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ENVIRONMENTAL PROTECTION AGENCY
llebly to "';•'
Ann of: OAQPS, CPDD, SIB , Ddt: June 22, 1973
Addition to Guidelines Series OAQPS No. 1.2-004, EPA Source Promulga-
tion _-r Rojcord'iocpinn and^Reportinn - Public Availibiiity of Data, March 14,
T8"/3.
To: Se.e Below
A computer program has been developed by the National Air Data Branch
(NADB), Monitoring and Data Analysis Division (MDAD), to provide the
Regional Offices with assistance in implementing the Federal regulation
prolongation for recordkteping and reporting and public availability of
emission d<->to. This program was written in an effort to supply the infor-
mation cHsu'SoCci on pages 7 and 8 of the above mentioned Guidelines docu-
ment. This infonnstion may also be used in dete'rmining those sources to
be contacted for recordkceping and reporting'requirements. An example of
the printout is enclosed showing the information that can be obtained for
soul c^. uy "cnij prugrLiru
The confuted omissions are .the actual emissions referred to in the
Guidelines document as of the year of record. Since emission factors
are often used to estimate emissions, NEDS has the computed emissions
broken down as to the type of process of source category (Source Classi-
fication C>;;',:.:>). In scr;.3 cases, two different source types r,ay be vented
through ll"1 s?"i? stack (point), es in the enclosed nrintcut. Unfortunately,
MCS is r,;'. ;it up -'.c pr:vv;': tivic, SL:, :- b,-ICKL';,.;: fcr "allcwccl emissions",
i.e., the emissions'allowed under the a'-r^oved control strategy. Thus,
the allov;ed emissions when avai uiblo : -'•. ypressed on a per stack basis,
even though the allowed emissions rr.us ce determined on source catagcry
basis. It should be noted that tn-2 allowed emissions and tre applicable
regulations under the approved control strategy have not generally been
ciiU-i cd •' . ....: ..ZC3 sys L^L'I as yet and ,;ill hav~ i^, be entered by i'ii/J
in the iiVLC'i'im.
The printout may be obtained by writing to Jacob Supers, riA!iQ.,
Mutual Enlding, Research Triangle Park, North Carolina 27711, or by
calling £"L -C,^-02S5. Tl'tis infori.iaticn cannot be accessed i!.-:;1. ' t!:i;
computer terminals at the regional offices at this time. The (,'c th
Carolina fc'cility is in the process of changing ccr;utcrs. 7V;. 'h.-nra
should bs crrplctcd by Doccrber 1973. Access throi.rh the R-sgi'-r.a"; Office
co'riNuter t-^imls will be iride ov?il:ble et that tirs if tl-c- (.'"/ J ''^r
information \'arro,nts it. It is important to specify the areas to .
considered in any requests for data. These rray be requested bv EPA
region; State; State-county; State-county-nlant; State-county.-p'iant-po-
orAQCR.
.j
G. Edmi'sten, Chief
Standards Implementation. Branch
Control F;: ;~^ars
DC- •:.lcp,',.int Division
V"
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Addressees:
Regional Administrators, Regions I - X , . .,
Director, Division of Air and 1,'ater Programs, Regions' I - X (3)"
Principal Air Contacts, Regions I - X (3)
R. h'ilson (5)
B. Steigerwald
J. Schuoncrnan '
R. Neligan
0. Padgett
R. Baum
D. Goodwin ' f"
J. Harrjiierle /"
J. Bosch
0. Suvr.ors
SIB Personnel
/ '
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July 1973
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INSPECTION MANUAL FOR THE
• ENFORCEMENT OF NATIONAL EMISSION
• STANDARDS FOR ASBESTOS
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m TIMOTHY R. OSAG
GILBERT H. WOOD
• GEORGE B. CRANE
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
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• ENVIRONMENTAL PROTECTION AGENCY
• OFFICE OF AIR QUALITY PLANNING AND STANDARDS
ENGINEERING SERVICES BRANCH
I DOCUMENT DEVELOPMENT SECTION
JULY 1973
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TABLE OF CONTENTS
Page
I LIST OF FIGURES 1v
• LIST OF TABLES v
1. INTRODUCTION 1"1
• 1.1 PURPOSE OF DOCUMENT 1"1
1.2 GOVERNMENT AGENCIES THAT REGULATE ASBESTOS EMISSIONS }~2
I 1.3 ASBESTOS EMISSION STANDARDS 1-4
• 1.3.1 Intent of Standards !'4
1.3.2 Asbestos Sources Covered ^~4
• 1.3.2.1 Asbestos Mills 1-4
1.3.2.2 Roadways !-6
I 1.3.2.3 Manufacturing 1-6
• 1.3.2.4 Demolition 1-7
1.3.2.5 Spraying T'8
• 2. ASBESTOS MILLS 2-1
2.1 PROCESS DESCRIPTION 2-1
I 2.2 EMISSION POINTS 2-3
• 2.3 INSPECTION PROCEDURES 2-4
2.3.1 General Procedure 2-4
I 2.3.2 Inspection Procedure for Baghouses 2-7
2.3.3 Inspection Procedure for Wet Scrubbers 2-17
I 2.4 REFERENCES FOR SECTION 2 2-20
• 3. ROADWAYS 3-1
3.1 DISCUSSION 3-1
I 3.2 REFERENCES FOR SECTION 3 3-2
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Page
4. MANUFACTURING 4'
4.1 ASBESTOS TEXTILES 4'1
4.1.1 Process Description 4~^
4-3
4.1 .2 Emission Points
4.1.3 Inspection Procedures 4~4
4.2 CEMENT PRODUCTS 4'4
4,2.1 Process Description 4"4
4.2.2 Emission Points 4'5
4.2.3 Inspection Procedures 4"^
4.3 FIREPROOFING AND INSULATING MATERIAL 4"7
4.3.1 Process Description 4"7
4.3.2 Emission Points 4"8
4.3.3 Inspection Procedures 4~9
4.4 FRICTION PRODUCTS 4'9
4.4.1 Process Description 4"9
4.4.2 Emission Points 4"^4
4.4.3 Inspection Procedures 4~'8
4.5 PAPER, MILLBOARD, FELT 4'18
4.5.1 Process Description 4"^°
4.5.2 Emission Points 4~20
4.5.3 Inspection Procedures 4~*^
4.6 FLOOR TILE 4'21
4.6.1 Process Description 4~^
4.6.2 Emission Points 4"^^
4.6.3 Inspection Procedures 4"24
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4.7 PAINTS, COATINGS, CAULKS, ADHESIVES, AND SEALANTS 4-24
jj 4.7.1 Process Description 4-24
_ 4.7.2 Emission Points 4-24
™ 4.7.3 Inspection Procedures 4-25
• 4.8 PLASTICS AND RUBBER MATERIALS 4-25
4.8.1 Process Description 4-25
| 4.8.2 Emission Points 4-26
g 4.8.3 Inspection Procedures 4-27
* 4.9 CHLORINE 4-27
I 4.9,1 Process Description 4-27
4.9.2 Emission Points 4-27
| 4.9.3 Inspection Procedures 4-29
_ 4.10 REFERENCES FOR SECTION 4 4-30
* 5. DEMOLITION 5-1
• 6. SPRAYING 6-1
7. INSPECTION RECORDS 7-1
| 7.1 REPORTS 7-1
_ 7.2 CHECKLISTS AND OUTLINES 7-1
" 7.3 REFERENCES FOR SECTION 7 7-7"
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/.,. 2.-7
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LIST OF TABLES
TABLE PAGE
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7-1 Inspection Checklist 7-3
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LIST OF FIGURES
FIGURE PAGE
1-1 Regulatory Responsibilities of Government Agencies for
Controlling Asbestos Emissions 1-3
2-1 Asbestos Milling 2-2
2-2 Unit Type Fabric Collectors, Unsupported Tubular 2-8
Elements
2-3 Screen or Envelope Type Collector 2-9
2-4 Pulse-Jet Cleaning Type Collector 2-10
4-1 Asbestos Textiles 4-2
4-2 Manufacture of Asbestos-Cement Pipe 4-6
4-3 Friction Products: Dry-Mixed Brake Linings 4-10
4-4 Friction Products: Roll-Formed Clutch Facings and
Brake Linings 4-11
4-5 Friction Products: Endless Woven Clutch Facings 4-12
4-6 Friction Products: Woven Brake Linings 4-13
4-7 Asbestos Paper 4-19
4-8 Vinyl-Asbestos Floor Tile 4-22
4-9 Diaphragm Cell, Hooker Type "S-3A" 4-28
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1. INTRODUCTION
1.1 PURPOSE OF DOCUMENT.
| This document has been issued to accompany promulgation of
m National Emission Standards for Hazardous Air Pollutants (NESHAPS).
It is intended to function as an inspection manual for use in
I enforcing national emission standards for asbestos. Regional, State
and other air pollution officials should find it useful for this
| purpose.
I The Federal regulations for asbestos are given and the interface
of EPA with other regulatory agencies is explained. The fabric
• filter or baghouse, is the device commonly used between asbestos
• source and atmosphere, and general procedures for inspecting a bag-
house are presented. It is not possible to cover all details of the
• many kinds of baghouses; therefore the inspector should become
familiar with the installations within his jurisdiction and with any
• unique features of these units.
I Visible emissions to atmosphere from buildings are conceivable.
• Therefore, this manual discusses many sources of asbestos emissions
from asbestos mills and manufacturing establishments. Process flow
• diagrams indicate points of asbestos emissions, and control techniques
applicable to each source are mentioned. This information will help
| the inspector to trace visible emissions back to their source.
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In all cases, inspectors will need to demonstrate the presence of
asbestos In an air emission, or in a construction material. The require-
ments for satisfvino. this need are outlined.
1.2 GOVERNMENT AGENCIES THAT REGULATE ASBESTOS EMISSIONS.
This manual was written for the use of inspectors from the
Environmental Protection Agency or for other air pollution enforce-
ment personnel. However, other Government agencies have jurisdiction
and interests In asbestos air emissions. Figure 1-1 illustrates
those Federal anencies having responsibilities for controlling
asbestos emissions. As the figure shows, these responsibilities are:
a. EPA - regulate and control emissions
to atmosphere.
b. Occupational Safety regulate and control v.-orking
and Health environment, indoors and out.
Administration
c. Bureau of Mines - regulate and control environments
in and around mining properties.
Further information on OSHA and Bureau of Mines may be obtained from:
Occupational Safety & Health Administration
U. S. Department of Labor
1726 M Street N. W.
Washington, D. C. 20210
1-2
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Office of the Deputy Director
Health and Safety
U. S. Bureau of Mines
18th and C Streets N.W.
Washington, D.C. 20240
1.3 ASBESTOS EMISSION STANDARDS.
1.3.1 Intent of Standards
On April 6, 1973, the Administrator promulgated National
Emission Standards for Hazardous Air Pollutants, including asbestos.
The standards are intended to call attention to significant sources
of asbestos air emissions and to control all of them so that an
ample margin of safety for protection of public health will result.
The standards avoid prohibition of essential uses of asbestos and
give due account to operations already under control by other
agencies.
1.3.2 Sources Covered
1.3.2.1 Asbestos mills
The promulgated standards prohibit visible emissions to
the outside air from any asbestos mill. Outside storage of asbestos
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materials is not considered a part of an asbestos mill. As an
B alternative to meeting a no-visible-emission requirement, an owner or
• operator may elect to use the following specified methods to
clean air streams containing particulate asbestos material before the
I air streams are vented to the atmosphere. If this alternative is
elected, the following requirements must be met:
(A) Fabric filter collection devices must be used, except as
| noted in paragraphs (B) and (C). Such devices must be operated at
g a pressure drop of no more than 4 inches water, as measured across
the filter fabric. The air flow permeability, as determined by
I
ASTM Method 0737-69, must not exceed 30 cubic feet per minute per
2 2
square foot (cfm/ft ) for woven fabrics or 35 cfm/ft for felted
12 2
fabrics, except that 40 cfm/ft for woven or 45 cfm/ft for
g felted fabrics is allowable for filtering air from asbestos ore.
driers. Felted fabric must have a weight of at least 14 ounces
I per square yard of material and be at least 1/16 inch thick
throughout. Synthetic fabrics must not contain fill yarn other
J than that which is spun.
• (B) Where the use of a fabric filter would create a fire or
explosion hazard, the Administrator may authorize the use of wet
• collectors designed to operate with a unit contacting energy of at
• least 40 inches water.
g (C) The Administrator may authorize the use of filtering devices
™ other than the specified fabric filters and wet collectors provided
• the owner or operator demonstrates to the Administrator's
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satisfaction that the filtering of participate asbestos is
equivalent to that achieved through the use of the specified
equipment.
(D) All air-cleaning equipment authorized by this section must be
properly installed, used, operated, and maintained. Bypass devices
may be used only during upset or emergency conditions and then only
for so long as it takes to shut down the operation generating
the particulate asbestos material.
1.3.2.2 Roadways
Surfacing roadways with asbestos tailing is prohibited except
for temporary roadways on areas of asbestos ore deposits. The
deposition of asbestos tailings on roadways covered with snow or ice
is considered surfacing.
1.3.2.3 Manufacturing
Any visible emission to the atmosphere from a building or
structure in which any of the following operations are conducted -
or directly from the operation itself if it is conducted outside of a
building or structure - is prohibited.
Affected Manufacturing Qperati ons
(A) The manufacture of asbestos-containing cloth, cord, wicks,
tubing, tape, twine, rope, thread, yarn, roving, lap, or other
textile materials.
(B) The manufacture of cement products.
(C) The manufacture of fireproofing and insulating materials.
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(D) The manufacture of friction products.
(E) The manufacture of paper, millboard, and felt.
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(F) The manufacture of floor tile.
(G) The manufacture of paints, coatings, caulks, adhesives,
• and sealants.
• (H) The manufacture of plastics and rubber materials.
• (I) The manufacture of chlorine.
_ As an alternative to the no-visible-emissions regulation, the owner
™ or operator of a manufacturing operation may elect to use a
• specified gas cleaning technique (Section 1.3.2.1) to remove asbestos
particulate from air streams before they are emitted to the atmosphere.
1.3.2.4 Demolition
• Operations involving the demolition of any institutional,
commercial, or industrial building (including apartment buildings
• having more than four chvelling units), structure, facility, or
• installation which contains a boiler, pipe, or structural merber that
is insulated or fireproofed with friable asbestos material must
• comply with the following control procedures.
• (A) Friable asbestos materials used as insulation or fireproofing
for any boiler, pipe, or structural member must be wetted
| and removed before the commencement of any demolition operation.
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Asbestos debris must be wetted sufficiently to remain wet
during all stages of demolition and related handling.
(B) Any pipe or structural member that is covered with
friable asbestos insulating or fireproofing material must be
lowered to the ground.
(C) No friable asbestos debris may be dropped or thrown
from any building, structure, facility, or installation to
the ground or from any floor to a floor below. I/hen the
demolition operation involves buildings, structures, facilities,
or installations 50 feet or greater in height, asbestos debris
must be transported to the ground by dust-tight chutes or
containers.
Any demolition operation is exempt from the previously listed
requirements if the building, structure, facility, or installation
is declared by the proper state or local authority to be structurally
unsound and in danger of imminent collapse. Under this circumstance,
the only requirement is the .adequate wetting of asbestos debris prior
to demolition.
1.3.2.5 Spraying
Visible emissions to the atmosphere from the spray application,
to equipment or machinery ,of insulating or fireproofing material
containing more than 1 percent asbestos on a dry weight basis (see
Section 6) are prohibited. As an alternative to the
no-visible-emission regulation, an owner or operator
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may elect to clean emissions from air streams by using the methods
• discussed in Section 1.3.2.1 before such air streams are vented to
the outside air. Spray-on materials used to insulate or fireproof
™ buildings, structures, pipes, or conduits must contain less than 1
• percent asbestos (dry weight basis).
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I 2. ASBESTOS MILLS
I 2.1 PROCESS DESCRIPTION.
• Asbestos ore is transported from the mine to the mill complex
v/here it is treated in a series of primary and secondary crushers
I which produce material with a maximum diameter of 1 5/16 inches for the
wet-ore stockpile. Ore from this stockpile serves as feed for the
I milling operation illustrated in Figure 2-1.
• The wet ore is dried, treated in a fine crushing circuit to
reduce the size tc approximately 1/4 inch diameter, and introduced to a
I rock circuit. The rock circuit is composed of a series of crushing and
screening operations and has the primary function of separating the
I asbestos fibers from the co-existing rock. Air suction hoods
• (aspirators) are used to entrain the asbestos fibers in an air stream
and separate them from the waste rock. The circuit performs the
• secondary function of grading the fibers according to length.
Air streams convey the asbestos fibers from the rock circuit
m to a fiber-cleaning circuit. Cyclone collectors are used to remove the
• entrained fibers. Exhaust air from the cyclones is sent to a fabric
filter before being vented tb the atmosphere. The fiber cleaning
• circuits perform additional fiber opening, classify and separate
opened fibers from unopened fibers and waste material, and permit
• additional fiber grading.
• The final portion of the milling operation is the cleaning and
bagging circuit. In this circuit, fibers receive additional cleaning
• and arc separated into several standard grades before being packaged for
shipping. A more detailed description of the milling operation is
2-1
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DRIED ROCK
STORAGE
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HDRY |H
ovn COLLECTOR
vlDDAGGIllG MACHINE
.ONE OF DUPLICATE . ,
H-ROCK CIRCUITS—»-HC;IF. OF DUPLICATED—FIBER CLEANING AND BAGGING-
1 FIBER CLEANING CIRCUITS
FAN-EXHAUST SITTLIiiG CHAMBER
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CSLOCATION OF POTENTIAL. ASBESTOS-COfiTAINIIJG DUST EMISSIONS
Figuie2-1. Asbestos milling.
2-2
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available in the AP-117 control techniques document for asbestos
• emissions. Inspectors should note Figures 3-4, 3-5, 3-6 and 3-8
and should read this document to become familiar with the processes
I they must inspect.
•
•
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2.2 EMISSION POINTS.
A list of exhaust points for mill ventilation and process air
streams must be obtained on an individual plant basis. This
information can be obtained by contacting the mill owner or operator
prior to the actual inspection. Major sources of emissions within
™ the mill and applicable control techniques are as follows:
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1. Emission Source — open conveyor belts transporting ore or
partially processed ore.
Control Technique -- enclose conveyor and transfer points
I and exhaust to baghouse, or wot the transported material.
I 2. Emission Source -- primary and secondary crushers.
Control Technique — enclose and exhaust crusher inlet
| and outlet to baghouse.
I 3. Emission Source — vibrating and shaking screens.
Control Technique -- enclose screens and exhaust to baghouse.
4. Emission Source -- cyclone exhaust.
| Control Technique — treat exhaust in baghouse.
5. Emission Source — ore-drier exhaust.
Control Technique — treat exhaust in baghouse.
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6. Emission Source -- mills and fiberizers.
Control Technique -- enclose inlets and outlets of mills
and fiberizers and exhaust to baghouse.
7. Emission Source — fiber grading circuits.
Control Technique -- enclose inlet and outlet ends of graders
and exhaust to baghouse.
8. Emission Source -- bagging machines.
Control Technique -- install dust capture hoods and exhaust
to baghouse.
9. Emission Source -- disposal of mill tailings.
Control Technique — enclose conveyors carrying mill
tailings and exhaust to baghouse or wet tailings before transporting.
2.3 INSPECTION PROCEDURES.
2.3.1 General Procedure
A visible emission, as defined by the standard, is any emission
which is visually detectable without the aid of instruments and which
contains particulate asbestos material.
If the no-visible-emission option is chosen, the first step in
the inspection of an asbestos mill should be the visual examination of
all exhaust points (stacks, vents, etc.) for mill ventilation and process
air streams. The inspector should be a qualified smoke reader wt:o has
successfully completed the EPA course on visible emission evaluation
or an equivalent course. The visual examination should be conducted
in accordance with 40 CFR 60, Method 9 of the Appendix.
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_ The visual detection of an emission must be followed by
' confirmation that asbestos material is present in the visible
• gas stream. Further guidance on collection and identification of
asbestos samples will be provided by DSSE.
g Exhaust streams from ore driers are unique, because water vapor
_ in these streams can be sufficient to cause a visible plume. The
™ inspector must read the opacity of the exhaust stream at the point
• where the steam plume disappears. A visible emission at this point
would be considered a violation of the no-visible-emission requirement.
| If the alternative to the no-visible-emission requirement is
« chosen and a baghouse is in use, either the design and operating
specifications must match those presented in Section 1.3.2.1(A), or
I the owner or operator of the mill must demonstrate to the Administrator's
satisfaction that the efficiency of the unit is equivalent to that of
I the specified control system. Design information, such as fabric
•j specifications and operating pressure, can be obtained from the
plant owner or operator. The presence of visible emissions in
• the baghouse exhaust gases is evidence of a probable malfunction.
None of the acceptable baghouses that have been observed have
I exhibited visible emissions when in proper operating condition.
m Visible emissions from baghouses are possible during the start-up
period, but should be eliminated as a filter cake forms on the
I clean cloth.
I
I
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Inspection procedures for fabric filters and high-energy wet
scrubbers are presented in the following sections. These procedures
are also applicable to systems used to control emissions from the
affected manufacturing operations or during the spray application of
2-6
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2.3.2 Inspection Procedure for Baghouses
Discussion
I
I
asbestos-containing insulation or fireproofing onto equipment or
I machinery and therefore will not be duplicated in Sections 4 or 6.
m Unique situations that would alter the inspection scheme will be
discussed whenever pertinent.
I
Fabric filters are produced by several different manufacturers
I and can have basic design differences. In general, they can be
classified hy (1) type of filter element (supported or unsupported), (2)
• the intended use (continuous or intermittent), and (3) the method of
• removing collected dust from the filter fabric (mechanical shaking,
mechanical rapping, pulse-jet, etc). Examples of three common baghouse
• designs are presented in Figures 2-2 through 2-4. A brief description of
each system is presented in this section. A more complete discussion can
• be obtained from the control techniques document for parti cul ate air
•
pollutants.
The fabric filter shown in Figure 2-2 is an unsupported tubular
| uni-bag tvpe. Bags are supported at their tops by a bag and shaker
support and are attached at their bottoms to a collar sealed into the
• cell plate. The cell plate is the perforated metal plate that
• separates the classified section from the clean air chamber and channels
dust-laden air into the filter elements.
• Dust-laden air enters a classifier section in which the larger
particles are removed by settling. The air then flows upward through the
• bag entrances, passes through the bag fabric and is exhausted to the
• atmosphere. Dust particles accumulate on the inside of the bags and must
I
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CLEAi; AIR CXIiAIJSl
FILTFi!
DUST- V" -
LAIJF.F! f.\\1
SIR" LA;, 1'"
V
BAG SUPPORT
CELL PLATE
Figuie 2-2. Unit type fabiic "inllpctrrs,
unstippoitcd tiibulai oloinonti-. ^
2-8
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TOP VIEW OF ONE ROW OF ELEMENTS
------,/- DUSKADLii AIR
•<— !i
CLLAN AIR ' -- : ^
l*\. ._. / _
'~~~
BAGSUI'POIU
sinEvirv;
AIR
DUST
COLLRCTiOII
HOPPER
DTf.! AIR
FILTER ClEf.:EKTS
Figuic 2-3. fjci
01 envelop:1 tyjx; cnllcctoi,
2-9
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fl
~1
VENTUKI
\,
\ ~"~' "
1
/
(
1
1
j
1
t
; 1
1 '
\
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CLFA:;I;:G
CYCLF.
[ n ?T
^ il rv
x- ^)
/ / / /'.s
?/' \ ^ /' v' ;^" '
! ) s .' . . »
1
1
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v
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": T~'Tf
|\ .
7 ; //
• i / -
i :
•
1 " I
Vi .' Vi
\ \\
i
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I i"""" '.'" ''"• •'• - .'
j
I
'' • •*'• ' \ /
. \ ' ( i \ /
.i - . - .
v •-,' i
v •*-— J
^-- DUST-LADF.;,1 AIR
i
,
-•r- CLFAIiAIR
.GAG SUPPORT
Fli TE'.R
H—
2-4. Pulco-j'.'t ck'nni.Kj !<,[)•• colloctoi.
2-10
-------
I
be removed by periodic cleaning, usually with a mechanical shaker. The
frequency and length of the cleaning cycle depends upon the specific
«
operation.
I When the filtration process is reversed, with the gas flowing from
the outside to the inside of the filter element, it is necessary to
P support the filter media against the developed pressure. Supported
• filter elements are either of the envelope (Figure 2-3) or the tubular
(Figure 2-4) type. In the case of a screen or envelope type of collector,
V dust-laden air entering the filter encounters a baffle plate that causes
the stream to diffuse over the entire chamber. This diffusion assures
m uniform loading throughout the system and permits the heavier dust
« particles to settle out. The air then passes through the filter media
to the inside of the bag and out the open end of the bag to the clean
• air chamber. Dust particles are deposited on the outside surface of
the bags and must be removed by periodic cleaning. Cleaning is usually
I accomplished by mechanical shaking or rapping.
m A schematic diagram of a fabric filter that utilizes a pulse- jet
cleaning mechanism is presented in Figure 2-4. This system uses tubular-
• type, supported filter elements. The collector consists primarily of a
series of cylindrical filter elements enclosed in a dust-tight housing.
m Dusty air is admitted to the housing and clean air withdrawn from inside
m the filter elements. Periodic cleaning is required to remove dust particles
which accumulate on the outside of the bags. Cleaning is accomplished by
I introducing a jet of high-pressure air into a venturi mounted above each
bag. The reverse flow of air created by the jet pulse is sufficient to
m loosen accumulated dust and clean the the filter media. Cleaning is
• continuous, with a complete cycle every 2 to 5 minutes.
i
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The existence of several types of fabric filters complicates
the procedure of evaluating specific systems. The inspection scheme
provided in this manual, although somewhat general in nature, is
adequate to allow a full evaluation of most fabric filters. It is
suggested, however, that the inspector make an effort to obtain and
review the operating instructions for the specific unit being examined
whenever possible. Although many vendors do not include a separate
inspection manual with their operating instruction package, the
information provided might suggest some alteration in the listed
procedure.
Procedure
1. Identify the type of fabric filter being used: manufacturer,
model, type of bags, cleaning mechanism, capacity, and source
of gas stream being treated.
2. Compare the fabric specifications of the bags being used
with the referenced specifications. Air flow permeability
(ASTM Method D 737-69) should not exceed 30 cfm/ft2 for woven
2
or 35 cfm/ft for felted fabrics. Permeability is defined
as the air flow in cubic feet per minute passing through a
square foot of clean new cloth with a pressure differential of
0.50 inch water. An exception to this requirement will
be allowed for fabric filters treating air from asbestos ore
2
driers. In this case, an air flow permeability of 40 cfm/ft
2
for woven or 45 cfm/ft for felted fabrics is acceptable. Felted
fabrics must weigh at least 14 ounces per square yard and be at
2-12
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I
least 1/16 inch thick. Synthetic fabrics must not contain fill
| yarn other than that which is spun. The inspector should de-
^ termine if the user has installed bags differing from those speci-
• fied in the original fabric filter design and the reason for any cnange
m
•
3. Observe pressure drop across fabric filter. The most common
differential pressure instrument used is a simple "U"-tube mano-
meter filled with water or anti -freeze solution and connected across
• the filter media. Other devices that indicate differential
pressure include well-type manometers, bourdon-type gauges, and
• diaphragm-actuated gauges. Pressure drop should be no more than
m 4 inches water . A reading several inches in excess of
this value is a sign that a system malfunction (blinding, etc.)
• exists. A low pressure-drop reading would indicate a bag rupture
or leak.
I
4. Search for bypass lines or ductwork. Determine the justification
g for them. Determine if any alternate atmospheric protection is
available if these bypasses are used.
•^^
5. Inspect fabric filter for leaks. The approach will depend upon
• the collector design. In the case of filters using unsupported
« bags, the inspector can actually enter the collector and evaluate
the condition of the bags. Filter elements should be examined for
• tears, ruptures, leaks, and signs of heavy wear. The inspection
should be scheduled to concur with a period when the unit has
• been removed from service for cleaning. When examining a system
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2-13
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designed for continuous service, the inspection must be on a
compartment-by-compartmcnt basis.
Dust deposits on the clean air side of the bags or the cell
plate are signs of collector malfunctions. Leaking bags will
frequently have a streak of dust leading from the leak towards
the clean air exit. Leaks in the cell plate are usually
indicated by a small mound of accumulated dust surrounding the
leak. The floor of the clean air chamber should be kept clean
so that any dust deposits observed during an inspection can be
attributed to a collector malfunction. Regular cleaning of the
baghouse cell plate is not common at rnost operations, however,
it is felt that the practice could be introduced without requiring
an unreasonable amount of effort.
Special attention should be given to the inspection of the bags '
around the area where they are attached to the cell plate (collar),
since this is a point of high wear. All bags should be firmly
attached to the cell plate or to the collar attached to the cell
plate. If a bag leak or rupture is located, the bag should be
tied off below the leak or the cell plate entrance capped as a-
temporary measure until the bag can be replaced.
When evaluating fabric filters equipped with supported filter
elements (gas flow from outside of filter element to inside),
visual examination of the interior of the collector is restricted
because of the presence of dust-laden air. Most fabric filters
using supported elements employ continuous cleaning techniques
2-14
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m (pulse-jet, reverse jet) and are therefore not normally removed
from service for cleaning (Figure 2-4). The units will have to
I
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be inspected when the systems are in operation. The major
emphasis should be placed on the baghouse manometer reading
and the cleanliness of the collector exhaust stream. At pulse-jet-
M cleaned units, the inspector should gain access to the upper
plenum chamber (clean air exit) and observe the exhaust stream
• during a cleaning cycle (complete cycle every 2 to 5 minutes).
The presence of a leak in any specific bag is indicated by the
JB discharge of a puff of dust from the venturi immediately
M following the cleaning step.
The presence of dust in the clean air plenum chamber is an
™ indication of a bag leak or to^ Ine chamber should be kept
• free of dust deposits so that any dust accunulation can be
attributed to a collector malfunction. Regular cleaning of
H the clean air plenum chamber is not a common practice at most
~ operations, but could be initiated without too much difficulty.
* Should a baq leak be discovered, the venturi can be capped as a
• temporary measure until the unit can be removed from service
and the bag replaced.
6. Observe bag spacing. Sufficient clearance should be provided
• so that one bag does not rub another. This decreases the
effective filter surface and increases bag wear.
7. Inspect ductwork and collector housing for leakage, wear, corrosion,
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- 2-15
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and general state of repair. The general location of leaks
can be determined by the air noise. Leaks in the housing or
ductwork should be sealed either by welding or the use of
epoxy cither on a temporary or permanent basis as conditions
permit.
8. Inspect dust hoppers for accumulation of dust. In most cases,
the hopper should not be allowed to become more than half full
in order to avoid re-entrainment of the collected material.
9. Observe the emptying of dust hoppers, rote the type of waste
containers being usoc! and the presence or absence of visible
emissions. Obtain information regarding ultimate fate of
asbestos waste.
10. Review operating procedures and maintenance schedules. Frequent
inspection and maintenance is essential to the effective operation
of the collector. External maintenance inspection of the filter
housing and system should usually be performed daily, while the
filter elements should typically be inspected once a week. Note
length arid frequency of cleaning cycle. This will vary depending
upon the specific applications.
11. Determine what preventive maintenance procedures are used to
avoid fabric failures and what procedures are used to replace
bags or correct malfunctions.
12. Gas itreams from baghouses servicing asbestos ore dryers may show
visible pluses of steam. The water content results both from the
a-16
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hydrogen in the ore-dryer fuel and from the moisture in the
I asbestos being dried. The inspector should read the opacity at
M the point where the steam plume disappears. Any opacity here
is evidence of a leak or system malfunction.
™ The inspector must remember that the baghouse tt-mperature must
• be held above the dewpoint of the ore dryer exit gas. This
dewpoint will depend upon the fuel being used and the moisture
I in the asbestos to be dried; more exactly, it will depend upon
^ the v;ei<;,nt (or mol} fraction of water vapor in the gas stream.
' For a specific mill, the dewpoint will fall within a limited
• temperature range. The inspector should therefore observe the
condition of the insulation on the baghouse (gas temperature is
| maintained above dewpoint by preventing gas heat loss) and check
— the gas temperature history. A fall below the dewpoint would
* mean trouble for the baghouse operator, by caking, blinding
• and increased pressure drop, through the bags.
I
2.3.3 Inspection Procedure for Het Scrubbers
Discussion
• High-energy wet scrubbers could find application in controlling
asbestos dust. Specifically, scrubbers might be used in situations
• in which the use of fabric filters would create a fire or explosion
• hazard. Low energy (6 to 8 inches water) scrubbers have been used
as a control for asbestos emissions at Johns-f'anville's Hanville,
• Hew Jersey plant; Ravbestos - Manhattan's flanheim, Pennsylvania pl.nt;
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Union Carbide's King City, California mill; and several Canadian
mills. No high-energy scrubbers, however, are known to be in use
as a control technique for asbestos in any of the mills or
manufacturing operations covered by the standard. All existing
scrubbing systems are expected to be replaced by fabric filters.
Procedure
1. Identify the type of wet scrubber being used: manufacturer,
model, type, unit contacting energy, capacity, and source of gas
stream Iziv.'j treated.
2. Compare design specifications with referenced specifications. The
collector must be designed to operate with a unit contacting energy
equivalent to 40 inches water pressure drop. Contacting energy is
that portion of useful energy exuded in producing contact of the
particulate matter with the scrubbing liquid. Unit contacting energy
is equal to the energy per unit weight of gas required to introduce
the gas stream into the contact chamber, plus, the energy per unit
weight of gas required to introduce scrubbing liquid into the
contact chamber, plus the mechanical (shaft) energy per unit
weight of gas applied to effect contact between the scrubbing
5
liquid and the gas stream. In the case of a venturi scrubber, the
most common type of high-energy scrubber, the contribution of the
liquid stream is small and most of the energy for contacting is
derived from the gas stream. The contacting energy is therefore
essentially equivalent to the gas stream pressure drop.
3. Note the design specifications for gas-stream volumetric flow
2-18
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rate, gas-stream pressure drop, liquid-stream volumetric flow
I rate, and liquid-stream inlet pressure. Observe the pressure
drops and flow rates if the necessary instruments have been
I
installed.
• 4. Search for bypass lines or ductwork. Determine the justification
for them. Determine if alternate atmospheric protection is available
in case of tneir use.
™ 5. Inspect ductwork and exterior of scrubber for leaks, wear,
fl| corrosion, and general state of repair.
• 6. Review operating procedures and maintenance schedules. Frequent
inspection arid maintenance is essential to the effective operation
• of the scrubber. Obtain information regarding ultimate fate of
collected asbestos.
7. Determine what procedures are used in cases of scrubber mal-
jp function.
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2-19
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2.4 REFERENCES FOR SECTION 2.
1. Control Techniques for Asbestos Air Pollutants. U. S. Environ-
mental Protection Agency. Research Triangle Park, North Carolina.
Publication Number AP-117. February 1973.
2. Hutcheson, J. R. M. Environmental Control in the Asbestos Industry
of Quebec. 73rd Annual General Meeting of the Canadian Institute
of Mining and Metallurgy, Quebec City, 25 p. 1971. p. 9, 23.
3. Control Techniques for Particulate Air Pollutants. U. S. Depart-
ment of Health, Education, and Welfare. Washington, D. C.
Publication Number AP-51. January 1969. p. 102-126.
4. Types of Fabric Filters. Industrial Gas Cleaning Institute, Inc.
Stamford, Connecticut. Publication Number F-5. August 1972. 8 p.
5. Semrau, K. T. Dust Scrubber Design - A Critique on the State of
the Art. Journal of the Air Pollution Control Association.
13:587-594, December 1963.
2-20
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I
I 3. ROADWAYS
I 3.1 DISCUSSION.
m The inspector should be familiar with sources of asbestos tailings
in his jurisdiction. These sources include asbestos mines and
• mills, which have been and are a source of rock wastes. The
large available quantities of such rock wastes have furnished
Q incentive to use them to surface roads. It is economical to
£ process asbestos rock to a residual asbestos content of about
3 percent. The inspector should maintain enough surveillance over
• mines and mills to be aware of the ultimate fate of such asbestos-
containing solids wastes.
| The inspector can maintain some surveillance over roads by
im visual examination of pieces of rock. Asbestos in such rock will
probably have a color varying from v.;iite, through greenish or
V yellowish white to brownish. It will have a silky, metallic, dull
and opaque luster. Fibres may be coarse or fine and probably are
• parallel with the walls. Sometimes they are felted. It is also
m interesting to note that a suspension of chrysotile in water
has a pH of over 10. This.is alkaline to litmus and to phenolphthalein.
• Although this property is not unique, it is one added test to use
for identification.
™ If the presence of asbestos is suspected, the inspector may take
• samples of rock or of apparently fibrous road materials and submit them
for microscopic examination.
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3.2 REFERENCES FOR SECTION 3.
1. Kirk-Othmer Encyclopedia of Chemical Technology, Second Edition,
Vol. 2., pg. 738, Intersciencc Publishers, N. Y.
3-2
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• 4. MANUFACTURING
I 4.1 ASBESTOS TEXTILES.
m 4.1.1 Process Description
The majority of the asbestos fibers received by a textile plant
• are of the milled variety. These fibers have frequently been com-
pressed during packaging and therefore require willowing (fiber
• opening) before being sent to the carding operation.
• Either in a preliminary mixing operation or during carding, small
amounts of a carrier fiber (rayon or cotton) are blended with the
• asbestos fibers to improve the spinning characteristics of the
asbestos. The asbestos content of the mixture will range frrm 80
9 percent to almost 100 percent depending upon the requirements of the
• end-product.
Carding is the preliminary st.p in the manufacture of textiles.
I The asbestos f;oers unde^jo a final opening and cleaning process by
the carding machine, which cor.ibs the fibers into a parallel arrange-
• ment thereby forming a coherent mat of material. This mat is
• separated into untwisted strands and wound onto spindles to form the
roving from which asbestos yarn is produced.
• Roving is converted into yarn by a conventional spinning operation,
The yarn may then undergo a twisting, weaving, or braiding operation
• depending on the desired end-product. Figure 4-1 provides a schematic
• diagram of an asbestos textile plant. Additional information is
I
I
I
available in the control techniques document for asbestos emissions.
-------
BAGGED ASBESTOS MUCK
UAGGEOSYNTHETIC
ORCELLULOSEFIRER
i.
PUKE/.VSTOS
LAPS AND CELTS
ASULS10S
>.- SYNlliLTK,
-, LAPS AND [ LL.TS
I
SPUN YARN
r.i!Ti::c
"Ll1™
— LIGHT -GJMt,L
REINFORCING i.lICF
TV/ISTED YARN -
V
II.VJLTI PLY
A YARN
R[V:H;DER
"OPTIONAL
BRAIDER
D
i:.
V/EAV1HG L00
IMPREGNATING
V
StALS
PACKINGS
: LOCAl'ION 0!: I'OTI ',ll\M A?L;F SI OS CONTAINING DUST [."ISSIGiJS.
BRAIDED TUBIf.T., r,:V,IDED
ROPE, BRAIUTD C(!';l/
SPINNING
AID
TV/IS! ING
WOVEN TUC'NG,
CLOTH, TAPES
Figure 4-1. Asbestos textiles.
4-2
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4.1.2 Emission Points
| A complete list of all exhaust points (stacks, vents, etc.) for
g plant ventilation and process air streams is necessary for the inspect-
ion of any manufacturing operation. This information must be obtained
I from the plant owner or operator. Major sources of emissions within
a textile plant and appropriate control techniques are as follows:
I 1. Emission Source — opening and emptying of bags of asbestos
m into fiber openers and carding machines.
Control Technique -- install dust capture hoods on bag
• opening stations and carding machines with exhaust to baghouse.
• 2. Emission Source -- carding operation.
Control Technique -- install dust capture hoods with exhaust.
• to baghouse.
• 3. Emission Source -~ spinning and twisting machines.
Control Technique -- enclose spindles with exhaust to
• baghouse or convert to wet process.
Jj 4. Emission Source -- looms and braiding machines.
— Control Technique -- install dust capture hoods with exhaust
™ to baghouse.
• 5. Emission Source — open carts of asbestos fiber, roving,
• or yarn.
Control Technique -- cover carts.
I
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4-3
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6. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place empty bag in enclosed container
immediately after emptying and deposit in landfill.
4.1.3 Inspection Procedures
Ventilation and process air from the fiber opening (willowing)
and carding machines could have loadings similar to the process gas
streams of asbestos mills. Most of the other gas streams are expected
to have lov/er fiber concentrations. The inspection procedures described for
asbestos mills in Section 2.3 will apply to tne manufacturing of textiles.
4.2 CEMENT PRODUCTS.
4.2.1 Process Description
Asbestos-cement products contain from 15 to 30 percent (by weight)
asbestos, usually of the chrysotile variety. The largest sector of
this industry is involved in the production of asbestos-cement pipe.
Other products include siding shingles and flat or corrugated sheets.
Siding shingles and other sheet products may be produced by
either a dry or wet process. In the dry process, a uniform thickness
of the dry mixture (asbestos fibers, Portland cement, and silica) is
distributed onto a conveyor belt, sprayed with water, and compressed
by rolls to the desired thickness. This asbestos-cement sheet is then
cut to size and sent to the curing operation.
The wet process produces dense sheets of asbestos-cement material
by introducing a slurry into a molH chamber and compressing the mixture
to remove excess water. A setting and hardening period of 24 to 48
hours precedes the curing operation.
-4-4
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I
• The manufacture of asbestos-cement pipe is illustrated in
8 Figure 4-2 With the individual manufacturing steps numbered and
listed on the bottom portion of the figure. Asbestos fibers are
I normally received in pressure packed bags and therefore require fiber
M conditioning (opening) before being sert to the production-line
storage bins. A more detailed discussion of the manufacturing
V operation is available in asbestos control techniques document.
• 4.2.2 Emission Points
Major potential emission sources within the plant and suitable
• control techniques are presented in the following list.
1. Emission Source -- slitting and emptying of bags of
• asbestos into hopper of fiber opener.
• Control Technique -- install dust capture hood over bag
opening and emptying station with exhaust to baghouse.
I
2. Emission Source -- dry mixing of asbestos, cement, and
• silica.
Control Technique -- install dust capture hood over mixing
I operation and exhaust to baghouse.
g 3. Emission Source -- finishing operations (machining, drilling,
cutting, grinding).
• Control Technique -- install hoods over all finishing operations
• and exhaust to baghouse.
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4-6
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4. Emission Source -- loading of scrap and rejects into
scrap grinder.
Control Technique -- install dust capture hood over loading
«
area and exhaust to baghouse.
• 5. Emission Source -- disposal of empty asbestos bags.
• Control Technique -- place empty bag in an enclosed
container immediately after emptying and deposit in landfill.
4.2.3 Inspection Procedures
• The inspection procedures discussed for asbestos mills should
be appropriate. Heavy concentrations of asbestos fibers might be
| present in process and ventilation rtreams from fiber opening,
M mixing, and finishing operations.
4.3 FI REPROOFING AND INSULATING MATERIAL.
4.3.1 Process Description
• Molded insulation and spray-applied mixtures used to fireproof
• steel-reinforced buildings are the principal asbestos-containing
insulating and fi reproofing materials. The preliminary step in the
• manufacture of molded insulation is the mixing of diatomaceous silica,
lime, and asbestos with water. This mixture is pumped to a holding
• (gel) tank where the silica reacts with the calcium hydroxide to
• form hydrated calcium silicate which crystallizes around the asbestos
fibers. The calcium silicate - asbestos slurry is then discharged to
• a molding press where the charge is dewatered and pressed into the
desired forms (pipe shells, blocks, etc.). After being removed from
i
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the molds, the pieces are heat cured in a series of autoclaves and
drying tunnels and sent to a finishing operation (sizing, leg
trimming, drilling, etc.) before being packaged for shipping.
Spray-applied fireproofing mixtures are a combination of
asbestos and an inorganic dry bonding agent. The mixing operation
is usually a batch process.
4.3.2 Emission Points
Major end i;si on points in the manufacturing operations together
with effective control measures are listed below.
1. Emission Source -- opening and emptying of bags of asbestos
into fiber openers or mixers.
Control Technique -- install dust capture hoods on bag
opening stations and mixing operations v/ith exhaust sent to a
baghouse.
2. Emission Source — finishing operations (sizing, leg
trimming, drilling, planing, etc.).
Control Technique — install hoods over all finishing
operations and exhaust to baghouses.
3. Emission Source -- packaging of pipe insulation or
fireproofing mixture.
Control Technique — install dust capture hoods over
packaging areas and vent to baghouse.
4-8
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4. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place bag in encloced container
and deposit in landfill.
•i
_ 4.3.3 Inspection Procedures
" Willowinq and mixing operations can produce high fiber concen-
• trations. The inspection procedures suggested for asbestos mills are
applicable.
4.4 FRICTP.'I PRODUCTS.
™ 4.4.1 Process Description
• Brake linings and clutch facings are the major asbestos-contain-
ing friction products. Methods of fabrication include molding (wet
J or dry), two-roll forming, and impse-.nating woven asbestos fabric
— with friction material. Molding and two-roll forming involve the
* preforming of the product under pressure in molds or between rolls.
• The preformed sheets are then cut into product sized segments, formed
into the proper shape, and heat cured. Woven friction products are
I constructed of resin impregnated asbestos fabric that has been cut
_ to length, formed into the desired shape, and heat cured.
* Detailed descriptions of the various manufacturing operations
emissions. Figures 4-3 through 4-6 illustrate these processes.
• are provided in the control techniques document for asbestos
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• 4-9
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, AND
FRIC'ilUH COMPOUND
MOLD
PT; --- rD
STEAM
PREHEAT
PREFORMING
PRESS
STRIPS CUT
TO LENGTH
MOLD
REMOVCD
. i
fell:
PiiL.A
V
i 1
•"•'< * fTJuti" . _.:";,""
ROUGH
GRIKDIf.'G
SHEET Clll I:.'IT
STRIPS
STEAM HEATED
BENDING
CLAWING IN
LUNETTES
BAKING
OVEN
- . n
DRILLING,
PACKAGING
G LOCATION OP POTENTIAL ASBESTOS-CONTAINING DUST EMISSIONS
- >
Figure 4-3. Friction products: dry-mixed
brake linings.
RADIUS
GRINDING
4-10
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START: ROI.L FOR','.; D CLUTCH FACINGS
ASBESTOS, SOLVFNT, AND
FRICTION COMPOUND
MU-SHEAR
,',IXER
-H-i
Tit
---
r.^-f
ill
RACKING
, FINISHING
! OPERATIONS
.1
i H
PRESS
1
-
iit
\;
r-i \
PACKAGING I SFEFIG. 29
START. ROLL FOR.V.LD BRAliE LININGS
ASBESTOS,
SOLVENT.
AND
FRICTIC:;
co,v,rai!,n W
3l.
BAKING
OVEN
FORCED-
AIIJDRYiiG1
CKAf:'.!;LR
RACKING
CHOPPER
TY/C ROLL>
MILL
(3 LOCATION OF POTENTIAL ASBFSrOS-COfiTAINING DUST EMISSIONS
Figure 4-4. Friction products: roll-formed clutch
facings and brake linings.
4-11
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WIRE REINFORCED
CLOTH ROLL
SLITTING TO
TAP(:S
11
STEAM-HEATED
ROLL
FRICTIOI: cc ,;POJ;,D
BA1 H
WATER-COOLED
ROLL
Vr'INDIiiG
METAL
PLATES
-F
- >r
PRrCL';-;li,G
1, OV1IH
HOT
PRESSING
V
FINISHING OPERATIONS
Fo:-'-.-.rj-;,!R
COOt.i;,G
SANDING
EOGF.
1-iDHiG
8 y
DRILLING.
BRANDING
JL,
*—V»t"~*
1NSPF.CT.ON
PACKAGING
LOCATION OF POTENTIAL ASBESTOS-CONTAINING DUST EMISSIONS
Figure 4-5. Friction products: endless woven
clutch facings.
4-12
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WIRE-REINFORCED
WOVEN TAPE
ROLL
CLAWING IN
LU.'imES
DRYING
OVEN
ROUGH
rjGRInbUG
*«•*•
IMPREGNATING
BATH
ROTARY
CUTTER
PRESS
DENS FIER
BAKING OVEN
I I
I FINISHING OPERATIONS '
SEE FIG. 2-9 I
n
PACKAGING
P
P1 LOCATION OF POTENTIAL ASBESTOS-COI1TAINING DUST (.MISSIONS
Figure 4-6. Friction products: woven brake lininqs.
4-13
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4.4.2 Emission Points
Dry-Mixed Brake Linings
1. Emission Source -- opening and emptying of hags of asbestos.
Control Technique- -- install dust capture hoods over bag
opening area and storage bins.
2. Emission Source -- transfer of asbestos from storage bins to
weighing scales.
Control Technique -- install dust capture hood over weighing
scale- c.-nd exhaust to baghouse.
3. Emission Source -- discharging of asbestos from weighing
scales to mixer.
Control Technique -- enclose discharge area or install dust
capture hood and exhaust to baghcu3e.
4. Emission Source -- discharging of mixer product to molds.
Control Technique -- enclose discharge area and exhaust to
baghouse.
5. Emission Source -- cutting of molded sheet into strips.
Control Technique -- install dust capture hoods and exhaust
to baghouse.
6. Emission Source -- rough grinding of molded strips.
Control Technique -- install dust capture hoods and exhaust
to baghouse.
4-14
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I
•
•
7. Emission Source -- cutting of molded strips to length.
Control Technique -- install dust capture hood and exhaust
to baghouse.
8. Emission Source -- finishing operations (grinding, drilling,
• counterboring) .
Control Tpchninue -- install dust capture hoods and exhaust
| to haohouse.
• 9. Erission Source -- disposal of emntv asbestos bags.
Control Techninuo -- place empty bags in enclosed container
' immediately after emptying and deposit in landfill.
• ^°J_llLP-!j'i0_^ i;ral'° .Lini'lf'Ji
• 1. Emission Source -- opening and emptying of bans of asbestos.
Control Technique -- install dust canture hoods over bag
• opening area and storage bins and exhaust to haohousp.
V 2. Emission Source -- transfer of asbestos from storane bins
to weigh inn scales .
| Control Technique -- install dust canture hoods over weighing
_ scales and exhaust to baohouse.
3. Em's si on Source -- discharging of asbestos from weighing
• scales to mixer.
• Control Technique -- install dust capture hoods over mixer
and exhaust to ban.'iouse.
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• 4-15
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4. Cmissinn Source -- hammer mill.
Control Technique -- enclose discharne area and
exhaust to bainq arr.i and -. toraqe bins and exhaust to baeliouse.
2. [r.is.-.ion Sourcu -- transfer of asbestos from storage bins to
weighing scales.
Control Technique -- install dust capture hoods over
weighing scalcf, and exhaust to baghouse.
3. Emission Source -- discharging of asbestos from weighing
scales to mixer.
Control Technique -- install dust capture hoods over mixer
and exhaust to baghouse.
4-16
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4. Emission Source -- finishing operations (sanding, edqe
I grindi nq, drilling, counter-boring, dustinci).
Control Technique -- install dust couture hoods over
| finishing operations and exhaust to bacjhouse.
I 5. (."mission Source -- disposal of empty asbestos baqs.
Control Technique -- place empty bags in enclosed container
• immediately after emptying and deposit in landfill.
• li°Y_cJl l'r_a! :> l-1Jlin3J-L
• 1, emission Source -- cutting of saturated tane.
Control Technique -- install dust caoture hoods and exhaust
I
to baqhouse.
12. Emission Source -- rouqh grinding of taoe.
'
Control Technique -- install dust capture hood and exhaust
to baqhousc.
• 3. emission Source -- finishing operations (sandinq, edge
grindi nq, drilling, counter-boring, dusting).
8 Control Technique -- install dust capture hoods over all
• finishing operations and exhaust to baghouse.
• Endless 1 .(P_ve_n__Clj : JL?_h. _£ acijios_
• 1. emission Source -- slitting of asbestos cloth into tapes.
• - Control Technique -- install dust capture hood and exhaust
to baghouse.
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• 4-17
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2. Emission Source -- finishing operations (sanding, edge
grinding, drilling, counter-boring, dusting).
Control Technique -- install dust capture hoods over all
finishing operations and exhaust to baghouse.
4.4.3 Inspection Procedures
The inspection procedures presented in Section
2-3 can be used. High concentrations of asbestos could be present
in ventilatio,. air from the dry-mixing and finishing (drilling,
grinding, ftc.) operations. Visible emissions might also be detected
from various other process steps (wet-mixing, impregnating bath, etc.)
because of the use of volatile organic solvents. Asbestos emissions
from these sources are expected to be small.
4.5 PAPER, MILLBOARD, FELT.
4.5.1 Irocess Description
Asbestos paper and felt are manufactured on machines of the
Fourdrinier and cylinder types similar to those used to produce
cellulose paper. The cylinder machine is the more v.-idely employed.
Figure 4-7 illustrates the operation of a Fourdrinier paper
machine. Short-fiber asbestos is combined with a binder and water
in a pulp beater to form a mixture containing between 6 and 12
percent fibers. This slurry is fed to a machine chest where it is
diluted to 2 to 4 percent solids. A thin uniform layer of the mixture
is deposited by gravity onto an endless, moving wire screen to form
the paper which is then transferred to a moving felt. Vacuum boxes,
roll presses, and a series of steam heated drum rollers are used to
4-18
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vi en: I-'-1
PRESS
RO'.LS
'>
CALENDER
ROLLS
o r\ /
.- ^ - xr /'tr
h; /'
v«* t
u
DRYERS
CHEATED ROLLS)
--
FINISUri) A'JBLSTOo
PAPER ROLL
HIGH-SPEED
SLITTCR
TAKE-UP
REEL
TAKE-UP REEL
fl LOCATION Of POTENTIAL ASnESTOS-CONTAIIIING DUST EMISSIONS
" J
Figure 4-7. Asbestos paper.
4-19
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dry the paper. This is followed by calendering to produce a smooth
surface and cutting to size.
The operation of a cylinder paper machine includes a mixing
step similar to that described for a Fourdrinier type machine. The
slurry from the machine chest is pumped to one of several vats, each
containing a rotating cylinder screen. Asbestos fibers are collected
on the rotating cylinders and transferred to an endless belt conveyor
to form the paper. The subsequent drying, calendering, and sizing
operations a.-; trie same as these described for the Fourdrinier machine,
f'illLCK-rc! is produced from short fiber asbestos. The asbestos
fibers, water, and a binder are mixed in a pulp beater, subjected to
a screening operation, and pumped to the millboard machine. The
asbestos slurry is fed to u large box containing a rotating cylinder
screen. Fibers are deposited on the rotating cylinder, partially
drained of waters and transferred to a conveyor belt to form the
millbO'Vd shoret. This sheet is then pressed, molded, and cut to the
size of consr.ercial millboard. All remaining water is removed by a
series of pressing and drying operations.
4.5.2 Emission Points
1. Emission Source -- opening and emptying of bags of asbestos
into mixer.
Control Technique — enclose bag opening and emptying
station and exhaust to baghouse, or convert to a wet process
using pulpable bags.
4-20
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_ 2. Emission Source -- slitting and edge-trimming of paper.
Control Technique — install dust capture hoods and exhaust
• to baghouse.
• 3. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place empty bags in an enclosed
g container immediately after emptying and deposit in landfill.
• 4.5.3 Inspection Procedures
The in:rvction procedure developed for asbestos mills should be
• appropriate. The major emission source will be the opening and
• emptying of bags of asbestos.
4.6 FLOOR TILE.
4.6.1 Process Description
• Vinyl-asbestos floor tile is produced from a mixture of asbestos
•j fibers, ground limestone, and a resin binder. The various components
are combined in a high shear mixer as indicated in Figure 4-8 to
• form the base material. After the base material passes through a
two-roll mill, the relatively thick sheet is cut and joined to a
• similar piece that has been previously formed and is in the process
• of being calendered (smoothed and reduced in thickness between two
revolving cylinders). A series of calendering cperations produces
I a tile sheet of the desired thickness and surface finish.
Before the compound can cool and harden, a blanking press die
I cuts the tiles to final size. Haste material is recycled to the
• mixing operation. A more detailed discussion of the manufacture
• 4-21
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BRPM ;
FRA..T.
STHAP
S/: !) ClIHL'K
;AV;:.:AIF.I;IALS
\
Ti-r, noi.i
fmLL
n;/v :. --
STKYP
/•
OIL
|,;OT'i I ! R
RADIANT
WAX AF'PLICATOI?
Buni;r;
..._J
COOLI[-;GCIiA!,;i]ER
OO:-
CALENDER ROLLS
PRESS
fTILES
\
\
\
\
I I'
•t~- —
PACKAGING
COOLIUG Cf!/,,V,bER
Ario;.1 or PGILNTIM ASp.rsros-co;.ri/i.iNiijc DUST [.MISSIONS
Fiqure 4-8. Vinvl-asbestos floor tile.
4-22
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g of vinyl-asbestos floor tile can bo obtained from tho control
techniques document for asbestos emissions.
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4.C.2 Emission Points
Potential sources of asbestos emissions are:
1, Emission Source -- opening and emptying of bags of asbestos.
I Control Technique -- install dust capture hoods over bag
opening and emptying stations and exhaust to baghouse.
2. Em's?ion Source -- transfer of asbestos from storage bins
• to weighing scales.
• Control Technique -- install dust capture hood over weighing
scales anci exhaust to baghouse.
• 3. Emission Source -- disch?rging of asbestos from weighing
• scale to mixer.
Control Technique -- enclose discharge area or install dust
| capture hood over mixer inlet,
• 4. Emission Source -- mixing process.
Control Technique — close mixer inlet.
5. Emission Source — loading of asbestos-containing chips
J into hoppers in preparation for mottling.
_ Control Technique -- install dust capture hood over hoppers
• and exhaust to baghouse.
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4-23
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6. Lrnission Source -- deposition of mottling chips on the
tile shoot ar. it emerges from the two- roll mill.
Control Technique -- install dust capture hood and exhaust
to baghouse.
7. Emission Source -- grinding of scrap in preparation for
recycle.
Control Technique -- install dust capture hoods over
de^ "nlet and outlet and exhaust to baghouse.
8. [.mission Source -- disposal of empty asbestos bags.
Control Technique -- place empty bags in an enclosed
container immediately after emptying and deposit in landfill.
4.6.3 Inspection Procedures
Asbestos emissions are limited primarily to the introduction
of asbestos into the process and to the mixing step. The inspection
procedures outlined in Section 2.3 will be applicable.
4.7 PAINTS, COATINGS, CAULKS, ADHESIVES, AND SEALANTS.
4.7.1 Process Description
Most asbestos-containing paints, coatings, caulks, adhesives,
and sealants are either asphalt or oil -based mixtures produced by
batch mixing operations. A high percentage of short-fiber asbestos
may be used.
4.7.2 Emission Points
Emissions are possible from the bag opening operations and
4-24
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from the introduction of asbestos into the process.
| 1. Emission Source -- opening and emptying of bags of
B asbestos into storage bins or receiving hoppers.
" Control Technique -- install dust hoods over bag opening
I and emptying stations and exhaust to bagliouse.
• 2. Emission Source -- transfer of asbestos from storage bins to
weighing scales.
I Control Technique -- enclose discharge area and exhaust to
baghouse.
3. Emission Source -- discharging of asbestos from the
| weighing scales to the mixer.
w Control Technique -- enclose discharge area or install dust
capture hood over mixer.
• 4. Emission source -- disposal of empty asbestos bags.
• Control Technique -- place bags in an enclosed container
immediately after emptying and deposit in landfill.
4.7.3 Inspection Procedures
I The inspection procedures provided in Section 2.3 are appropriate.
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4.8 PLASTICS AND RUBBER MATERIALS.
4.8.1 Process Description
Asbestos-reinforced or-filled plastics and rubber materials
• may be produced by both batch and continuous operations and may
make extensive use of both short and long fibers. Process
4-25
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descriptions must be obtained on an individual basis from the plant
owner or operator.
4.8.2 Emission Points
1. Emission Source -- opening and emptying of bags of asbestos
into storage bins or receiving hoppers.
Control Technique -- install dust capture hoods over bag
opening and emptying stations and exhaust to beghouse.
2. Emission Source -- transfer of asbestos from storage bins
to v/eigning scales.
Control Technique — enclose discharge area and exhaust to
baghouse.
3. Emission Source -- discharge of iisriestos fron the weighing
scales to the mixer.
Control Technique -- enclose discharge area or install
dust capture hood over mixer.
4, Emission Source -- grinding of sheets of asbestos-
reinforced plastic to form molding compound.
Control Technique -- enclose inlet and outlet of grinder
and exhaust to baghouse.
5. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place bags in an enclosed container
immediately after emptying and deposit in landfill.
4-26
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• 4.0.3 Inspection Procedures
Potential enission sources are the bag opening and the mixing
I operations. Mo alteration in the inspection procedures listed in
Section 2.3 should be required.
4.9 CHLORINE.
4.9.1 Process Description:
I Host chlorine is produced by the electrolysis of aqueous
solutions of alkali-metal chlorides. All cell designs for this
• electrolytic process are variations of either the diaphragm cell
• (Figure 4-9) or of a cell which uses mercury metal as an inter-
mediate cathode. In the diaphragm cell, an asbestos diaphragm
• separates the anode from the cathode. The diaphragm is applied by
inmersing the cathode into a bath of asbestos slurried in cell
m liquor and then applying a vacuum to the cathode. Asbestos is
• deposited on the steel-screen fingers of the cathode.
« 4.9.2 Emission Points
1. Emission Source --.opening and emptying of bags of asbestos.
• Control Technique — install dust capture hoods over bag
opening and emptying stations with exhaust to baghouse, or convert
| to wet process using pulpable bags.
I 2. Emission Source -- disposal of empty bags of asbestos.
Control Technique -- place empty bags in enclosed container
• immediately after emptying and deposit in landfill.
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l-
QJ
O
O
cu
O
CD
(O
J-
^;
en
o
CTl
I
3
cn
u.
4-28
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4.9.3 Inspection Procedures
I
Visible emissions of asbestos can occur during the bag
0 opening and emptying operation. The inspection procedures developed
for asbestos mills should be suitable.
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4.10 REFERENCES FOR SECTION 4.
1. Control Techniques for Asbestos Air Pollutants. U. S.
Environmental Protection Agency. Research Triangle Park, North
Carolina. Publication Number AP-117. February 1973.
2. Shreve, R. M. Chemical Process Industries. New York, McGraw-Hill
Book Company, 19C7. p. 234.
4-30
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• 5. DEMOLITION
I A rewrite of the Demolition Section is being prepared by D5SE
• and will be distributed no later than at the July 19 NESHAPS seminar
in Dallas, Texas.
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6. SPRAYING
I
The only spray applied insulation or fireproofing now being
I produced that is known to contain more than 1 percent asbestos is
_ MK 111 produced by the Zonolite Construction Products Division of the
• W. R. Grace Company. MK 111 contains from 10 to 12 percent asbestos.
• The Fireproofing Products Division of Carboine Co. of St. Louis
manufacturers Pyrocrete I and Pyrocrete II. These are cement-piaster-
• asbestos mixtures used for structural steel fireproofing. They are
no I spray applied.
The asbestos limitation of 1 percent by weight for drv spray
I material applied to buildings, structures, pipes, or conduits suggests
that the inspector may often want to check supplies allegedly contain-
| ing less than 1 percent asbestos. Quantitative analysis for asbestos
• in a mixture is an extremely difficult procedure. Available methods
arc based on electron microscopy used by highly trained specialists.
I Determining asbestos content with these methods costs approximately
$300, and the results are accurate within plus or minus 50 percent.
p The few available U. S. locations that have the required facilities
I
and expertise include the following:
Battelle Columbus
I Attention: Mr. William Henry
505 King Avenue
Columbus, Ohio 43201
I California State Department of Health
Attention: Dr. Peter K. Mueller
2151 Berkeley l.'ay
Berkeley, California 94704
I
_ McCrone Associates, Inc.
• 493 East 31st Street
™ Chicago, Illinois 60616
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6-1
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Mt. Sinai School of Medicine
City University of Mew York
Attention: Dr. Irving J. Selikoff
Environmental Sciences Laboratory
5th Avenue and lOOlh Street
New York, New York 10029
Johns f'onville Research and Engineering Center
Attention: Dr. Sydney Spi°l
Denver, Colorado
Obviously, speedy analysis, although highly desirable, will
not normally be possible. However, the submission of samples at
least serves r>s a deterrent to a contractor who would misrepresent,
since action could be taken against him later if the analysis showed
more than 1 percent asbestos.
In cases involving the spray application of asbestos containing
insulating or fireproofing material containing n.ore than 1 percent
asbestos to equipment or machinery, the inspection procedures listed
in Section 2.3 would be appropriate.
6-2