EPA 440/l-74/035


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


    TEXTILE, FRICTION MATERIALS

        AND SEALING  DEVICES
             Segment of the

    ASBESTOS MANUFACTURING

         Point Source Category
 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

               AUGUST 1974

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             DEVELOPMENT  DOCUMENT

                      for

   PROPOSED EFFLUENT LIMITATIONS GUIDELINES

                      and

       NEW SOURCE PERFORMANCE STANDARDS

                    for the

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

                 James L. Agee
     Assistant Administrator for Water and
              Hazardous Materials

                      _ito •'«*.
                   Allen  Cywin
     Director,  Effluent Guidelines  Division

                Richard T.  Gregg
                 Project  Officer
                 August,  1974
          Effluent  Guidelines Division
     Office of Water and Hazardous Materials
      U. S. Environmental  Protection Agency
            Washington, D. C.  20460

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                              ABSTRACT


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

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

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

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

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                         TABLE OF CONTENTS
SECTION

    I     Conclusions

   II     Recommendations

  III     Introduction

               Purpose and Authority                        ^
               Summary of Methods                           °
               General Description of the Industry          B
               Location of Manufacturers                    j^
               Manufacturing Processes                      ^
               Textile Products                             ^
               Friction Materials
               Gaskets, Packing, and Sealing Devices        23
               Current Status  of the Industry               24

    IV     Industry  Categorization                           25

               Introduction  and Conclusions                 25
               Factors  Considered                           25

     V     Water  Use and Waste  Characterization             29

                Textile  Coating                             29
                Solvent  Recovery                            30
                Vapor Absorption                            31
                Wet Dust Collection                         31
                Dispersion Process                           32
                Plant Descriptions                           32

    VI     Selection of Pollutant Parameters                37

                Major Pollutants                            37
                Other Pollutants                            39

   VII     Control and Treatment Technology                 47

                Introduction                                ^7
                In-Plant Control Measures                   48
                Treatment Technology                        49
                Industry Suhcategories                      50
                             iii

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SECTION                                                    PAGE

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

               Representative Plants                        53
               Cost Information                             55
               Control Technologies with Costs              ^6
               Energy Requirements of Control Technologies  "•*•
               Non-Water Quality Aspects of Control
                 Technologies                               65

   IX     Effluent Reduction Attainable Through             67
            Application of the Best Practicable Control
            Technology Currently Available - Effluent
            Limitations Guidelines

               Introduction                                 67
               Effluent Reduction Attainable Through
                 the Application of Best Practicable
                 Control Technology Currently Available     67
               Identification of Best Practicable
                 Control Technology Currently Available     ^9
               Rationale for the Selection of Best
                 Practicable Control Technology
                 Currently Available                        7^

    X     Effluent Reduction Attainable Through             73
            Application of the Best Available
            Technology Economically Achievable -
            Effluent Limitations Guidelines

               Introduction                                 73
               Effluent Reduction Attainable Through
                 Application of the Best Available
                 Technology Economically Achievable         73
               Identification of Best Available
                 Technology Economically Achievable
               Rationale for the Selection of Best
                 Available Technology Economically
                 Achievable                                  76

   XI     New Source Performance Standards                   79

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

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SECTION



  XII     Acknowledgments                                     83




 XIII     References                                          85




  XIV     Glossary                                            89



          Conversion Table                                    91

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                              FIGURES



NUMEER                                                     PAGE

  1       As"bestos Textiles Manufacturing Operations         16

  2       Dry-Mixed Molded Brake Linings Manufacturing
            Operations                                       ]_g

  3       Wet-Mixed Molded Brake Linings Manufacturing
            Operations                                       20

  ^       Molded Clutch Facings Manufacturing Operations     21

  5       Woven Clutch Facings Manufacturing Operations      22

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                              TABLES


                                                           PAGE
NUMBER                                                     	

  1       Locations of Asbestos Manufacturing Plants -       ^
            Phase II

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

  3       Representative Manufacturing Plants Used in
            Developing  Cost Estimates

  U       Water Effluent Treatment Costs - Asbestos          ^
            Textile  Coating

   5       Water Effluent Treatment Costs -  Solvent
   '                                                          Do
            Recovery

   6      Water Effluent Treatment Costs - Vapor
             Absorption

   7       Water Effluent Treatment Costs - Wet Dust
             Collection - Small Plant

   8       Water Effluent Treatment Costs - Wet Dust
             Collection - Medium Plant

   9       Water Effluent Treatment Costs - Wet Dust          ^
             Collection - Large Plant

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

  11       Effluent  Reduction Attainable Through
             Application of Best Available  Technology
             Economically Achievable                          74

  12        Standards of Performance for New Sources           80
                               vii

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                             SECTION I

                            CONCLUSIONS


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

The subcategories are for the following operations:

      1.    coating, or finishing, of  asbestos textiles,

      2.    Solvent recovery,

      3.    Vapor  absorption, and

      4.    Wet  dust collection.

The waste waters  resulting  from the  first   three  subcategories   are
similar  in that the primary pollutants are synthetic organic resins,
elastomers,   and/or   solvents,  but   they   differ  in composition and
concentration.    The  wastes  from   the wet  dust  collectors   are
characterized  by high   suspended   solids  levels.    For  all  sub-
categories,   the   volume and   strength  of  the  waste  waters   are
independent   of  the  level  of  production  in the manufacturing plant,
and raw  waste loads  and  effluent  limitations  guidelines  cannot  be
meaningfully expressed in terms of  production units.

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

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

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                             SECTION II

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

The   recommended  effluent  limitations  for  parameters  of  major
significance and standards of performance for plants within the four
subcategories are summarized as follows:
Best Practicable Control Technploqy Currently Available
COD-mg/1
Suspended Solids-
mg/1
pH-units
Textile
Coating

 zero
 zero
                                 Solvent     Vapor
                                 Recovery  Absorption
                         Wet Dust
  50
  30

 6-9
 zero
 zero

 6-9
   NA*
   30

  6-9
        Best Available Technology EconomicallY Achievable
COD-mg/1
Suspended Solids-
mg/1
pH-units
Textile
Coating

 zero
 zero
Solvent     Vapor
Recovery.  AbsorjDtion

   5        zero
   5        zero

 6-9         	
             Wet Dust
            Collection

             zero
             zero
            Standards of Performance for^New sources

                                 Solvent     Vapor
COD-mg/1
Suspended Solids-
mg/1
pH-units
Textile
Coating

 zero
 zero
  50
  30

 6-9
zero
zero
 Wet Dust
Collection

 zero
 zero
      *NA - Not Applicable

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                            SECTION III

                            INTRODUCTION
PURPOSE AND AUTHORITY

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

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

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

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

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

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

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

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Sources of Data

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

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

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

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

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

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

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tionnaire indicated that no process waste waters  are  generated  in
their operations.

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

GENERAL DESCRIPTION OF THE INDUSTRY

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

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

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

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                         QUESTIONNAIRE FORM
Company Name _.

Plant Address
Name of Contact at Plant 	

Telephone Number at Plant 	

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

Number of Employees 	

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


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

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

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

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

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

     other  (please describe)

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 INDIVIDUAL PLANT QUESTIONNAIRE

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

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

           Vinyl-Asbestos Floor Tile                      19.2%
           Asbestos-Cement Pipe                           18.7
           Paper and Felt, including Roofing              14.7
           Friction Materials                             10.7
           Asbestos-Cement Building
             Materials                                     6.7
           Packing Materials                               3.3
           Textiles                                        2.9
           Asbestos Insulation                             2.1
           Spray-on Asbestos Materials                     2.0
           All Other Asbestos Products                    19.0
                                                         100.0%

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

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

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

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

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

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

           Gaskets, seals, washers, and packings that contain asbestos,

LOCATION OF MANUFACTURERS

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

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                                            TABLE 1

State
Alabama
California
Connecticut
Georgia
Illinois
Indiana
Kentucky
Massachusetts
Michigan
LOCATIONS OF ASBESTOS
City
Prattville
Fullerton
Stratford
Hogansville
Glenwood
Waukegan
Crawfordsville
Logansport
New Castle
Warsav
Danville
Lawrence
North Brookfield
Hartford
Saginaw
St . Joseph
Trenton
MANUFACTURING PLANTS - PHASE II
Company
Molded Industrial Friction Corp.
Raybestos-Manhattan
Raybestos-Manhattan
Uniroyal, Inc.
Jas . Walker Packing Company , Inc .
Johns-Man vi lie
Raybestos-Manhattan
National Friction Products Corp.
World Bestos Company
Gatke Corporation
Royal Industries Brake Products
Auto Friction Corporation
Gatke Corporation
Auto Specialties Manufacturing Co.
General Motors Corporation
Auto Specialties Manufacturing Co.
Chrysler Corporation

Products
FM
FM
*FM, S
*T
S
*S
FM
FM
FM
FM
FM
FM
FM, T, S
FM
*FM
FM
*FM
New Hampshire
Meredith
Amatex Corporation

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                   TABLE 1 (cont)




LOCATIONS OF ASBESTOS MANUFACTURING PLANTS - PHASE II
State
New Jersey







New York

North Carolina


Ohio




Pennsylvania






City
Cranford
Man ville
Newark
New Brunswick
North Brunswick
Patterson
Trenton
Trenton
Green Island
Palmyra
Charlotte
Laurinberg
Marshville
Boydsville
Chagrin Falls
Dayton
Dayton
Paulding
Ambler
Manheim
Norristown
North Wales
North Wales
Philadelphia
Ridgway
Company
Chempro , Inc .
Johns -Manvi lie
Reddaway
Metallo Gasket Company
Johns -Manvi lie
Brassbestos Manufacturing Corp.
Mercer Rubber Company
Thiokol Chemical Corporation
Bendix Corporation
Garlock , Inc .
H. K. Porter, Inc.
Johns-Man ville
Raybestos-Manhattan
Wheeling Brake Block Mfrg. Company
Hollow Center Packing Company , Inc .
General Motors
General Motors
Maremont Corporation
Nicolet
Raybestos-Manhattan
Amatex Corporation
Atlas Textile Company
Greene, Tweed & Company
Asten-Hill Manufacturing Company
Carlisle Corporation
Products
S
,y. m
*T
FM
S
S
FM
S
FM
*FM
T, S
T
FM
T
FM
S
*FM
*FM
FM
*T, S
FM, T, S
T
T
S
T
FM

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                                        TABLE 1 (cont)

                     LOCATIONS OF ASBESTOS MANUFACTURING PLANTS - PHASE II
State
South Carolina
Tennessee
Texas
Virginia
City
Bennetsville
North Charleston
Cleveland
New Port
Houston
Houston
Houston
Winchester
Company
H. K. Porter, Inc.
Raybestos-Manhattan
Bendix Corporation
Detroit Gasket & Manufacturing Co.
Lamons Metal Gasket Company
Standee Industries
Standee Industries
Abex Corporation
Products
T
T
FM
S
S
FM
S
FM
KEY:  FM - Friction Materials
       S - Sealants (Gaskets, Packings,  Etc.)
       T - Textiles

     *Waste waters from manufacture of products  not  covered by this  study are  more
      significant at these plants.

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

MANUFACTURING PROCESSES

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

TEXTILE PRODUCTS

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

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

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

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

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                                            RAYON, COTTON
                                            OR OTHER FIBER
CARDED
1 TWISTING 1^-



TWISTING
WISTED ROPE
1 BRAIDING 1
BRAIDED
ROPE
MIXI



L_^
1
NG —


ING |— —
NG
k
SPINNING
SINGLE 1
1
T
k

r
r>

, U


— ^NON-WOVEN FELTS
LIGHT GAUGE WWE


PLIED YARNS METALLIC YARNS
i i


1COATWG L_ DRYING .^.TREATED

I^-WASTE WATER
TWISTING l^-TWISTED CORD
                  BRAIDING
                                     WEAVING
                   ^
  I       T      I      I      I      I
BRAIDED  BRAIDED  BRAIDED  TAPE  WOVEN  CLOTH
TUBING   CORD   ROPE         TUBING
                                                          SOLVENT
                                                 COATING
                                            CLOTH
                                                   t
                                                                 ..TREATED
                                                                  FABRIC
                                            •WASTE WATER
FIGURE  1-ASBESTOS  TEXTILE  MANUFACTURING OPERATIONS
           (From handbook of Asbestos Textiles )
                            16

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         basic  component of several other asbestos textile products.


         ^

          Li^
Erection to pla" tne  yarn together and form a braided product.

Asbestos  yarn  can also be twisted or braided into various shapes to
form packing and gaskets.  The braided material can  be  impregnated
5iS PdiffSren?  compounds.   Graphite is commonly used *° impregnate
braided  packing  material,   the graphite   serves  to   lower   the
frictional and  binding  properties of the packing.

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

Asbestos yarn or  cloth may be coated for  fabrication   into   friction
 rollers, brushes, or doctor blades.  The coated textile product then
 passes through a drying oven where the solvent is evaporated.


 Water Usage

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

 Operating  Schedule

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

 FRICTION MATERIALS

 Molded Products

 The  manufacturing   steps typically used  in J*^£* ^i*6*^6
 linina manufacture  are  shown  in   Figure  2.   The  bonding  agents,
 me^alliS  constituents ,   asbestos   fibers,  and additives are weighed
 and mixed in a  two- stage mixer.  The mix  is then  hand-tamped into   a
 metal  mold.   The   mold  is  placed in  a  preforming  press which
 partially cures the molded asbestos sheet.  The   asbestos  sheet  is
 laken  from the preforming press,  and put in  a steam  PFehJa^n?J^d
 to soften the resin in the molded  sheet.  The molded  sheet is  formed
 to the proper arc by a steam heated arc  former,  which  resets  the
 resin.  The arc-formed sheets are  then  cut  to the  proper size.  The
 lining  is  then  baked in compression  molds  to  retain the arc shape
                                17

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

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

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

H°.Y££ Products

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

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RAW MATERIALS
STORAGE
PROPORTIONING


                           MIXING


PREFORMING
PRESS
COOLING WATER STEAM
•fck


                         | PREHEAT |   >COOL,NG WATER
     COOLING WATER
STEAM
                'CONDENSATE
                        ARC FORMER |
                                     ^•COOLING WATER
              ^•CONDENSATE


   CUTTING ^•^•DUST
                             r
                      COMPRESSION MOLD
                        BAKING OVEN
                         INSPECTION
                         PACKAGING
                          STORAGE
                          CONSUMER
FIGURE 2-DRY-MIXED BRAKE LINING MANUFACTURING OPERATIONS
                            19

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                            RAW MATERIALS
                                STORAGE
                            PROPORTIONING
                                MIXING


GRINDING
SCREENS
                              TWO-ROLL
                               FORMING
                               CUTTING
                            ARC FORMING
                              AIR DRYING
                             DRYING OVEN
                              FINISHING
                                                  SOLVENT
SOLVENT
   A


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

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 COOLING WATER
                       RAW MATERIALS
                         STORAGE
                       PROPORTIONING
STEAM
                     TWO-ROLL FORMING
                       (SHEETER MILL)
                       COOLING WATER

                       CONDENSATE
                      [ROTARY CUTTER J
| EXTRUSION MACHINE] \

1
fcUTTING | '

1
                                           (RECYCLED SOLIDS)
 IPUNCH PRESS
                                      .J
                                           SOLVENT
                       {DRYING OVEN j
                                           SOLVENT
                         BAKING OVEN
                          FINISHING
                      DUST
                          INSPECTION
                          PACKAGING
                           STORAGE
                             4-
                          CONSUMER
FIGURE 4- MOLDED CLUTCH FACINGS MANUFACTURING OPERATIONS
                            21

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


INSPECTION
PACKAGING
STORAGE
I	
DUST
                       CONSUMER
FIGURE 5-WOVEN CLUTCH FACINGS MANUFACTURING OPERATIONS
                         22

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

Figure 5 illustrates the manufacture of woven clutch  facings.   The
treated  fabric is cut into tape-width strips by a slitting machine.
The strips are wound around a mandrel to form a roll of the  fabric.
The  roll  is  pressed  in a steam-heated press and then baked in an
oven to cure the resin in the clutch facing.  Following curing,  the
clutch facing is finished, inspected, and packaged.

Water Usage

Water does not mix with the ingredients of friction materials and is
not used in the manufacturing processes.  Waste waters are generated
in  a  few  friction materials plants in solvent recovery operations
and in wet dust collection equipment used to control the quality  of
the  air from the finishing areas.  Most plants in this industry use
dry dust collection equipment.

Operating Schedule

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

GASKETS, PACKING, AND SEALING DEVICES

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

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

Water Usage

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

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


                               23

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

Operating Schedule

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

CURRENT STATUS OF THE INDUSTRY

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

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

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                             SECTION IV

                      INDUSTRY CATEGORIZATION
INTRODUCTION AND CONCLUSIONS

In developing  effluent  limitations  guidelines  and  standards  of
performance  for  new  sources  for a given industry, a judgment was
made by  EPA  as  to  whether  different  effluent  limitations  and
standards  were  appropriate  for different segments (subcategories)
within the industry.  The factors considered in determining  whether
such  categories  were  justified  for  this  part  of  the asbestos
manufacturing industry were:

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

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

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

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

FACTORS CONSIDERED

All of the factors listed above are briefly  discussed  below,  even
though most of them did not serve as bases for categorization.
                                25

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 Product

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

 Raw Materials

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

 Manufacturing Process

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

Characteristics and Treatability of Waste Waters

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

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

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

Ai£ Pollution Control Eguipment

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

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

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

Plant Size

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

Plant Age

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

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Geographic Location

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

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                             SECTION V

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

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

For each of the subcategories in  this  industry,  the  waste  water
characteristics  are described below.  In all cases, the quantity of
water used cannot be directly related to the  level  of  production,
and  raw  waste  loads  cannot  be  expressed in terms of production
units.  Because only a small  number  of  plants  generate  process-
related  waste  waters,  the  data base is not large.  Each plant is
unique and the information presented here is based on all data  that
are available about these waste waters.

TEXTILE COATING

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

Water Usage

The volume of waste generated in the coating of asbestos textiles is
estimated  to be no more than 750 liters  (200 gallons)  per day.  The
coating of asbestos textiles is not presently a full-time  operation
at  either  of  the  two  plants.   The waste results from dumps and
cleanup at the end of a run.  The number  and  length  of  the  runs
varies  on  a  typical  day,  making  the  quantity of waste largely
independent of the quantity of textile  treated,  or  the  level  of
production.
                               29

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Waste Characteristics

Coated  asbestos  textiles  are used in a variety of products; e.g.,
pipe lagging, paper machine felts, ironing board covers,  etc.   One
of the purposes of coating is to encase the fibers, thereby reducing
the  potential  health  hazards  in  fabricating and using the final
products.  The coating has additional functions and its  composition
is normally specified by the fabricator.  Consequently, the chemical
constituents  of the coating material, and subsequently those of the
waste water, vary at each of the plants.   The  ingredients  include
resins, elastomers, pigments, solvents, and fillers.  The wastes are
high  in COD and suspended and dissolved solids.  In addition to the
organic components, trace quantities of  heavy  metals,  phosphates,
and fluorides may be present.

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

SOLVENT RECOVERY

Waste  waters  are  known  to  be  generated  in  solvent   recovery
operations at two plants in this industry.

Water Usage

The quantity of waste water from solvent recovery operations varies,
depending  upon  the  type and the size of the equipment.  A typical
value is 38,000 liters (10,000 gallons) per day for  this  industry.
The  discharge is normally steady and, since it is a function of the
activated carbon regeneration process, it cannot be directly related
to the level of production in the plant.

Waste Characteristics

The waste waters from solvent recovery units  may  contain  residual
solvent  and/or  other  organic materials that are either evaporated
from the product or generated during the recovery  operations.   The
suspended solids level is normally very low, and the waste water may
have  an  elevated temperature.  Typical waste water characteristics
from one solvent recovery operation are as follows:

                    BOD  (5-day)            1125 mg/1
                    COD                    1930 mg/1
                    Suspended Solids          0 mg/1

The waste waters from this plant are discharged  with  the  sanitary
wastes  to the municipal sewerage system.  The waste waters from the
other known plant that recovers solvent  are  combined  with  larger
volumes of industrial waste waters  (covered in the Phase I report on
the asbestos industry) for treatment prior to discharge to a surface
water.   The BOD of the combined, treated effluent from the plant is
less than 20 mg/1.  There are plans  at  this  plant  to  completely
recycle all process-related waste waters.
                               30

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VAPOR ABSORPTION

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

Water Use

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

Waste Characteristics

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

WET DUST COLLECTION

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

Water Usage

The water use rate in wet dust collectors varies from  0.06  to  1.3
liters per second per cubic meter per minute of air scrubbed  (0.5 to
10 gpm per 1000 scfm).  The plant air systems that are served by wet
scrubbers  that discharge waste waters from the plant property range
from 280 to 1700 cubic meters per minute (10,000  to  60,000  scfm),
resulting  in waste water discharges of from 190 to 570 cubic meters
(50,000 to 150,000 gallons)  per day.   The  units  that  incorporate
recirculation discharge a settled slurry.  In addition, the contents
of  the  settling  tank are dumped, usually once per week.   As noted
above, the wastes are discharged to a settling lagoon in  all  known
cases.

W§ste Characteristics

The  waste  waters  from the wet dust collectors are slurries of the
dust emenating from the grinding and  drilling  operations  used  in


                             31

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finishing  friction  products.   The principal parameter for charac-
terizing the wastes is suspended solids.  Because friction materials
are specifically designed to shed water, it  is  unlikely  that  the
dust is solubilized to any measurable degree.  The COD test provides
a convenient means of detecting and monitoring this phenomenon if it
is suspected.

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

DISPERSION PROCESS

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

Water Usage

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

Waste Characteristics

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

PLANT DESCRIPTIONS

Forty-five  manufacturing plants representing 30 different companies
or corporations were contacted directly in this study.   Information
was  collected  from  six additional plants through a questionnaire.
This coverage is believed to include better than 80 percent  of  all
the  plants  that  are  properly  within the two SIC classes, and it
represents an accurate picture  of  this  segment  of  the  asbestos
manufacturing  industry.   A  total  of  ten  plants were found that
                             32

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discharge process-related waste waters.  These plants are  described
individually in Table 2.

In  reviewing  Table  2, it should be noted that the discharges from
the two plants using the dispersion process for making asbestos yarn
are included, even though these operations are experimental and  not
yet  classified as subcategories of this industry.   Of the remaining
eleven waste  streams,  seven  result  from  air  pollution  control
equipment   and   only   four   from  manufacturing  and  associated
operations.
                                33

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                                                      TABLE 2
                                 GENERAL DESCRIPTION OF KNOW WASTE WATER SOURCES
                                     ASBESTOS MANUFACTURING PLANTS - PHASE II
       Plant
        Product
                                        Waste Water Source    Treatment Provided
                                               Effluent Discharged To
co
A       Textiles

B       Textiles

B       Textiles

C       Textiles

D       Textiles


D       Sheet Gasketing

E       Friction Materials

F       Friction Materials

G       Friction Materials

H       Friction Materials
Coating

Coating

Fume Scrubber

Dispersion Process

Dispersion Process


Solvent Recovery

Dust Scrubber

Dust Scrubber

Dust Scrubber

Dust Scrubber
None

Two-Stage Lagoon

Two-Stage Lagoon

Filtration

None/Lagoon


Lagoon

Lagoon

Sedimentation

Two-Stage Lagoon

Lagoon
Municipal Sewer

Municipal Sewer

Municipal Sewer

Municipal Sewer

Municipal Sewer/
 Surface Water

Surface Water

No Discharge

Surface Water

Surface Water

Surface Water

-------
                                                 TABLE 2 (cont)


                                GENERAL DESCRIPTION OF KNOWN WASTE WATER SOURCES

                                    ASBESTOS MANUFACTURING PLANTS - PHASE II
      Plant
Product
Waste Water Source
Treatment Provided
Effluent Discharged To
CO
cn
        I       Friction Materials


        I       Friction Materials


        J       Friction Materials
                  Solvent Recovery


                  Dust Scrubber


                  Dust Scrubber
                      None


                      Lagoon


                      Chemical Precipitation

                       with Other Wastes
                            Municipal Sewer


                            No Discharge


                            Surface Water

-------
                             SECTION VI

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

           COD (or TOC)
           Suspended Solids

           PH
           Temperature
           BOD
           Dissolved Solids
           Heavy Metals
           Phenols
           Nitrogen
           Phosphorus

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

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

MAJOR POLLUTANTS

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

                Demand

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

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


                               37

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

Suspended Solids

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

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

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

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

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


                               38

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

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


OTHER POLLUTANTS

ESx Acidity and Alkalinity

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

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

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

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

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


                              39

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

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

 Temperature

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

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

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

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

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


                             40

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

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

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

When  water temperatures increase, the predominant algal species may
change from diatoms to green algae, and finally at high temperatures
to blue-green algae, because of species  temperature  preferentials.
Blue-green  algae  can  cause serious odor problems.  The number and
distribution of benthic organisms decreases  as  water  temperatures
increase  above  90°F, which is close to the tolerance limit for the
population.  This could seriously affect certain fish that depend on
benthic organisms as a food source.
                                               r
The cost of fish being attracted to heated water  in  winter  months
may  be  considerable,  due to fish mortalities that may result when
the fish return to the cooler water.

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

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

Biochemical Oxygen Demand  jBQD)

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

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waste waters  are  not  readily  biodegradable,  however,   and  will   not
respond  in  the test.

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

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

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

Dissolved Solids

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

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

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

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

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

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

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

Heavy. Metals

Some  of  the additives used in the textile coating subcategory con-
tain heavy metals.  The raw wastes should  be  monitored  for  those
metals that are contained in the raw materials.

Phenols

The  waste  waters  from one solvent recovery operation are known to
contain about 12 mg/1 of phenol.  This material is derived from  the
material   used  to  impregnate  woven  friction  materials  and  is
evaporated from the product  in the drying oven.  Since  phenols  are
especially  troublesome  in  receiving  waters,  this  parameter  is
included for use, as appropriate.
                             43

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

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

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

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

Nitrogen

The nitrogen levels in  the  waste  waters  from  the  subcategories
covered  here  are  not  known  to be significantly high.  Nitrogen-
containing compounds are used as additives in  the  textile  coating
formulations,  however,  and  the nitrogen level of the waste waters
should be evaluated.

Phosphorus

Like nitrogen, there are no reliable data as to phosphorus levels in
the wastes in this  part  of  the  asbestos  industry.    Phosphorus-
containing  materials  are  used  in  small  amounts  in the textile
coating formulations, and  the  use  of  this  parameter  should  be
evaluated.

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

When  a  plant  population is stimulated in production and attains a
nuisance status,  a  large  number  of  associated  liabilities   are


                               44

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

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

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                            SECTION VII

                  CONTROL AND TREATMENT TECHNOLOGY
INTRODUCTION

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

Treatment

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

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

Implementation

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


                              47

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

 IN-PLANT CONTROL MEASURES

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

 Raw Material  Storage

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

 5?lSi® Water Segregation

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

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

 Housekeeping  Practices

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

 Water Usage

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

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

TREATMENT TECHNOLOGY

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

Technical Considerations

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

Application

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

Land Requirements

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

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

Compatibility of control Measures

In  some  categories,  the  Level I technologies  (1977) are based on
treatment to reduce the pollutants to  acceptable  levels  prior  to
discharge,  while  the  Level II technologies  (1983) involve substi-
tution of equipment so that no waste water is  generated.   The  two
levels  are incompatible in that the money spent in implementing the
Level I controls is lost when the Level II controls  are  installed.
Whether  to  stop  at  Level  I  or  move  directly to Level II is  a


                                49

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management decision for each plant.  Since half of the plants  known
to  be  generating  process  waste waters now discharge to municipal
sewerage systems, the decision takes on added dimensions.

INDUSTRY SUBCATEGORIES

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

Asbestos Textile Coating

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

Solvent Recovery

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

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

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

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

Vapor Absorption

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

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

Wet Dust Collection

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

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

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                            SECTION VIII

            COST, ENERGY, AND NON-WATER QUALITY ASPECTS


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

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

REPRESENTATIVE PLANTS

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

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

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

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                  TABLE 3

REPRESENTATIVE MANUFACTURING PLANTS USED IN
         DEVELOPING COST ESTIMATES
               Waste Water Flow
              cu m/day      mgd

                0.8       0.0002

               38         0.01

              230**       0.06**
     Subcategory

Textile Coating

Solvent Recovery

Vapor Absorption

Wet Dust Collection:

     Small

     Medium

     Large


     * NA - Not Applicable

    ** Total discharge per operating period.
190
380
570
0.05
0.10
0.15
 Exhaust Air Flow
cu m/min     scfm
  NA*

  NA

 570
   NA

   NA

20,000
                                       280       10,000

                                       850       30,000

                                      1700       60,000
               54

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COST INFORMATION

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

Investment Costs

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

Capital Costs

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

Depreciation

Straight-line depreciation was used in all cases.  The periods  used
were  believed  to  be typical for the particular technology and are
indicated in the footnotes on Tables 4 through 9.

Operation and Maintenance costs

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

Ener CJY and Power Costs

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

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 CONTROL TECHNOLOGIES WITH COSTS

 The  estimated  costs  and  the associated  reduction   benefits   for  the
 alternative  control  technologies  for  each  of  the subcategories  are
 presented below.
     ile Coating  (Table  U)

Alternative A -  No Waste Treatment  or Control

Effluent waste load is  a very  small volume of  concentrated   organic
material   (COD)  and  suspended   solids with potentially significant
levels of  heavy  metals  and plant  nutrients.  The waste  is discharged
on about half of the plant operating days.

           Costs.  None.
                 •
           Reduction Benefits.  None

Alternative B -  Zero Discharge

Discharge  of waste water  is   eliminated  through   in-plant   control
measure,   including  the use of dry cleaning methods and containment
of dumped  and spilled coating  material.  Waste is containerized   for
salvage  by  commercial waste  salvage firm or for disposal in a  con-
trolled sanitary landfill.  Some  in-plant control measures are   now
in   use, e.g., minimizing dumps,  but no plant completely retains all
waste.

           Costs.  Investment  cost  is approximately $2,000.

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

Solvent Recovery (Table 5)

Alternative A - No Waste Treatment  or Control

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

           Costs.  None.

           Reduction Benefits.   None.

Alternative B - Biological Treatment

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

           Costs.  Investment costs are approximately $73,000.
                              56

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                              TABLE h
                           TYPICAL PLANT
                  WATER EFFLUENT TREATMENT COSTS
                      ASBESTOS MANUFACTURING
                     ASBESTOS TEXTILE COATING
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation
  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
               (Costs in $1000)
                  A	B

                            2.0
                            0.2

                            0.2*

                            8.0

                            Zero

                            8.4
Effluent Quality:



  Effluent Constituents

  COD - mg/1

  Suspended Solids - mg/1

  pH - units

          * Expected Lifetime
   Raw
  Waste
  Load

 Variable

 Variable

 Variable

10 years.
Resulting Effluent
      Levels
Variable

Variable

Variable
Zero

Zero
                              57

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                              TABLE 5

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

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost


Effluent Quality:
  Effluent Constituents
  (Costs in $1000)
A       B         C
       73



        5.9

        2.9*
11.7

10.5**
       12.5      20.6

       11.0       1.0***

       32.3      1*3.8
  BOD (5-day) - mg/1

  COD - mg/1

  Suspended Solids - mg/1

  pH - units
     *  Expected lifetime - 25 years
    **  Expected lifetime - lU years
   ***  Not including carbon regeneration.
Raw
Waste
Load
1200
2000
30
6-9
Resulting Effluent
Levels
1200
2000
30
6-9
30
50
30
6-9
5
5
5
6-9
                              58

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

Alternative C - Carbon Adsorption

This alternative involves treating the effluent from the bio-treatment
process in 2-stage granular activated carbon columns.  The carbon
is regenerated off-site by the supplier.  Costs for filtration
of the bio-treatment process effluent are not included.  The daily
effluent waste load is estimated to be less than 0.2 kg  (0.4 Ib)
for both COD and BOD.

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

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

Vapor Absorption (Table 6)

Alternative A - No Waste Treatment or Control

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

           Costs.  None.

           Reduction Benefits.  None.

Alternative B - Carbon Adsorption

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

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

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

Alternative C - Zero Discharge

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

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

           Reduction Benefits.  Reduction of all pollutant


                              59

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                              TABLE 6

                           TYPICAL PLANT
                  ¥ATER EFFLUENT TREATMENT COSTS
                      ASBESTOS MANUFACTURING
                         VAPOR ABSORPTION
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
           (.Costs in $1000)
         A       B         C
                130
                  152
                 10.H      12.2

                  9-3*     15.2**


                  8.7       1.8

                  1.0***   16.8

                 29. U      1*6.0
Effluent Quality:



  Effluent Constituents

  COD - mg/1

  Suspended Solids - mg/1

  pH - units
 Raw
Waste
Load

1800

  30

  >9
    Resulting Effluent
         Levels
1800

  30

  >9
 50

 30

6-9
Zero

Zero
          *  Expected lifetime - 1^ years
         **  Expected lifetime - 10 years
        ***  Not including carbon regeneration.
                             60

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             constituents of 100 percent.

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

Alternative_A - No Waste Treatment or Control

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

           Costs.  None.

           Reduction Benefits.  None.

Alternative B - Sedimentation

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

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

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

Alternatiye^c - Zero Discharge

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

           Costs.  Estimated investment cost is $94,000.

           Reduction Benefits.  Reduction of all pollutant
             constituents of 100 percent.
ENERGY REQUIREMENTS OF CONTROL TECHNOLOGIES

The energy requirements to implement the control technologies in the
asbestos  textile  coating  subcategory  are  minimal   and   relate
primarily  to transportation of the containerized waste to a salvage
facility or a sanitary landfill site.

The additional energy required in the solvent recovery category will
also involve energy for transportation of waste sludge away from the
plant and of activated carbon to  and  from  the  site.   The  major
energy  requirements  will  be  for pumping and aeration in the bio-
treatment unit and for regeneration of the activated carbon columns.
The former requirement is estimated to be about 7.5 kw (1C hp).  The


                               61

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                              TABLE 7

                           TYPICAL PLANT
                  WATER EFFLUENT TREATMENT COSTS
                      ASBESTOS MANUFACTURING
                 WET DUST COLLECTION - SMALL PLANT
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost


Effluent Quality:
  Effluent Constituents

  COD (Filtrate) - mg/1

  Suspended Solids - mg/1

  pH - units
          *  Expected lifetime - 25 years
         **  Expected lifetime - 20 years.
  (Costs in $1000)
A       B         C
        3.5       3.k

        1.8*      1.7**


        7.7       k.3



       17.0       9.U
Raw
Waste
Load
Unknown
Variable
6-9
Resulting Effluent
Levels
Unknown
Variable
6-9
50
30
6-9
Zero
Zero
^
                              62

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                              TABLE 8

                           TYPICAL PLANT
                  WATER EFFLUENT TREATMENT COSTS
                      ASBESTOS MANUFACTURING
                ¥ET DUST COLLECTION - MEDIUM PLANT
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
             (Costs in $1000)
           A       B         C
                  6k



                   5.1

                   2.6*


                  12.0

                   5-2

                  2k. 9
              9k
               7.5
               6.1
              18.3
Effluent Quality:



  Effluent Constituents

  COD (Filtrate) - mg/1

  Suspended Solids - mg/1

  pH - units
 Raw
Waste
Load
Resulting Effluent
     Levels
Unknown  Unknown   50

Variable Variable  30

  6-9      6-9     6-9
          *  Expected lifetime - 25 years
         **  Expected lifetime - 20 years.
               Zero

               Zero
                              63

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                              TABLE 9

                           TYPICAL PLANT
                  WATER EFFLUENT TREATMENT COSTS
                      ASBESTOS MAMJFACTURING
                 WET DUST COLLECTION - LARGE PLANT
Treatment or Control Technologies:

Investment

Annual Costs:

  Capital Costs

  Depreciation

  Operating and Maintenance Costs
    (excluding energy and power costs)

  Energy and Power Costs

          Total Annual Cost
             (Costs in $1000)
           A       B         C
                  83



                   6.6

                   3.3*


                  16.0

                   6.5

                  32.7
              11.7

               7-3**


               8.5


              27-5
Effluent Quality:



  Effluent Constituents

  COD (Filtrate) - mg/1

  Suspended Solids - mg/1

  pH - units
 Raw
Waste
Load
Resulting Effluent
     Levels
Unknown  Unknown   50

Variable Variable  30

  6-9      6-9     6-9
               Zero

               Zero
          *  Expected lifetime - 25 years
         **  Expected lifetime - 20 years.
                            64

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energy required to regenerate the carbon off-site at the  supplier's
facility  cannot  be  estimated  without  knowing  the  scale of the
operation.  If it is large, the incremental energy required for this
subcategory will not be significant because of the relatively  small
carbon requirements.

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

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

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

NON-WATER QUALITY ASPECTS OF CONTROL TECHNOLOGIES

Air Pollution

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

There are no significant odor problems associated  with  implementa-
tion of the waste water control and treatment technologies.  Neither
are  there any unusual or uncontrollable sources of noise associated
with the control measures.
                              65

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§2iid Waste Disposal

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

There is no known recovery value in any of the  residues  from  this
industry  with the possible exception of use as fuel substitute.  No
data are available by which to evaluate this possibility.
                                66

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                             SECTION IX

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


INTRODUCTION

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

Consideration must also be given to:

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

     b.    energy requirements,

     c.    non-water quality environmental impact,

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

     e.    the processes employed,

     f.    process changes, and

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

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

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

EFFLUENT  REDUCTION  ATTAINABLE  THROUGH   THE   APPLICATION  OF  BEST
PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
                              67

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                              TABLE 10

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

Solvent Recovery

Textile Coating

Vapor Absorption

Wet Dust Collection
 COD
mg/1

 50
zero

 NA
     Suspended Solids
            mg/l            pH

             30            6-9

No discharge of process wastes

            zero           6-9

             30            6-9
*Maximum average of daily values for any period
 of 30 consecutive days.
                                  68

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


Oxygen-Demanding Materials

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

Suspended Solids

Suspended solids are the principal pollutant  constituent   in  waste
waters  from  the  wet  dust collection subcategory.  Application of
control technology  will  reduce  the  suspended  solids  to  levels
comparable  to those achieved in the secondary treatment of  municipal
waste waters.

EH

The  pH  level  of  all waste waters should be  in the neutral range  from
6 to 9  upon application of  this control technology.

IDENTIFICATION   OF  BEST  PRACTICABLE  CONTROL  TECHNOLOGY  CURRENTLY
AVAILABLE

The  Best Practicable Control  Technology  Currently   Available   com-
prises   in-plant measures   for  the textile  coating subcategory and
end-of-pipe treatment  technologies  for the  solvent   recovery,  vapor
absorption, and  wet  dust  collection  subcategories

Textile coating

The   control   technology   comprises  elimination of  discharge    con
tainment of dumped  and spilled  coating materials, dry techniques for
cleaning of equipment  and for housekeeping, and institution of water
conservation  practices to minimize  the volume of  waste.   All wastes
are  containerized for  salvage,  use  as  a  fuel substitute,  or disposal
in  a controlled  sanitary  landfill.   Although this control technology
is   not practiced within  this subcategory,  it is  believed to be  much
less costly than providing treatment  to  render  the  waste waters
 suitable for discharge to a surface water.
                               69

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  Solvent Recovery
  indicates  that  they are amenable to biological treatment

  Vapor Absorption
                                                                   IS
                    = afp^-upi-i-crce control  technology.

Wet Dust Collection

For the wet dust
                             f"bcate?ory, the control  technology

                                                           TECHNOLOGY


 Total Costs of Application
                                                             S
annual costs for all of  the  known manufacturing plants in  thl  ?our
subcategones are estimated  to  be $150,000.

Energy Requirements

The   most   significant   energy  requirement  is   fn«=i   for-  -F» «
xncxneration in the vapor absorption subcaSgSry.    sSce  there  Ts
only  one  known  plant  in  this subcategory,  the additional SnerJv
required 1S not large for the industry as  a  whole     othe?  eneraJ

SSSSTf 8 ' ^^Ude ,th°Se  f°r PUmP±ng °f ^e wlste Satlrs lo the
treatment facilities, for aeration of bio-treatment   processes   and
for  transportation  of  wastes   and activated  carbonf A?l  ol'thSe
                              70

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requirements will not increase the level of energy consumption at  a
typical plant by more than 5 percent.

Non-Water Quality Environmental Impact

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

Size and Age of Equipment and Facilities

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

Processes Employed

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

        Changes

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

Engineering Aspects of Application

Outside  of  the wet dust collection subcategory, this level of con-
trol has not been applied in this  industry.   The  recommended  in-
plant  control  measures and end-of-pipe treatment technologies have
been widely applied in other industrial settings,  however,  and  no
technical  difficulties  are  anticipated.   As noted elsewhere, the
data base for this document is not extensive, and evaluation of each
plant's particular  wastes  is  necessary  before  implementing  any
control   measure.    Of  particular  interest  would  be  the  bio-
degradability of waste waters from solvent recovery  facilities  and
the   sorptive   properties  of  wastes  from  wet  vapor  scrubbing
operations.  The need for coagulation should be  evaluated  for  the
waste waters from wet dust collectors.
                               71

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                             SECTION X

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

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

Consideration must also be given to:

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

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

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

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

Based upon the information contained in Sections III through VIII of
this document, a determination has been made  that  the  degrees  of
effluent  reduction  attainable  through the application of the Best
                             73

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                              TABLE 11
         EFFLUENT REDUCTION ATTAINABLE THROUGH APPLICATION
             OF BEST AVAILABLE TECHNOLOGY ECONOMICALLY
                            ACHIEVABLE*
  Subcategory
Solvent Recovery
Textile Coating
Vapor Absorption
Wet Dust Collection
 COD
mg/1
                                          Suspended Solids
 pH
6-9
        No discharge of process wastes
        No discharge of process wastes
        No discharge of process wastes
*Maximum average of daily values for any period
 of 30 consecutive days.
                                74

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


Oxygen-Demanding Materials

Application of this control technology will reduce the concentration
of oxygen-demanding materials in  the  raw  waste  waters  from  the
solvent recovery subcategory by at least 99.5 percent.

Suspended Solids

The  suspended  solids in the raw waste waters from solvent recovery
facilities  should  be  negligible.   Application  of  this  control
technology  will  not  increase  the  discharge  of suspended  solids
significantly,  although  dissolved  organics  are  converted   into
suspended solids within the biological treatment process employed as
the  first step.

EH

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

IDENTIFICATION OF BEST AVAILABLE TECHNOLOGY  ECONOMICALLY ACHIEVABLE

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

Textile Coating

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

 Solvent Recovery           *

The  control technology is activated carbon treatment of the effluent
 from the biological treatment process identified as  Best Practicable
Technology  Currently  Available.   With proper  operation of the bio-
 treatment unit,  filtration of the effluent  may  not  be  necessary.
 Because of the relatively small scale of the treatment facility,  the
 carbon is regenerated off-site,  probably by the supplier.

 Vapor Absorption

 No  discharge  of  process wastes is achieved in this subcategory by
 use of a fume incinerator to oxidize the vapors in the air exhausted
 from the drying oven.
                                75

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 Wet Dust Collection
 reDlac^°i ^hn^y for the ™* dust  collection  subcategory  is
 replacement  of  the  wet  scrubbers  with  baghouses  or  other dry
 particulate collection devices of equal efficiency.  No was?e  wate?
 is generated with this control technology.

 RATIONALE   FOR   THE   SELECTION   OF   BEST  AVAILART V  T^HMOTrv-v
 ECONOMICALLY ACHIEVABLE                        AVAILABLE  TECHNOLOGY
       Costs of Application


 ^-inT^ry^^

 tnfeSti°Lef^r^uLh\fl??r??o\fnPa0^?ont%rtlUrfaCerLrS'
 S/'SSSS *? BeSt ?aCti""4  ?~"n°?°£  Cu£entlVTailaliee?

 ""charge  tf™nicH sISL?StlS ^^^"^tSufS
 for this control technolSgyeis9eS?imatea'tohbeacloserlntoStJ600 000*
 Jnnf^? *a\, c°mbfned.  cost  f°r  implementation  of  both levels of
 £2£?   technologies is estimated to be  about  $800,000,   with  the
 total annual costs estimated to be about $225,000 for th4  industry.

 Energy Requirements

 Application  of   this  control   technology  will  require  additional
 energy for  carbon regeneration  in the solvent recover^  subcategory
 ?he L~ 11  Subcate9°rv includes only a very small number  of —   Y*

 be%?^alLnr^len^Li^6arthe tota?nergY re^1'«"«t«
                              -co -cne total  energy requirement
Non-Water Quality Environmental Impact
                                         -
                                                 t.,
plants! °  particulates Produced in friction materials manufac?urSg
Size and Ac[e of Equipment and Facilities
fci                and, age  of  the  manufacturing  equipment  and
technology".          influence  the  applicability  of \his control
                               76

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Processes. Employed

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

£E°£J=i2.§ Changes

For  the reason noted in the previous paragraph, application of this
control technology does not  require  any  changes  in  any  of  the
manufacturing  processes  in  any subcategory of this industry.  Any
normal process changes would not lessen  the  effectiveness  of  the
control  technology.  If different solvents were used, the operation
of the fume incinerator  and  the  activated  carbon  units  can  be
modified to compensate for the changes.

Engineering Aspects of Application

Although no insurmountable problems are anticipated in applying this
control  technology,  an  engineering  evaluation  will be necessary
prior to implementation  in  each  plant  in  the  solvent  recovery
subcategory.   If  carbon  adsorption  should not be effective, more
sophisticated processes, e.g., reverse osmosis, might  be  necessary
to  meet  the  recommended effluent limitations.  In the design of  a
fume incinerator, the engineer must consider  the  auxiliary   energy
requirement,  if  any, and the potential for toxic by-products, such
as the generation of phosgene in the burning  of  trichloroethylene.
Application  of  the  recommended control technology in the wet dust
collection subcategory has already been widely  demonstrated  and  no
unusual engineering problems should arise.
                               77

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                             SECTION XI

                  NEW SOURCE PERFORMANCE STANDARDS
INTRODUCTION

Defined  standards  of performance are to be achieved by new sources
of waste waters.  The term "new source"  is  defined  to  mean  "any
source, the construction of which is commenced after the publication
of proposed regulations prescribing a standard of performance".

In  defining  performance  standards  for new sources, consideration
must be given to:

     a.    costs and energy requirements,
     b.    Non-water quality environmental impact, and
     c.    Process and other operational changes.

EFFLUENT QUALITY  ACHIEVED  THROUGH  IMPLEMENTATION  OF  NEW  SOURCE
PERFORMANCE STANDARDS

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


Pollutant Constituents

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

IDENTIFICATION OF NEW SOURCE PERFORMANCE STANDARDS

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

Textile coating

New sources  in the textile coating subcategory   should  be  designed
and  built   to   contain   all wastes.   Such design and operation will
involve minimal  additional  construction  costs   and only  moderate
annual costs.   Added  energy  requirements will be negligible.   If
properly disposed of in a controlled   sanitary   landfill,  this  in-
plant  measure  should not create  any pollution problems.  Initially,
consideration should be given to  recovery  and reuse  of  the   coating
material instead of  land  disposal.
                              79

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                              TABLE 12
             STANDARDS OF PERFORMANCE FOR NEW SOURCES*
  Subcategory
Solvent Recovery
Textile Coating
Vapor Absorption
Wet Dust Collection
 COD
mg/1
 50
     Suspended Solids
     	rng/1            pH
             30            6-9
No discharge of process wastes
     (Subcategory eliminated)
     (Subcategory eliminated)
*Maximum average of daily values for any period
 of 30 consecutive days.
                                80

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Solvent Recovery

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

Va^or Absorption

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

Wet Dust collection

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

Dispersion Process

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

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                            SECTION XII

                          AC KNOWLEDGMENTS


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

Appreciation is extended to many people in the asbestos  manufactur-
ing  industry, especially those persons with the companies listed in
Table 1 of this document who cooperated in providing information and
data for this study.

A special word of thanks is due the  following  company  representa-
tives:

Mr. Ernest C. Bratt and Mr. Larry E. Moody of Thermoid Division
     of H. K. Porter Company, Inc.

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

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

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

A lasting indebtedness is acknowledged  to those in the  Environmental
Protection  Agency  who assisted  in the  project from inception  of  the
study through preparation and  review of this  document.   Especially
deserving recognition are:  Ms.  Bobby Wortman, Robert Carton,  Arthur
Mallon,  and Richard Stevenson.
                                83

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                            SECTION XIII

                             REFERENCES


1    Anon., "Asbestos Health Question Perplexes Experts", Chemical
           R_Engineerina News, p. 18, December 10, 1973

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

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

4.   Bowles, O., The_Asbestos_Industry., U.S. Bureau of Mines,
           Bulletin 552

5.   Clifton, Robert A., "Asbestos", Bureau of Mines_Mjn|rals
           Yearbook, U.S.  Department of the Interior,  1971

6.   Daniel son, J. A. Ed., Air_]PoUjry:oj^Enainee^in3_Manual,
           U.S. Department of Health,  Education and Welfare,
           Public Health Service,  No.  999-AP-40,  Cincinnati, Ohio,  1967

7.   Development Document  for Proposed Effluent Limitations  Guide-
           lines and New Source  Performance Standards  for the
           Building, Construction,  and Paper Segment of  the
           Asbestos Manufacturing  Point Source Category, No.
           EPA  440/1-73/017,  U.S.  EPA, October, 1973

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

 9.   HandbQOk_gf_Asbestos  Textiles , 3rd Ed.,  Asbesots  Textile
            Institute,  Willow Grove, Pennsylvania, 1967

 10.  impact  of  Proposed OSHA^Standards_for_Asbestos ,  report to
            U.S. Department of Labor by Arthur D.  Little, Inc., 1972
 11.  Industriaa^W£ste_S^udv._ReEor^^lat^^
            Gypsum, and Asbestos Industries, report to Environmental
            Protection Agency by Sverdrup & Parcel and Associates, Inc.,
            1971

 12.  Knapp, Carol E. , "Asbestos, Friend or Foe?", Environmental
            science and Techno logy. Vol. 4, No. 9, 1970

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

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

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15.  McDermott, James H. , "Asbestos in Water", Memorandum to
           Regional Water Supply Representatives. U.S. Environmental
           Protection Agency, April 2U, 1973

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

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

1 8 •  Methods for Chemical Analysis of Water and Wastes ,
           Environmental Protection Agency, National Environmental
           Research Center, Analytical Quality Control Laboratory,
           Cincinnati, Ohio, 1971
19 •  National Inventory of Sources and Emissions; Cadmium,,
           and Asbestos, report to National Air Pollution Control
           Administration, Department of Health, Education and
           Welfare, by W. E. Davis S Associates, 1970
20 •  Occupational Exposure to Asbestos - Criteri^a_   __
           Standard, U.S. Department of Health, "Education and
           Welfare, Public Health Service, HSM 72-10267, 1972

21.  Patterson, W. L. and Banker, R. F. , Estimating costs and
           Manpower Requirements for convent- inn a i wac+oMa-i-OT-
           Treatment Facilities. Black and Veatch, Consulting
           Engineers for the Office of Research and Monitoring,
           Environmental Protection Agency, 1971

22.  Rosato, D. V., Asbestos:  Its Industrial Appli cat ions r
           Reinhold Publishing Corporation, New York, New York, 1959

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

24.  Selikoff, Irving J., Hammond, E. Cuyler and Seidman, Herbert,
           Canc^r_Rj^^f_^^j^ti^n_Wprkers_in_the United States.
           International Agency for Research on Cancer, 1972

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

2 6 .  Sewage Treatment Plant and Sewer Construction Cost Indexes ,
           Environmental Protection Agency, Office of Water Programs
           Operations,  Municipal Wastewater Systems Division,
           Evaluation and Resource Control Branch
                               86

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

28   Smith, Robert, £v^*_of_cgnventional and Advanced_Treatment
           of wastewaters. Federal Water Pollution Control
           Administration, U.S. Department of the Interior, 1968

29.  Smith, Robert and McMichael, Walter F. , Cost and_,Performance
           Estimates for Tertiary Was tewater Treating Processes ,
           Federal Water Pollution control Administration, U.S.
           Department of the Interior, 1969
30   Standard M^hn^s fQr the ExaminatiQn_Qf_Water_and_Wastewater,
     -- 13th Ed.,"American Public Health Association, Washington,
           D.C., 1971

31.  Sullivan, Ralph J. , Air_Pollution_As£ects_of .Asbestos,
           U.S. Department of Commerce, 1969

32.  Tabershaw, I. R., "Asbestos as an Environmental Hazard",
           journal of Occupational Medicine , 1968

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

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

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

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                            SECTION XIV

                              GLOSSARY


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

1.   "Act" - The Federal Water Pollution Control Act Amendments
     of~~1972.

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

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

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

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

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

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

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

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

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

  8.  Chemical Oxygen Demand  (COD)  -  an indirect measure  of the
     organic material  present  in a water sample.  Most  organic
     compounds  are measured  in this  analysis.

  9.  Dissolved  Solids  -  the  amount of  material  remaining after  a
                              89

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      filtered water sample  is  evaporated to dryness at 103C.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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                                             TABLE  13
MULTIPLY (ENGLISH UNITS)

     ENGLISH UNIT      ABBREVIATION
acre                    ac
acre - feet             ac ft
British Thermal
  Unit                  BTU
British Thermal
  Unit/pound            BTU/lb
cubic feet/minute       cfm
cubic feet/second       cfs
cubic feet              cu ft
cubic feet              cu ft
cubic inches            cu in
degree Fahrenheit       °F
feet                    ft
gallon                  gal
gallon/minute           gpm
horsepower              hp
inches                  in
inches of mercury       in Hg
pounds                  lt>
million gallons/day     mgd
mi 1e                    nri
pound/square
   inch  (gauge)          psig
square feet            sq ft
square inches           sq in
ton  (short)            ton
yard                    yd
          METRIC TABLE

        CONVERSION TABLE

         by                TO OBTAIN (METRIC UNITS)

     CONVERSION   ABBREVIATION   METRIC UNIT
      0.405
   1233.5

      0.252
ha
cu m

kg cal
0.555
0.028
1.7
0.028
28.32
16.39
0.555(°F-32)*
0.3048
3.785
0.0631
0.7457
2.54
0.03342
0.454
3,785
1.609
kg cal/kg
cu m/min
cu m/min
cu m
1
cu cm
°C
m
1
I/sec
kw
cm
atm
kg
cu m/day
km
(0.06805 psig +1)*  atm
       0.0929
       6.452
       0.907
       0.9144
 sq  m
 sq  cm
 kkg
 m
hectares
cubic meters

kilogram - calories

kilogram calories/kilogram
cubic meters/minute
cubic meters/minute
cubic meters
1i ters
cubic centimeters
degree Centigrade
meters
liters
liters/second
killowatts
centimeters
atmospheres
kilograms
cubic meters/day
kilometer

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

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