PxEPA
450277030
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 2771 1
EPA 4B
JUf'f-
Air
Standards Support
Document:
Promulgated
Amendments to the
National Emission
Standard for
Asbestos
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EPA-450/2-77-030
Standards Support Document:
Promulgated Amendments
to the National Emission Standard
for Asbestos
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
June 1978
',. *£*.'''-'
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD-35), U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
Publication No. EPA-450/2-77-030
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FINAL
STANDARDS SUPPORT DOCUMENT
Amendments to National Emission Standard
for Asbestos
Type of action: Administrative
Prepared by
Don R. Goodwin, Director
Emission Standards and Engineering Division (MD-13)
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
(Date)
Approved by
Assistant Administrator
Office of Air and Waste Management
Environmental Protection Agency
401 M Street, South West
Washington, D. C. 20460
(Date)
Additional Copies May be Obtained At:
EPA Library (MD-35)
Research Triangle Park, North Carolina 27711
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TABLE OF CONTENTS
Page
CHAPTER 1.
1. SUMMARY 1-1
1.1 SUMMARY OF CHANGES SINCE PROPOSAL 1-1
1.2 SUMMARY OF ENVIRONMENTAL AND
ECONOMIC IMPACTS 1-2
CHAPTER 2.
2. SUMMARY OF THE PUBLIC COMMENTS 2-1
2.1 SPRAYING RESTRICTIONS 2-1
2.2 DEMOLITION AND RENOVATION REQUIREMENTS 2-5
2.3 TEST METHODS/MONITORING 2-9
2.4 HEALTH EFFECTS 2-11
2.5 MISCELLANEOUS 2-11
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1. SUMMARY
On March 2, 1977 (42 FR 12121), the Environmental Protection Agency
(EPA) proposed amendments to the national emission standard for asbestos
under the authority of section 112 of the Clean Air Act. The Federal
Register notice of proposed rulemaking requested public comments on the
proposal. Twenty-four comment letters were received from manufacturers
of asbestos products, demolition contractors, State air pollution control
agencies, various Federal agencies, and other interested parties. The
comments that were submitted along with EPA's responses to these
comments are summarized in Chapter 2 of this document. This summary of
comments serves as the basis for the revisions which have been made to
the amendments between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
The major change made since proposal is the development of an exemption
for certain materials from the spraying restrictions in the proposed
amendments to the asbestos standard. The proposed amendments would have
prohibited the spray-on application of any material containing more than
1 percent asbestos on buildings and conduits. Also, no visible emissions
would have been permitted from the spray-on application of materials
containing more than 1 percent asbestos on equipment and machinery, and
the intent to spray such materials would have had to be reported to EPA
20 days before spraying. The promulgated amendments provide an exemption
from these restrictions for materials in which the asbestos fibers are
encapsulated with a bituminous or resinous binder during spraying and
which are not friable after drying.
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1.2 SUMMARY OF ENVIRONMENTAL AND ECONOMIC IMPACTS
The promulgated amendments to the asbestos standard will have a signifi-
cant beneficial environmental impact by reducing emissions of asbestos to
the atmosphere. There will be minimal solid waste and v/ater pollution impacts
from the increased amount of friable asbestos materials which must be removed
and disposed of in conjunction with demolition or renovation. No impact on
national energy consumption is anticipated.
There is little difference in the environmental impacts of the proposed
amendments and the promulgated amendments. The proposed amendments were
intended to reduce asbestos emissions in two ways:
1. By requiring proper removal or stripping of all friable asbestos
materials during demolition or renovation. As discussed in the preamble
to the prooosed amendments (42 FR 12121), decorative materials were not
covered by the 1975 demolition and renovation provisions which applied
to friable asbestos-containing fireproofing and insulation materials. Friable
decorative materials, however, or for that matter any other friable asbestos-
containing materials, would have as great a potential for releasing asbestos
fibers to the air during demolition or renovation as asbestos-containing
fireproofing and insulation materials. Therefore, the amendments were proposed
to extend the demolition and renovation requirements to all friable asbestos
materials.
2. By prohibiting the spray-on application of all materials containing
more than 1 percent asbestos. This was intended to prevent the future use
of friable asbestos-containing materials since these materials are likely
to release asbestos during application, during their service life, and during
demolition or renovation.
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The promulgated amendments to the demolition and renovation provisions
are the same as the proposed amendments. The spraying restrictions,
however, have been changed. The wording, which was primarily intended
to prevent the use of friable asbestos-containing decorative materials,
was so broad in scope that it would also have prevented the use of
asbestos-containing roofing products and other non-friable coatings in
which the asbestos is well-bound both during and after application. As
discussed in chapter 2, acceptable substitutes for the use of asbestos in
bitiminous- and resin-based materials are not available and any beneficial
environmental impacts resulting from the prohibition of this use of
asbestos would be negligible. Therefore, the promulgated amendments exempt
such materials from the spraying restrictions.
When these amendments were proposed, EPA invited all interested persons
to participate in the rulemaking action by submitting factual information
related to the proposed requirements during the comment period. Information
concerning economic impacts which could result from implementing the proposed
amendments was specifically requested. EPA received no comments which would
indicate that any adverse economic impacts would result from prohibiting
the spray application of friable asbestos-containing materials. Comments
from the demolition industry did not address the possible economic impacts
of the proposed amendments. Therefore, no significant economic impacts are
expected to result from either the spraying provisions or the demolition and
renovation retirements.
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2. SUMMARY OF THE PUBLIC COMMENTS
The list of commenters and their affiliations is shown in Table 2-1.
EPA received 24 letters commenting on the proposed amendments. The signifi-
cant comments have been combined into the following major areas:
1. Spraying Restrictions
2. Demolition and Renovation Requirements
3. Test Methods and Monitoring
4. Health Effects
5. Miscellaneous
The comments and issues, along with EPA's responses, are discussed in
the following sections of this chapter. A summary of the changes to the
regulations is included in chapter 1.
2.1 SPRAYING RESTRICTIONS
The main issues raised by commenters on the spraying restrictions in
section 6l.22(e) of the proposed amendments involved exempting certain
materials from the spraying restrictions and labeling asbestos-containing
spray materials.
A number of commenters requested that EPA exempt bitumen- and resin-
based asbestos-containing materials from the spraying restrictions in
section 61.22(e) of the proposed amendments. Since the proposed amend-
ments would have prohibited the spraying of all materials containing
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more than 1 percent asbestos by weight, these materials 'would essentially
have been banned by the proposal. Several commenters, however, reported
that no acceptable substitutes are available for the asbestos fibers in
these materials. Among the most likely substitutes which have been
investigated are glass, cotton, wood, cellulose, mineral wool, hemp, and
other types of inorganic and organic fibers; gelling and thickening
agents; clay thickeners; including attapulgite; ground cork; styrofoam;
ground rubber; vermiculite; feldspar; polyethylene fibrous powders; and
ceramic fibers. Generally, these substitutes have been found to be
unacceptable because of unsatisfactory durability; insufficient bulk;
unsatisfactory qualities related to fibrous reinforcing, homogeneity,
and adhesiveness; and agglomeration during spraying.
Materials with a bituminous or asphalt binder typically contain less
than 15 percent asbestos and are primarily used as roofing compounds,
for waterproofing of insulation exposed to the weather, and for automobile
undercoating. Materials with a resinous binder typically contain less
than 5 percent asbestos and are primarily used in marine and industrial
maintenance applications to provide protection from damage due to water,
chemicals, corrosion, weather, and other exposures.
The application of hot asphalt is a substitute for the spray-applied
roofing compounds but is more expensive and is considered undesirable
from an environmental and energy standpoint. In addition to being less
effective than cold-process products, hot asphalt requires more energy
for heating the compound and is a fire and safety hazard. Plastic
or rubber membrane systems which are just coming into the marketplace
are possible substitutes but currently have limited availability.
Prohibiting the spray application of asbestos-containing industrial
maintenance materials would impose severe economic and energy impacts on
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the industry. For example, a spraying ban on materials used to protect
various forms of thermal insulation would decrease insulation effective-
ness at industrial plants which use the products and increase energy
consumption.
Further, the commenters submitted information to show that spray
application of a non-friable material which contains a bituminous or
resinous binder is unlikely to be a source of asbestos fiber emissions.
Normally these materials are thixotropic (i.e., viscosity decreases as
they are stirred or shaken). Consequently, before application, they
are viscous and "sticky" or "tacky" and any asbestos fibers in the
material are encapsulated and immobilized by the binder. During appli-
cation, they take on an oily consistency and the spray equipment atomizes
the material into droplets as it passes through the spray nozzle. The
droplets vary in size according to the type of equipment used; but in
all cases, the droplets are much larger than the individual asbestos
fibers. The fibers do not become airborne during spraying because they
are bound together by the binder in the material and encapsulated
within these droplets which are too large to remain suspended in the air
for any length of time.
The amount of binder necessary to encapsulate all the asbestos
fibers which may be present is not the same for all materials. It
varies with the amount of pigment, filler, and additives which are
included. When just enough binder is present to completely fill the
voids between these materials, the critical pigment volume concentration
(CPVC) has been reached. If the CPVC is not exceeded, the binder is
present in an amount sufficient to encapsulate the asbestos fibers in
the coating. The CPVC will not be exceeded in any material which is
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competitive in the marketplace. If the CPVC is exceeded, the material
will not be durable and will not remain effective for an acceptable
length of time because there is simply not enough binder to hold the
components of the material together. Because the asbestos fibers in
these materials are so firmly bound, non-friable bitumen- or resin-based
spray materials which contain asbestos would not be a significant source
of asbestos emissions during application, during their service life, or
during demolition or renovation.
Because there do not appear to be acceptable substitutes available
and any beneficial environmental impact resulting from the prohibition
of this use of asbestos would be negligible, the spraying of materials
in which asbestos fibers are encapsulated by a bituminous or resinous
binder and which are not friable after drying is exempt from the provisions
of section 61.22(e) of the promulgated amendments.
Data on the concentrations of asbestos measured during the spraying
of bituminous- and resinous-based materials were submitted during the
comment period. Asbestos concentrations measured during the spraying of
asphalt cutback and emulsion roofing compounds containing from 3 to
15 percent showed levels from as low as 0.003 to as high as 0.6 fiber
per cubic centimeter (f/cc). Measurements during tear-off of existing
roofs comprised of asbestos-containing roofing felts and asbestos-
containing asphalt materials showed levels as low as 0 to as high as 0.4 f/cc.
Other types of resin-based materials containing up to 37 percent
asbestos, were also tested. Ambient air asbestos concentrations measured
during spraying showed the following levels:
(a) 0 to 0.5 f/cc for weather-barrier mastics using asphalt,
vinyl acetate, or vinyl or acrylic latex as a binder and
containing from 1 1/2 to 37 percent asbestos.
(b) 0 to 0.2 f/cc for industrial materials using epoxy-coal
tar as a binder and containing from 1/2 to 5 1/2 percent
asbestos.
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(c) 0 to 0.4 f/cc for materials using polyester or vinyl latex
resins as binders and containing from 1 1/2 to 4 percent
asbestos. Grinding and sanding of these materials after
application showed levels from 0 to 0.4 f/cc.
These measurements were made in close proximity to the spraying
operations, and are more representative of occupational exposure than
exposure to the general public. As discussed above, the asbestos fibers
in these materials do not become airborne during spraying, but are bound
together by the binder in the material and encapsulated within droplets
which are too large to remain suspended in the air for any length of
time. Consequently, the airborne asbestos fiber concentrations to which
the general public would be exposed would probably be at least one or
two orders of magnitude lower than these levels.
To aid enforcement of the proposed spraying restrictions, some
commenters suggested that materials should be labeled as to their asbestos
content if they contain in excess of 1 percent asbestos by dry weight
and have the potential for spray-on application. Requiring labeling
would constitute a significant change in the amendments and would require
reproposal. Rather than reproposing, the need for such a provision will
be assessed during the enforcement of the amendment. Based on this
assessment, additional amendments may be proposed to require labeling at
some future date.
2.2 DEMOLITION AND RENOVATION REQUIREMENTS
Although several issues concerning the demolition and renovation
requirements were raised during the comment period, most did not deal
specifically with the proposed amendment. One commenter, for example,
questioned EPA's authority to establish work practice rules rather than
emission standards to control hazardous air pollutants. The same commenter
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suggested that EPA has never had a factual basis for considering the
demolition of buildings not containing sprayed asbestos fireproofing
as a "major" source of asbestos emissions and requested that EPA monitor
ambient air in the vicinity of representative mechanical demolitions to
determine asbestos emissions. Other commenters, however, stated that
the extension of the demolition and renovation provisions to all friable
asbestos material is warranted and that renovation or demolition will in
time constitute the most significant emission source of asbestos fibers
to the atmosphere.
The demolition and renovation regulation requires certain work
procedures to be followed. These methods of control are required because
of the impossibility of prescribing and enforcing allowable numerical
concentrations or mass emission limitations. There is no way to measure
the total emissions from a demolition or.renovation operation since these
operations are not enclosed and emissions are not directed through one
or more specific points or smoke stacks.
In the 1977 amendments to the Clean Air Act, section 112(e)(i) states,
"...if in the judgment of the Administrator, it is not feasible to prescribe
or enforce an emission standard for control of a hazardous air pollutant
or pollutants, he may instead promulgate a design, equipment, work practice,
or operational standard, or combination thereof, which in his judgment
is adequate to protect the public health from such pollutant or pollutants
with an ample margin of safety." This provision clarifies the intent
of section 112 by specifically including the prescription of work practices
as a legal alternative to a numerical emission standard. It reaffirms
EPA's original interpretation of section 112 as stated in the preamble
to the 1975 amendments to the demolition and renovation provisions (40 FR
48291): "Congress has specified that EPA should set emission standards
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for hazardous air pollutants. EPA, charged with implementing this require-
ment, has determined that the term 'emission standard' includes work
practice requirements designed to limit emissions." The prescription of
work practices is therefore riot only a legally permissible form of an
emission standard, but also the only practical and reasonable form.
In the preamble to the 1975 amendments (40 FR 48291), the determination
that demolition of buildings containing friable asbestos fireproofing or
insulation was a major source of asbestos emissions was discussed. Other
types of asbestos materials besides fireproofing and insulation are friable
and would thus constitute a source of asbestos emissions during demolition
or renovation. Therefore, buildings containing any friable asbestos
materials are covered by the promulgated amendments.
Two commenters requested that the definition of "friable asbestos
material" be amended because it is inadequate. The suggestion was made
that it specify an ASTM test method by which the friable nature of a
material can be determined with accuracy and uniformity.
The American Society for Testing and Materials (ASTM) has indicated
its intention to develop a test method for friability of asbestos-containing
materials. The test method will be evaluated when it is developed and
consideration given to incorporating it into the asbestos standard.
The current definition of "friable asbestos material" is sufficiently
clear that owners or operators subject to the regulation can easily
understand the term. The term is defined in such a way that a simple
on-site test can be used to determine the applicability of the regulation.
It is only necessary to apply hand pressure to a sample of the material
to see if it can be crumbled, pulverized, or reduced to powder.
One commenter suggested that the regulation be extended to require
removal of existing asbestos-containing sprayed materials which present
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significant risks to human health due to deterioration, particularly in
buildings accessible to the public. The proposed amendments would have
only prohibited the future application of asbestos-containing spray material
This problem is being addressed through the preparation of a
guidance document which will assist governmental agencies and private
individuals who must decide on proper action to take when sprayed
asbestos materials are found in existing buildings. The first volume
of the document discusses criteria for determining whether asbestos
material in a building is a problem; the current knowledge of hazards
from spray-on asbestos in buildings; and alternative corrective actions
that may be taken, including acceptable removal procedures and the use
of sealants for coating the material. Available information on sealant
types will be discussed and a preliminary list of desirable properties
for effective sealants will be included. Very little data are currently
available for various sealants; therefore, this document will only
contain minimal guidance concerning the use of these products. The
second volume of the document, which is scheduled to be available in
later 1978, will present the results of studies which will be done on
sealants to determine their effectiveness and acceptability for coating
asbestos materials. As soon as each volume is published, copies will
be provided to State and local governmental agencies and other interested
parties. Copies of the first volume of this document may be obtained
upon written request from the Emission Standards and Engineering Division
(MD-13), Environmental Protection Agency, Research Triangle Park, North
Carolina 27711 (specify Sprayed Asbestos-Containing Materials in Buildings:
A Guidance Document).
One commenter requested that the renovation, modification, and
dismantling of process equipment at industrial facilities be exempted
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from the demolition and renovation requirements since OSHA regulations
prescribe procedures which provide adequate safeguards to prevent excessive
airborne asbestos emissions.
The OSHA regulations are designed mainly to protect the worker's
health and therefore allow certain practices that result in emissions
of asbestos to the atmosphere. Workers are required to take special
precautions, such as wearing respiratory equipment and special clothing
during renovation or demolition, if asbestos emissions are likely to
exceed the level of the standard. Thus, the purpose of the OSHA standard
to protect employees' health can be achieved by measures such as the use
of respiratory equipment, even when emissions may produce concentrations
in excess of the OSHA exposure limit. Therefore, the demolition and
renovation requirements in section 61.22(d) of the standard remain in
effect for OSHA-regulated industries in order to reduce asbestos emissions
to the ambient air to which the general public is exposed.
2.3 TEST METHODS/MONITORING
The lack of EPA reference methods for making various asbestos measure-
ments was of concern to some commenters. Specifically, they suggested
that EPA publish a method for determining the percentage of asbestos in
spray materials and reference OSHA-NIOSH procedures for measuring airborne
asbestos particulate matter from spraying operations.
There are a number of methods, based on electron microscopy, which
have been developed by independent laboratories for determining the
percentage of asbestos in materials. Laboratories that perform asbestos
analyses using these methods generally have reasonable internal consistency.
Inter-laboratory comparisons, however, have shown that the results obtained
by separate laboratories are often widely different. In mid-1977, a
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laboratory crosswalk study was conducted in which ambient air samples of the
same asbestos-containing materials were sent to different laboratories for
analysis by electron microscopy. The results showed a range of four orders
of magnitude for laboratories using different procedures. This experiment
indicates that extremely wide variability in results can be expected between
laboratories. Part of the problem is that even the same measurement
principle is used, each laboratory has different sub-procedures that
are followed.
In an attempt to standardize procedures and reduce this variability,
a provisional electron microscope procedure for measuring the concentration
of asbestos in air samples has been developed. This procedure can also
be used for material samples although it is recognized that the provisional
procedure may have to be modified for various applications. Statistical
analysis was used to evaluate the effects of the many interacting sub-
procedures and arrive at an optimum composite procedure. This procedure
is expected to reduce the expected variability in results among laboratories
to the range of 40 to 60 percent. It will be further evaluated for use
in actual field studies and if found acceptable, may eventually serve as
the basis for an EPA reference method. The procedure is available in
a publication entitled Electron Microscope Measurement of Airborne
Asbestos Concentrations: A Provisional Methodology Manual, EPA
500/2-77-178, August, 1977. Copies of this document may be obtained
upon written request from the Environmental Sciences Research Laboratory
(MD-49), Environmental Protection Agency, Research Triangle Park, North
Carolina 27711.
The OSHA-NIOSH method measures airborne asbestos fiber concentrations
by phase contrast microscopy. It measures only those fibers that are
longer than 5 microns and does not differentiate between asbestos and
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other fibers. While such a method may be sufficient for enforcing the
OSHA workplace asbestos standard, it is not sufficient as an indicator
of total asbestos concentration in the ambient air. Many asbestos
fibers are smaller than the smallest measured by the OSHA-NIOSH method
and these fibers May contribute significantly to the total amount of
asbestos which may be present in the ambient air. The provisional
electron microscope method described above is useful for estimating
airborne asbestos fiber concentrations with greater precision.
2.4 HEALTH EFFECTS
Some commenters suggested that since asbestos is a carcinogen and
a threshold level for health effects has not been established, the 1
percent allowable asbestos content for spray material permits too much
environmental contamination and should be lowered considerably, if not
completely eliminated. The 1 percent allowable content of asbestos was
selected primarily to allow the spray application of materials which
contain trace amounts of asbestos which occur in numerous natural substances
and which could not be reduced or removed from these materials without
effectively banning their use.
2.5 MISCELLANEOUS
There were a number of minor questions, requests for clarification,
and suggestions made by the commenters. Several questions were raised
regarding the intent and applicability of various parts of the regulation.
Commenters specifically questioned the applicability of section 61.22(e)
with respect to the meaning of the terms "structures," "structural members,"
"pipes," "conduits," and "equipment and machinery," and suggested that
definitions for these terms be included in section 61.21.
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The term "structure" is part of the definition of "stationary source"
in section 61.02(p): '"Stationary source1 means any building, structure,
facility, or installation which emits or may emit any air pollutant which
has been designated as hazardous by the Administrator." The term "structural
member" is defined in section 61.21(x) which was promulgated on March 2,
1977 (41 FR 12124): '"Structural member" means any load-supporting
member, such as beams and load-supporting walls; or any non-load-supporting
member, such as ceilings and non-load-supporting walls." The terms "pipes,"
"conduits," and "equipment and machinery" are used in the general sense
and, therefore, their meanings are self-evident. The question was raised
as to whether the term "equipment and machinery" applies only to stationary
equipment and machinery or would include such machinery as automobiles.
The term applies to all equipment and machinery, whether mobile or stationary.
It is important to make it clear at this point, however, that under section
61.22(e) .the source being regulated is not the object being sprayed; rather,
it is the spraying operation itself.
Under the proposed amendment to section 61.22(e), the spray application
of asbestos-containing automobile undercoating and sound deadeners would
have been covered. The promulgated amendment exempts such applications,
however, since undercoating and sound deadeners are bitumen-based and are
non-friable after drying, as discussed in section 2.1.
One commenter suggested that references to "institutional, commercial,
or industrial" buildings should be eliminated in Subpart B to prevent opportunities
for future loopholes to be uncovered in the applicability of the standard. This
limitation on the types of buildings covered by the demolition and renovation
regulation was discussed in the preamble to the asbestos standard promulgated
on April 6, 1973 (38 FR 8821). The coverage at that time was based on
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the National Academy of Sciences' (MAS) report which states, "In general,
single-family residential structures contain only small amounts of
asbestos insulation. Demolition of industrial and commercial buildings
that have been fireproofed with asbestos-containing materials will prove
to be an emission source in the future, requiring control measures."
The NAS report referred specifically to asbestos fireproofing and insulation,
and those were the only types of asbestos-containing materials covered
by the 1973 standard. There is no information which would
indicate that other types of friable asbestos materials would be present
in single-family residential structures to such a degree that asbestos
emissions would be significant during renovation or demolition. Therefore,
the applicability of the demolition and renovation requirements of the
standard has not been revised other than extending the coverage to all
friable asbestos materials.
National Academy of Sciences: Asbestos (The Need for and Feasibility of
Air Pollution Control). Washington, National Academy of Sciences, 1971,
40 pp.
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lame t- \
List of Commenters on the Proposed Amendments to the Asbestos Standard
March 2, 1977 (42 FR 12121)
Commenter
Edward E. Reich
W. H. Mortonson
J. C. Winkley
Eric S. Wormser
Jon C. Root
J. H. Macpherson
* Leo J. Spillane
Irving J. Selikoff,
M.D.
Raymond J. Connor
Paul H. Arbesman
Richard P. Carter
W. P. Ellis
Burton Y. Weitzenfeld
and Stanley M. Lipnick
J. A. Bierbaum
Joseph T. Mooney, Jr.
Andrew E. Kauders
H. J. Holloway
Robert H. Mereness
F. D. Dennstedt
Edwin W. Abbott
V. L. Lawson
Heather L. Ross
J. R. West
David M. Benforado
Affiliation
DSSE - EPA
Flintkote Building Products
C F & I Steel Corporation
Gibson-Homans Company
Southwest Grease & Oil Co.
(Kansas City), Inc.
Chevron Research Company
Gulf States Asphalt Co., Inc.
Mt. Sinai School of Medicine
National Paint and Coatings
Association
N.J. Department of Environmental
Protecti on
Johns-Manvilie Sales Corporation
H.B. Fuller Company
Attorneys for National Association
of Demolition Contractors, Inc.
Lion Oil Company
Monsey Products Co.
General Services Administration
GAF Corporation
Asbestos Information Association
Exxon Company, U.S.A.
Air Transport Association of
America
Texas Refinery Corporation
U.S. Department of the Interior
Koppers Company, Inc.
3M Company
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1, REPORT NO.
EPA-450/2-77-030
3. RECIPIENT'S ACCESSIOt*NO.
4. TITLE AND SUBTITLE
Standards Support Document: Promulgated Amendments to
the National Emission Standard for Asbestos
5. REPORT DATE
June 1978
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Emission Standards and Engineering Division
3. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO ADDRESS
DAA for Office of Air Quality Planning and Standards
Office of Air and Waste Management
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY COOS
200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT • ...
The national emission standard for asbestos is being amended. Scientific
information indicates that asbestos exposure can cause cancer and other adverse •
health effects. The amendments will reduce asbestos emissions by requiring that
proper work practices be followed during the renovation and demolition of buildings
where friable asbestos materials are present and by prohibiting the spray application
of asbestos materials which would be friable after drying. A brief discussion'
of the economic and environmental impacts associated with these amendments is included
in this document.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATI Field/Group
Air pollution
Pollution control
Hazardous air pollutants
Asbestos
Coatings
Demolition
Renovation
Air pollution control
13. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
20
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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