environmental Protection Agency,
  Asbestos-Containing Materials in School
  Buildings: A Guidance Document, Parts  1 and 2,
  Office of Toxic Substances, Washington, DC, EPA
  450/2-78-014, March 1979.
U.S. Environmental Protection Agency, Guidance/or
  Controlling Friable Asbestos-Containing Materials
  in Buildings, Office of Pesticides and Toxic
  Substances, Washington, DC, EPA 560/5-83-002,
  March 1983.
U.S. Occupational Safety and Health Administration,
  Preliminary Regulatory Impact and Regulatory
  Flexibility Analysis of the Proposed Revisions to
  the Standard for Regulating Occupational
  Exposure to Asbestos, PB84-198225, 30 March 1984.

Appendix  A
 U.S. Environmental Protection Agency
Regional Asbestos NESHAPs Contacts

(For information on NESHAPs rule compliance and disposal)
Region 1
Asbestos NESHAPs Contact
Air Management Division
JFK Federal Building
Boston, MA 02203
(617) 223-4872

Region 2
Asbestos NESHAPs Contact
Air & Waste Management Division
26 Federal Plaza
New York, NY 10007
(212) 264-2611

Region 3
Asbestos NESHAPs Contact
Air Management Division
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6552

Region 4
Asbestos NESHAPs Contact
Air, Pesticide & Toxic Management
345 Courtland Street N.E.
Atlanta, GA 30365
(404) 881-3067

Region 5
Asbestos NESHAPs Contact
Air Management Division
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-6793

Region 6
Asbestos NESHAPs Contact
Air & Waste Management Division
1201 Elm Street
Dallas, TX 75270
(214) 767-9869
Region 7
Asbestos NESHAPs Contact
Air & Waste Management Division
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2834

Region 8
Asbestos NESHAPs Contact
Air & Waste Management Division
1860 Lincoln Street
Denver, CO 80295
(303) 844-3763

Region 9
Asbestos NESHAPs Contact
Air Management Division
215 Fremont Street
San Francisco, CA 94105
(415) 974-7648

Region 10
Asbestos NESHAPs Contact
Air & Toxics Management Division
1200 Sixth Avenue
Seattle, WA98101
(206) 442-2724

               Appendix  B
                U.S. Environmental Protection Agency
                Regional Asbestos Coordinators

                (For information on asbestos identification, health effects,
                abatement options, analytic techniques, monitoring, asbestos in
                schools, and contract documents)
               Region 1
               Regional Asbestos Coordinator
               JFK Federal Building
               Boston, MA 02202
               (617) 223-0585

               Region 2
               Regional Asbestos Coordinator
               Woodbridge Avenue
               Edison, NJ 08837
               (201) 321-6668

               Region 3
               Regional Asbestos Coordinator
               841 Chestnut Street
               Philadelphia, PA 19107
               (215) 597-9859

               Region 4
               Regional Asbestos Coordinator
               345 Courtland Street, N.E.
               Atlanta, GA 30365
               (404) 881-3864

               Region 5
               Regional Asbestos Coordinator
               230 S. Dearborn Street
               Chicago, IL 60604
               (312) 886-6879

               Region 6
               Regional Asbestos Coordinator
               First International Building
               1291 Elm Street
               Dallas, TX 75270
               (214) 767-5314
Region 7
Regional Asbestos Coordinator
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2838

Region 8
Regional Asbestos Coordinator
1860 Lincoln Street
Denver, CO 80295
(303) 837-3926

Region 9
Regional Asbestos Coordinator
215 Fremont Street
San Francisco, CA 94105
(415) 454-8588

Region 10
Regional Asbestos Coordinator
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-2870