EPA/530-SW-85-007
May 1985
United States
Environmental Protection
Agency
Washington DC 20460
Office of Solid Waste
Asbestos
Waste Management
Guidance
• Generation
• Transport
• Disposal
-------
Contents
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
Appendix
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
-------
1
Introduction
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
diseases.
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
FOG
BACTERIA
ASBESTOS llength)
i
| i 1 1 1 i
LU
I I II
O.Oi O.I I 10
SIZE RANGE, micromelen
Source; EPA 450/2-78-014, March 1978.
100
1000
-------
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
Hotline:
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
Inhalation
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
exposure.
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
symptom.
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
8
ASBESTOSIS LUNG CANCER MESOTHELIOMA OTHER CANCERS
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
Federal
Regulatory
Programs
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
insulation.
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
Transportation.
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
Product
Friction products
Average
percent
asbestos Binder
50
Various polymers
Dates used
1910-present
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
Asphalt
Phenolic resin
Portland cement
Asphalt
Various polymers
Starches, sodium silicate
Polymers, starches, silicates
Cotton, wool
Portland cement, silicates,
organic binders
Portland cement, silicates
Magnesium carbonate,
calcium silicate
Silicates
Magnesium carbonate,
calcium silicate
1950-present
1900-present
?-present
1930-present
1910-present
?-present
1910-present
1910-present
1910-present
1935-1978
1935-1978
1926-1975
Unknown
1890-1978
Other uses
<50 Many types
1900-present
-------
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.
10
-------
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
friable.
Textile
Products
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.
Insulating
and Decorative
Products
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.
12
-------
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
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
wrap.
14
-------
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.
15
-------
Generation
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
16
-------
Manufacturing
and Fabricating
Asbestos
Products
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;
and
• Pollution control device waste from dust capture
systems.
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."
17
-------
Removal
of Asbestos
Materials
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
buildings.
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).
18
-------
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.
CAUTION
CONTAINS ASBESTOS FIBERS
AVOID OPENING OR BREAKING CONTAINER
BREATHING ASBESTOS IS HAZARDOUS TO YOUR
HEALTH
or
CAUTION
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
MAY CAUSE SERIOUS BODILY HARM
Figure 9.
Negative
air pressure
system.
WINDOWS AND DOORS
COVERED WITH PLASTIC
CLEAN
EXHAUST
DIRTY
ROOM
SHOWER
ROOM
CLEAN ROOM
(LOCKERS)
HEPA FILTERS
19
-------
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
waste.
20
-------
Cleanup
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.
21
-------
Transport
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.
22
-------
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.
23
-------
Disposal
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.
24
-------
Receiving
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.
Waste
Deposition
and Covering
Recognizing the health dangers associated with
asbestos exposure, the following procedures are
recommended to augment current federal
requirements:
• 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
winds.
• 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.
25
-------
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
26
-------
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.
27
-------
6
Costs
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
bags.
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
28
-------
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.
29
-------
Other Sources
of Information
on Asbestos
30
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
USEPA
JFK Federal Building
Boston, MA 02203
(617) 223-4872
Region 2
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
26 Federal Plaza
New York, NY 10007
(212) 264-2611
Region 3
Asbestos NESHAPs Contact
Air Management Division
USEPA
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6552
Region 4
Asbestos NESHAPs Contact
Air, Pesticide & Toxic Management
USEPA
345 Courtland Street N.E.
Atlanta, GA 30365
(404) 881-3067
Region 5
Asbestos NESHAPs Contact
Air Management Division
USEPA
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-6793
Region 6
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
1201 Elm Street
Dallas, TX 75270
(214) 767-9869
Region 7
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2834
Region 8
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
1860 Lincoln Street
Denver, CO 80295
(303) 844-3763
Region 9
Asbestos NESHAPs Contact
Air Management Division
USEPA
215 Fremont Street
San Francisco, CA 94105
(415) 974-7648
Region 10
Asbestos NESHAPs Contact
Air & Toxics Management Division
USEPA
1200 Sixth Avenue
Seattle, WA98101
(206) 442-2724
31
-------
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
USEPA
JFK Federal Building
Boston, MA 02202
(617) 223-0585
Region 2
Regional Asbestos Coordinator
USEPA
Woodbridge Avenue
Edison, NJ 08837
(201) 321-6668
Region 3
Regional Asbestos Coordinator
USEPA
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9859
Region 4
Regional Asbestos Coordinator
USEPA
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 881-3864
Region 5
Regional Asbestos Coordinator
USEPA
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-6879
Region 6
Regional Asbestos Coordinator
USEPA
First International Building
1291 Elm Street
Dallas, TX 75270
(214) 767-5314
Region 7
Regional Asbestos Coordinator
USEPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2838
Region 8
Regional Asbestos Coordinator
USEPA
1860 Lincoln Street
Denver, CO 80295
(303) 837-3926
Region 9
Regional Asbestos Coordinator
USEPA
215 Fremont Street
San Francisco, CA 94105
(415) 454-8588
Region 10
Regional Asbestos Coordinator
USEPA
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-2870
32
------- |