United States
            Environmental Protection
            Agency
             Air And Radiation
             (EN-341W)
EPA 340/1-92-010
February 1992
vvEPA
Guidelines For Catastrophic
Emergency Situations
Involving Asbestos


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Guidelines for Catastrophic Emergency Situations
              Involving Asbestos
     U.S. Environmental Protection Agency
  Office of Air Quality Planning and Standards
     Stationary Source Compliance Division
            Washington, DC 20460

                September 1991

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                             TABLE OF CONTENTS
 I.    INTRODUCTION	   l
      A.   Background	   1
      B.   Purpose	   *•

 H.    RECENT EMERGENCIES	   3
      A.   Gramercy Park	•.	   3
      B.   Hurricane Hugo	   3
      C.   San Francisco Earthquake  	   4

m.    OTHER APPLICABLE STATUTES 	   6
      A.   AHERA	   6
      B.   EPCRA	   6
      C.   CERCLA	   7
      D.   OSHA	   7

 IV.   ASBESTOS NESHAP APPLICABILITY	   8
      A.   Definitions (61.141)  	   8
      B.   Demolition and Renovation Provisions (61.145)	   9
           1.   Emergency Renovation Operations  	   9
           2.   Government-Ordered Demolitions	   10
      C.   Waste Disposal (61.150)  	   U
      D.   Active Waste Disposal Sites (61.154)	   12

  V.   PRE-EMERGENCY PLANNING 	   13
      A.   Emergency Response Organization	   13
      B.   Coordination With Local Emergency and Related Organizations	: .   13
            1.   The Problem	   18
           2.   Strategy	   18
      C.   Mapping Asbestos Locations 	   20
            1.   Asbestos Milling, Manufacturing, and Fabricating	   20
            2.   Asbestos in Facilities	   21
                a. Surveys of Buildings for Asbestos 	   21
                b. Schools	   23
                c. Local Building  Permit Agencies	   23
                d. Notifications 	   25
       D.    Cleanup and Disposal 	   25
            1.  Water Supply	   26
            2.  Chemical Contamination	   26
            3.  Waste  Disposal	   27
            4.  Backup Personnel	•	   27
            5.   Laboratory Capabilities	   27
            6.   Emergency Exemptions 	   28

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 VI.   EMERGENCY PERIOD  	  29




VH.   CONCLUSIONS	  30i




REFERENCES  	  32




APPENDIXES




      A   Asbestos NESHAP Checklist for Catastrophic Emergency Situations  	  33




      B   FEMA Regional Directors	  35




      C   State Official Responsible for Disaster Operations  	  39




      D   Regional Asbestos Coordinators	  54

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           GUIDELINES FOR CATASTROPHIC EMERGENCY SITUATIONS
                               INVOLVING ASBESTOS
 I.   INTRODUCTION

     A.  Background

         In 1989, the California earthquake and Hurricane Hugo resulted in the destruction of

or damage to numerous buildings, many of which contained asbestos.  Badly damaged or

destroyed structures had to be demolished quickly to reduce the threat of injuries from the

damaged structures and to aid in restoring the affected areas. In the same year, a steam pipe

explosion in Gramercy Park, NY spread asbestos over a wide area with the potential to

expose a large number of people to asbestos.

     These recent natural and man-made disasters and others that have damaged or destroyed

structures containing asbestos have served to focus attention on the need to consider asbestos

along with other emergency response activities. Understandably, the emphasis in an

emergency or disaster situation is on efforts to mitigate the immediate threats to public health

and safety  and to return the stricken area to its former condition as quickly as possible.  Also,

the organizations that typically respond to emergency or disaster situations, such as fire

departments and emergency management agencies, do not deal with asbestos  as part of their

normal duties.  As a result, there may be a tendency to overlook potential public health

threats like asbestos, which do not pose an immediate, life-threatening hazard.

     B.  Purpose

         These guidelines are intended to assist Regional, state, and local agencies in

 managing potential asbestos hazards resulting from a catastrophic accident or disaster. The

 guidelines may be used as a reference for advanced planning or, once the emergency presents

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itself, to help ensure that, to the extent feasible and compatible with other emergency




measures, all appropriate steps are taken to safely handle and dispose of all asbestos, while




avoiding unnecessary exposures to asbestos.  The guidelines provide information that may be




helpful to EPA Regional offices and delegated NESHAP agencies that must respond to




emergencies involving asbestos.




     The guidelines review the experiences of EPA Regional and state enforcement agencies




in dealing with asbestos during recent emergencies. Information is included on statutes and




regulations that may be applicable in emergency situations, including the emergency




provisions of the asbestos NESHAP. Lines of communication within EPA and between EPA




and emergency management agencies are discussed.  A list of contacts responsible at the state




level for emergency and disaster activities is provided, as is a protocol for coordinating




asbestos NESHAP activities with local fire and building departments.  Information is provided




to help identify potential sources of asbestos releases, and factors are identified that should be




considered in planning for the cleanup and disposal of asbestos.

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 H. RECENT EMERGENCIES




    Three emergencies occurred in 1989 that focused EPA's attention on the handling of




asbestos. One was a technological failure~a Consolidated Edison steam pipe explosion at




Gramercy Park in N.Y. City; the other two were natural phenomena—Hurricane Hugo and the




San Francisco earthquake.  These emergencies are reviewed here for lessons that may help




plan for and deal with similar problems in the future.




    A.   Gramercv Park




         On August 19, 1989, an underground Consolidated Edison steam pipe exploded in




Gramercy Park in New York City, discharging 400°F steam, asbestos and mud into the air




and onto and into nearby buildings.  The explosion killed three people, injured 24, and forced




the evacuation of 200 residents. Two-hundred pounds of asbestos from pipe insulation were




released with the explosion.  The cleanup and decontamination of the contaminated structures




required several months. The asbestos-contaminated waste was collected and transported to




the Meadowfill Landfill, Clarksburg, West Virginia for disposal.  The cleanup was supervised




by the New York City Department of Environmental Protection, with oversight by EPA. This




cleanup effort was not regulated under the asbestos NESHAP, because it was neither a




demolition nor a renovation.




    B.   Hurricane Hugo




         In September 1989, Hurricane Hugo made a landfall on the South Carolina coast at




Charleston destroying many buildings, damaging many others, and creating vast amounts of




debris, some of it contaminated by asbestos.  The City of Charleston was declared a disaster




 area and the South Carolina Department of Health and Environmental Control (SCDHEC) was




 asked to assist with the cleanup of debris. To deal with a problem of such great magnitude,




 SCDHEC adopted the following procedures:




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     •   Buildings destroyed by Hugo were considered to be demolished by natural
         causes and notification requirements were waived.  Removal contractors
         were not required for the cleanup; however, wetting and proper disposal of
         asbestos-containing material were required.

     •   Remaining, uncontaminated building debris was disposed of in accordance
         with solid waste regulations.

     •   Open burning was permitted in the disaster area to clear it of trees and
         wood products without using landfills.

     •   Partially destroyed buildings could be demolished without notifications
         after asbestos materials were removed by abatement contractors.

     A problem that emerged in South Carolina was that of unscrupulous contractors preying

on unsuspecting home owners by telling them that they were subject to $25,000 a day in fines

unless their roofs were repaired by licensed  asbestos contractors, when, in fact, SCDHEC

regulations did not apply to private residences unless the homeowner selected a licensed

asbestos contractor. A one-page  Guidelines for Homeowners with Damaged Asbestos

Roofing was issued by SCDHEC to outline requirements for homeowners.

     Emergency preparedness representatives, presumably unaware of the presence of

asbestos, complicated asbestos NESHAP enforcement by instructing people to go ahead and

knock down damaged buildings.

     C.   San Francisco Earthquake

         On October 17, 1989, an earthquake registering 7.1 on the Richter scale shook San

Francisco.  According to the Region 9 asbestos NESHAP coordinator, many demolition

contractors thought the NESHAP regulations did not apply following the earthquake and

many buildings were demolished without regard to asbestos.  At a minimum, the NESHAP

coordinator feels that wetting should be employed and the debris disposed of properly.

Based on the Region 9  experience, the NESHAP coordinator suggested the following to

prepare  for emergencies:

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    •   Create an emergency phone list

    •   Coordinate with nearby Regions

    •   Tie into existing emergency communication plans

    •   Set up an emergency protocol for buildings and fire departments

    •   Set up emergency protocols with delegated agencies

    •   Prepare and pre-position press releases regarding NESHAP and asbestos
        risks

    •   Contact the Federal Emergency Management Agency (FEMA) regarding
        asbestos risks and NESHAP

    •   Contact state emergency planners

    •   Set up an informal network of volunteer inspectors.


The NESHAP coordinator also noted that there was a shortage of inspectors available to

determine whether asbestos was present in the damaged buildings and that obtaining

additional help was a problem.

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     OTHER APPLICABLE STATUTES

     In addition to the asbestos NESHAP, there are other Federal statutes that provide

planning information and/or cleanup authority applicable to catastrophic emergencies

involving asbestos.  They include the Asbestos Hazard Emergency Response Act (AHERA);

the Emergency Planning and Community Right-to-Know Act (EPCRA); the Comprehensive

Environmental Response, Compensation, and Liability Act of 1980 (CERCLA); and the

Occupational Safety and Health Act (OSHA).

     A.  AHERA

         Regulations promulgated under the authority of AHERA require the preparation of

management plans for asbestos in school buildings (40 CFR 763.93). Plans must be prepared

by an accredited management planner and include:

     •    The name and address of each school building and whether it contains
         friable asbestos.

     •    A blueprint, diagram or written description that identifies the location and
         approximate square or linear feet of asbestos.

Thus, a data base  on asbestos in school buildings already exists in the administrative offices

of school systems in many communities. This data base is potentially useful either for

emergency  response planning or for identifying asbestos-containing structures following the

occurrence  of a catastrophic emergency.

     B.  EPCRA

         Since asbestos is not listed as an extremely hazardous substance, emergency plans

developed under EPCRA do not address asbestos.  However, the Act also requires  routine

toxic chemical release reporting and friable asbestos is a reportable emission (40 CFR

372.65).  Information collected in this way is entered into a computer file known as the Toxic

Release Inventory System (TRIS) which can be accessed to identify asbestos sources in SIC

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codes 20 through 39. TRIS would seem to be a useful database for either emergency




response planning or identifying facilities where friable asbestos might be expected following




an emergency.




     C.   CERCLA




         Hazardous air pollutants regulated under the Clean Air Act (CAA) are also




regulated as hazardous substances under CERCLA.  CERCLA provides the authority and




funds for emergency government response to hazardous substance releases into the




environment, including the ambient air and allows the federal government to recover the costs




of responding to and cleaning up hazardous substance releases.




     Emissions of reportable quantities (RQs) of listed substances must be reported to the




National Response Center in Washington.  The RQ for asbestos is 1 Ib. (0.454 kg) of pure




asbestos (40 CFR 302.4).




     As noted earlier, the Gramercy Park response was conducted under New York City law




and was not regulated under the asbestos NESHAP.  A federal response could have been




carried out under CERCLA, however, if that had been needed.




     D.  OSHA




         The OSHA rules on asbestos  (29 CFR 1910.1001 and 29 CFR 1926) are applicable




in catastrophic emergencies. OSHA rules specify a permissible exposure limit for asbestos,




respiratory protection, work practices, and  engineering controls for worker protection.  There




 are no exemptions for emergencies in the Act.

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 IV. ASBESTOS NESHAP APPLICABILITY

     The applicability of the asbestos NESHAP (40 CFR Part 61, Subpart M) in emergency

situations is discussed here.  Whenever asbestos will be damaged or disturbed as part of a

demolition or renovation and a threshold amount (160 square feet, or 260 linear feet, or 35

cubic feet) is exceeded, or whenever a building is demolished, the asbestos NESHAP applies.

There are no provisions that stay the applicability of the NESHAP as a result of disaster,

although there are emergency-related provisions. The relevant sections of the NESHAP

include Definitions (61.141), Standard for Demolition and Renovation (61.145), Standard for

Waste Disposal for Manufacturing, Fabricating, Demolition, Renovations, and Spraying

Operations (61.150), and Active Disposal Sites (61.154).

     A.  Definitions (61.141)

         The only definition that is specifically  applicable to emergencies is "emergency

renovation operation."  The NESHAP defines the term as follows:

     "Emergency renovation operation"  means a renovation operation that was not
     planned but results from a sudden, unexpected event that, if not immediately
     attended to, presents a safety or public health hazard, is necessary to protect
     equipment from damage, or is necessary to  avoid imposing an unreasonable
     financial burden. This term includes operations necessitated by nonroutine failures
     of equipment.

     The repair or replacement of an apartment building's asbestos-insulated boiler that fails

during the winter may be considered an emergency renovation, since to delay repair or

replacement could expose residents of the apartment building to dangerously cold

temperatures. Or, the repair of asbestos-insulated equipment that suddenly fails at a power

plant could result in prolonged power outages and affect many essential services if not

attended to immediately. These are examples of asbestos removal operations that might be

considered emergency renovations.  It is usually the responsibility of the building owner or


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operator to demonstrate that the renovation was an emergency.  The implications for an




emergency renovation in the context of the NESHAP requirements are discussed below.




    B.   Demolition and Renovation Provisions (61.145)




         The demolition  and renovation provisions of the NESHAP contain specific




requirements that may apply in certain emergency situations and include the provisions for




emergency renovation operations and government-ordered demolitions.




         1. Emergency Renovation Operations




            In order for a renovation to be considered an emergency renovation operation




and be subject to the NESHAP, it must satisfy the definitional requirements of an emergency




renovation operation and it must also meet the applicability requirements of Section 61.145




(a)(4)(iv).  Section 61.145 (a)(4)(iv) specifies that for an emergency renovation to be subject




to the notification and control provisions of the NESHAP, the combined amount of regulated




asbestos-containing material (RACM) that is to be stripped or removed as a result of the




emergency, must equal or exceed 260 linear feet of asbestos on pipes or 160 square feet on




other facility components, or 35 cubic feet if the asbestos material is already off the facility




component and the length or area could not be determined previously.




    Notifications for emergency renovation operations that are subject to the NESHAP  must




be given as early as possible before the renovation begins, but no later than the next working




day following the day the emergency renovation begins (61.145 (b)(3)(iii)).  As for all




notices, they must be in writing and may be delivered by U.S. Postal Service, commercial




delivery service, or hand delivery.  The NESHAP does not permit notification by telephone or




telephone facsimile (fax) machines. The information contained in the notice for an




emergency renovation is the same as that required for all notices, except that the following




additional information is also required:




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     •    The date and the hour that the emergency occurred,

     •    A description of the sudden, unexpected event, and

     •    An explanation of how the event caused an unsafe condition, or would cause
          equipment damage or an unreasonable financial burden (61.145 (b)(4)(xv)).


     Emergency renovation operations are subject to the emission control procedures of

 section 61.145 (c). These procedures include removal of asbestos from the facility before any

 activity that would disturb or break up the asbestos, wetting the asbestos during stripping,

 keeping the asbestos that has been removed or stripped wet until collected  or contained for

 disposal, and having an individual on-site who is trained in the provisions of the NESHAP.

 There are no exemptions from emission control procedures for emergency renovation

 operations.

          2.  Government-Ordered Demolitions

             The NESHAP exempts certain types of demolitions from some of the

 notification and emission control requirements.  The applicability provisions in section 61.145

 (a)(3) state that a facility that is being demolished as a result of a government order that is

 issued because the facility is  structurally unsound and in danger of imminent collapse, is

 exempt from the following:

     •    Notification requirement to provide 10 working days advance notice.  Notice for
         such demolitions must be provided as early as possible before demolition and not
         later than the following working day.

         Notification requirement to include the scheduled starting and completion dates of
         asbestos removal.

All other notification requirements apply. In addition, the notice for government-ordered

demolitions must include the name, title, and authority of the State or local government
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representative who ordered the demolition, the date the order was issued, and the date on

which the demolition is ordered to begin.

     As specified in the applicability provisions of 61.145 (a)(3), government-ordered

demolitions are exempt from all but the following emission control procedures:

     •    The requirement to strip or place in leak-tight wrapping all asbestos covered or
         coated facility components that were removed in sections or units (61.145 (c)(4)).

     •    The requirements for large facility components to be removed where the asbestos
         will not be disturbed (61.145 (c)(5)).

         The requirements for RACM that has been stripped or removed (61.145 (c)(6)).

         The requirements during periods of freezing temperatures (61.145 (c)(7)).

     •    The requirement for a person trained in the provisions of the NESHAP to be on site
         (61.145 (c)(8)).

     •    The requirement that all government-ordered demolitions adequately wet the portion
         of the facility that contains RACM during the wrecking operation (61.145  (c)(9)).


     C.  Waste Disposal (61.150)

         For facilities that have been demolished in response to government orders, Section

61.150 (a)(3) requires that the resulting asbestos-containing waste be adequately wetted at all

times after demolition and kept wet during the handling and  loading for transport to a

disposal site.  Such waste may be transported and disposed of in bulk.  All the rest of the

waste disposal provisions in section 61.150 apply, including  the requkements to dispose of

the waste as soon as practical at an  appropriate site, to properly mark vehicles used to

transport the waste, to maintain waste shipment records, to  provide a copy of the waste

shipment record to the disposal site, and to report any waste  for which a copy of the waste

shipment record signed by the disposal site owner or operator is not received from the

disposal site within the prescribed amount of time.
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    D.   Active Waste Disposal Sites (61.154)




         There are no special provisions or exemptions from the NESHAP for any




asbestos-containing waste material that is subject to the asbestos NESHAP.




Asbestos-containing waste from emergency renovations, government-ordered demolitions, or




from any source covered by the NESHAP must be disposed of in compliance with all the




provisions of 61.154.

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  V. PRE-EMERGENCY PLANNING




     In advance of a catastrophic emergency, Regional, state and local NESHAP coordinators




 should take certain steps to ensure that potential asbestos hazards can be adequately managed




 and asbestos exposures minimized. The following sections identify activities that, if




 performed prior to an emergency, should help to ensure an adequate response in the event of




 a catastrophic emergency.




      A. Emergency Response Organization




         Each Regional office should prepare a flow chart for their Region (similar to




 Figure 1) with the names and telephone numbers of contact persons and backups. Copies of




 the completed flow chart should be provided to neighboring Regions.




      An organizational flow chart showing in parallel the levels of government engaged in




 enforcing the asbestos NESHAP and responding to catastrophic emergencies is given in




 Figure 1.  Normal channels for the flow of information, requests for assistance, etc. are shown




 as solid lines connecting the government agencies, while channels that need to be established




 in order to plan for and respond to asbestos encountered in forced demolitions resulting from




 emergencies are shown as dashed lines.  Example emergency telephone lists for Regional,




 state,  and local asbestos NESHAP coordinators are presented in Figures 2, 3,  and 4.  The lists




 are presented for illustrative purposes only; they are not intended to be comprehensive. The




telephone lists needed by a NESHAP coordinator will depend on several factors including, for




example, the extent to which NESHAP authority has been delegated.




     B.  Coordination With Local Emergency and Related Organizations




         The responsible NESHAP coordinators should establish contact with responsible



emergency agencies and inform them of the NESHAP requirements.
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        EPA
Regional Administrator
                                  Other EPA Regions
                                  Asbestos NESHAP
                                    Coordinators
   Division Director
    Section Chief
  Asbestos NESHAP
     Coordinator
     Delegated
       State
 Air Pollution Control
      Agency
        State
Emergency Management
       Agency
     Delegated
       Local
 Air Pollution Control
       Agency
        Local
Emergency Management
       Agency
1

Buildings
Department

i

Fire
Department
    Figure 1. Emergency response structure.
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              Contact
Telephone number
Other EPA Regional asbestos NESHAP
coordinators
State asbestos NESHAP coordinators
        Figure 2.   Example emergency telephone list for
             Regional asbestos NESHAP coordinator.
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Contact
Telephone number
Regional asbestos NESHAP
coordinator
Asbestos NESHAP
coordinators of adjacent
states
Local asbestos NESHAP
coordinators
Local air pollution control
agencies
State emergency management
agency
Landfill operators
Laboratories
Emergency response
organizations
        Figure 3.  Example emergency telephone list for
               state asbestos NESHAP coordinator.
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             Contact
Telephone number
State asbestos NESHAP
coordinator
Other local asbestos NESHAP
coordinators
Local emergency management
agency
Building department
Fire department
Landfill operators
Laboratories
Emergency response organization
        Figure 4.  Example emergency telephone list for
               local asbestos NESHAP coordinator.
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         1.  The Problem




            In the aftermath of catastrophic events that result in significant structural




damage to buildings, fire and buildings departments personnel typically are called upon to




identify those structures that are in imminent danger of collapse. Recent experience with




Hurricane Hugo and the San Francisco earthquake indicates that these personnel are often not




conscious of the presence of asbestos and the hazard it represents.  Nor are they aware that




the NESHAP prescribes minimum work practices that must be followed even in an ordered




demolition resulting from a catastrophic emergency. The first part of the problem then is one




of a lack of awareness of the applicable asbestos regulations on the parts of some local




government  personnel.  It can be remedied by a conscious effort to inform them of the




NESHAP. The second part of the problem is that local emergency personnel, even if they are




aware of asbestos and the NESHAP, may not be qualified to determine whether asbestos is




present in a  structure. Accordingly, an asbestos NESHAP inspector needs to be on the scene.




         2.  Strategy




            As a courtesy, Regional asbestos NESHAP coordinators should contact the




FEMA Regional Directors to explain EPA's interest in asbestos, the NESHAP requirements




applicable to catastrophes, and EPA's plan to inform state and local emergency preparedness




agencies of the NESHAP requirements.  Copies of the regulation and A Guide to the




Asbestos NESHAP. As Revised November  1990 with the relevant portions highlighted should




be made available to FEMA. Names, addresses, and telephone  numbers of FEMA Regional




Directors are given in Appendix B.




     Then the Regional asbestos NESHAP coordinators should recommend that the state air




pollution control agencies in their regions contact their counterpart state emergency




preparedness agencies to inform them of the NESHAP requirements. Again, copies of the




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regulation and Guide should be provided.  The state emergency preparedness agency should




be asked to inform local emergency preparedness agencies that they will be contacted by their




local air pollution control agency, as appropriate.  The state air pollution control agency




should then contact local air pollution control agencies and recommend that they contact the




appropriate local emergency preparedness agencies.  Names, addresses, and telephone




numbers of state officials responsible for disaster operations are given in Appendix C.




     By working through the local emergency preparedness agency, the local air pollution




control agency can reach fire and building department personnel and share the message with




them.  The asbestos NESHAP coordinator should discuss with heads of fire and building




departments their procedures for identifying buildings that need to be demolished and develop




procedures whereby the NESHAP agency can be kept apprised of the location of buildings




that are ordered demolished during emergency situations.




     Many state and local emergency preparedness agencies utilize emergency operations




centers to coordinate emergency response and relief activities in times of disaster.  These




operations centers frequently have communications systems designed to remain intact during




disasters when normal systems, such as telephone lines, may be inoperative.  In their contacts




with state and local emergency preparedness agencies, NESHAP coordinators should discuss




the possibility of having access to these  systems if their normal communication links are




disrupted in an emergency.




     At the local level, plans can be prepared that provide for making asbestos NESHAP




inspectors available to assist in evaluating asbestos problems in buildings following disasters.




State and Regional NESHAP enforcement agencies should plan to respond by providing




additional inspectors if requested and public information services.  A checklist is provided in




Appendix A summarizing suggested lines of communications along with other planning aids.




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      C. Mapping Asbestos Locations




         State and local NESHAP coordinators should, to the extent feasible, determine the




presence and location of asbestos-containing facilities before a catastrophic emergency occurs.




      During an emergency, knowing which structures in the community contain asbestos and




which do not could save time, reduce the risk associated with entering unsafe structures, and




avoid the unnecessary cost of treating the building as though it contained asbestos when in




fact it did not.  Even at the facility level, knowing what equipment, for example, is insulated




with asbestos could be useful in responding to an accident involving that equipment.  Sources




of location information are discussed below and are separated into those for asbestos milling,




manufacturing, and fabricating; and demolition and renovation.




         1.  Asbestos Milling, Manufacturing, and Fabricating




             The most obvious source of information on the location  of asbestos mills,




manufacturers, and fabricators is EPA's own compliance inspection records for these sources.




Where enforcement of the NESHAP has been delegated, the responsible state or local




government should have in its files the names and locations of these sources.




      Additional information on asbestos sources may be available from agencies responsible




for enforcement of occupational safety and health regulations.  OSHA enforcement agencies




will have information on many of the same sources covered by asbestos air pollution




regulations. Typically, however, OSHA rules cover a much wider range of sources than those




covered by the asbestos NESHAP. Many of these additional sources may not be of as great a




concern because they frequently include sources that handle small amounts of asbestos or




asbestos-containing products, such as automobile brake servicing shops and the field




fabrication of asbestos products for construction.
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     Another source of information on asbestos milling, manufacturing, and fabricating




facilities is the Toxic Chemical Release Inventory System (TRIS), a computer system




designed by EPA to track the annual emission of toxic chemicals into the environment. TRIS




compiles toxic emissions information submitted by facilities, including asbestos processing




facilities, regulated under the Superfund Amendments and Reauthorization Act (SARA).




TRIS can be accessed by the name of the pollutant and provide a list of the names and




locations of sources in the data base. Facilities are required to report under TRIS if they




release above a certain amount of the toxic pollutant. If the estimated emissions fall below a




certain level, a facility is not required to submit information and will not be picked up by




TRIS.  TRIS can be accessed by EPA employees and other Federal, state,  and local




government officials on  EPA's National Computer Center (NCC) in Research Triangle Park,




North Carolina.  The user must have an NCC user ID and authorization to access the system.




To obtain  a user ID, contact TRIS User Support at (202) 475-9419.




         2. Asbestos in Facilities




            Facility refers to any institutional, commercial, public, industrial,  or residential




structure, installation,  or building (excluding residential buildings having four or fewer




dwelling units).  There are several potential sources of information that may be used to help




locate asbestos-containing structures within a community.




            a.  Surveys of Buildings for Asbestos




                The  results of an EPA survey of buildings for the presence of asbestos may




be helpful in identifying asbestos-containing faculties.1'2  In addition to estimating the number




of buildings that contained asbestos, the survey also looked at the presence of asbestos in




relation to various building characteristics, including height and age of the building. The




findings of the EPA survey represent the situation on a national basis.  The presence of




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asbestos in buildings may vary from these national averages from one part of  the country to




another for various reasons, such as climate and age of cities.




     Overall, the survey found that 20 percent of all buildings contained asbestos-containing




friable material, either in the form of sprayed- or trowelled-on asbestos, asbestos ceiling tile,




asbestos pipe and boiler insulation, or a combination of two or all three types. Pipe and




boiler insulation was more common (found in 16 percent of the buildings) than sprayed- or




trowelled-on asbestos (found in 5 percent of the buildings).  Asbestos ceiling tile was rarely




found.  Pipe and boiler insulation was generally limited to machine rooms, while sprayed- or




trowelled-on material was usually found exposed to areas of public use rather than behind




drop ceilings or otherwise concealed.




     Relative to the age of buildings, the study found that in buildings built prior to 1960,




most of the asbestos was found as boiler and pipe insulation; after 1960, most of the friable




asbestos was sprayed or trowelled onto ceilings and steel beams, a practice which continued




until 1973 when most sprayed-on uses of asbestos were banned by EPA. Decorative




sprayed-on asbestos was banned in 1978.




     The study also found that taller buildings are more likely to have asbestos-containing




friable material. Of the 19 high-rise buildings (8 or more floors) surveyed, all contained




asbestos pipe and boiler wrap  and 41 percent contained sprayed- or trowelled-on asbestos




material.




     As stated above, the  EPA survey results represent national averages of asbestos-




containing buildings.  The  results may be significantly different in different parts of the




country. For example, in a survey of buildings in New York City for the presence of




asbestos, the results varied significantly from the national averages presented in the EPA




study.3  Overall, 68 percent of buildings in New York City have some form  of asbestos.  The




                                           22

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New York City survey showed that tall office buildings most frequently contained asbestos




and also contained the greatest amount of asbestos. Table 1 presents a summary of the




survey results regarding the percent of buildings with asbestos and the amount of asbestos per




building.




             b.   Schools




                 Information on asbestos in schools is available at the local level as well as




at the state level. Under AHERA, schools are required to inspect their facilities for the




presence of asbestos, document the location of the asbestos and keep this information on site




as well as forward a copy to the responsible state agency.  In some states, the state




department of education will retain copies of this information, while in other states, the state




agency responsible for asbestos programs is the designated state agency responsible under




AHERA.  Each school must also keep a copy of the inspection results in its files. The




Regional Asbestos Coordinators for each region can provide information on state contacts for




information on asbestos in schools. A list of the addresses and telephone numbers for the




Regional Asbestos Coordinators is given in Appendix D.




             c.   Local Building Permit Agencies




                 In most communities, a building permit is required prior to any new




construction.  As part of the application for a building permit, the building plans are reviewed




by the permitting agency to determine that the structure is designed and will be constructed in




accordance with applicable building codes.  Building plans usually specify that a particular




code or standard will be met which, for example, relates to a certain fire rating.  The




specifications which accompany the building plans state what materials are to be used to meet




the code specified in the plans. If asbestos was recommended for a certain application in




order to meet the relevant  codes, the specifications would contain that information. A copy




                                            23

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Table 1.  New York City Survey Results -- Percentage
    of Buildings Containing Asbestos and Average
          Amount  of Asbestos Per Building
Building Category
Tall office buildings
Educational structures
Hotels
Walk-up apartments
Hospitals
Elevator apartments
Churches
One and two family
Outdoor recreation
Short office buildings
Stores
Factories
Theaters
Govt . /transportation
Warehouses/lofts
Garages /gas stations
Source: City of New York I
Average Amount of
Percent of Asbestos per
Buildings Building with
with Asbestos Asbestos (sq. ft.)
84
83
78
74
72
72
71
68
64
64
62
61
57
43
40
17
Department of
64,341
3,233
3,802
457
6,929
4,832
919
167
969
2,109
363
1,759
4,438
8,282
2,393
419
Environmental
    Protection.   Final  Report.   Assessment  of  the  Public's
    Risk of Exposure to In-Place Asbestos.   New York, New
    York.   December 1,  1988.
                          24

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of approved building plans is usually kept by building permit agencies.  Where a copy of the




specifications is also kept by the permitting agency, it could be used to help identify buildings




that contain asbestos.




            d.  Notifications




                A number of large industrial facilities, such as petroleum refineries and




chemical plants, contain large amounts of asbestos in the form of thermal insulation. Many




of these facilities remove asbestos as part of nonscheduled renovation operations in addition




to scheduled renovations and demolitions. Nonscheduled renovations  are typically




maintenance-related or repair-related renovations for which the exact date of occurrence




cannot be predicted, but based on previous experience, are likely to occur.  Because the dates




of these renovations cannot be predicted, facilities where these operations occur often submit




annual, semiannual, or quarterly notices to EPA or its delegated authority describing how




these nonscheduled renovations will be handled to control asbestos emissions.  Notices of




nonscheduled renovations and scheduled renovations and demolitions received from large




industrial facilities identify where asbestos is to be found and in what amounts.




      D.  Cleanup and Disposal




         The responsible NESHAP coordinator should identify critical activities and




resources and develop contingency plans for augmenting or replacing them in an emergency.




      Operations to clean up and dispose of asbestos during emergencies may be hampered by




unusual conditions resulting from the disaster.  Often during disaster-related emergencies, the




normal provider/supplier relationships are disrupted so that business as usual is difficult, if not




impossible. Identified below are some circumstances that could complicate cleanup and




disposal  operations and some suggested approaches to planning for such contingencies.  The
                                           25

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list of considerations is not intended to be complete since any number of complications could



arise.



         1. Water Supply



            Water supplies may be disrupted during disasters making it difficult to wet



asbestos during the demolition or abatement of asbestos-containing structures.  This is likely



to be more of a problem where relatively large quantities of water are needed, for example,
          i


when a building is being demolished upon a government order and the asbestos cannot be



removed prior to demolition.  Large quantities of water will be needed to keep the debris wet



during demolition and during the loading for transport to a disposal site.  However, during an



emergency, adequate water may not be readily available. If possible, such demolitions should



be delayed until the water supply can be restored or until an alternate supply can be obtained.



         2. Chemical Contamination



            Where accidents or emergencies involve industrial facilities, there is the



possibility that any asbestos that is involved may be contaminated with process chemicals.  In



some instances, the chemicals may be hazardous.  Where asbestos is contaminated with toxic



chemicals, other regulations may also apply to their handling and disposal.  For hazardous



chemicals regulated under RCRA, for example, the disposal site requirements are more



stringent than those for asbestos. In some instances, it may not be advisable to apply water to



the contaminated asbestos waste. Usually the emergency response teams that deal with



accidents involving hazardous chemicals will know the best procedures for handling those



chemicals.  Coordination with emergency response teams in these situations should help



ensure that the hazards associated with asbestos are adequately addressed.
                                          26

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         3. Waste Disposal




            Where a large number of asbestos-contaminated facilities are damaged and need




to be demolished without prior removal of the asbestos, a large amount of




asbestos-contaminated waste will be generated.  The existing capacity of the landfills that are




available to accept asbestos waste may be inadequate. Another problem may arise if the




landfill is not accessible as a result of the disaster.  Under these conditions, alternative




disposal sites would be needed. In some cases, it may be possible to arrange with another




local landfill to accept the waste, or it may be necessary to transport the waste to more distant




sites. Alternative sites should be identified in advance, if possible.  To the extent possible,




uncontaminated demolition waste should  be segregated from the asbestos-contaminated debris




to reduce the volume that has to be disposed of in accordance with the NESHAP.  NESHAP




coordinators should establish emergency contacts for landfills and agree on emergency




procedures in advance for accepting and handling asbestos-containing waste.




         4.  Backup Personnel




             It may be necessary to have additional enforcement personnel available to




oversee asbestos cleanup and disposal operations, since decisions may have to be made at the




same time at numerous locations regarding appropriate actions to take.  Cleanup operations




that go on around the clock may require  inspections after normal working hours to make sure




work is being done properly.  Additional NESHAP inspectors may be available from other




NESHAP delegated local agencies, the state, the Region, or from other states.




          5.  Laboratory Capabilities




             Large numbers of bulk samples may require quick analysis before NESHAP




enforcement personnel can make decisions on appropriate actions to take. Arrangements




should be made for additional laboratory support to handle a potentially large number of




                                           27

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samples. In addition, consideration should be given to arranging for overnight analysis of




bulk samples.  This would allow for the results from the analysis of samples collected one




day to be available to enforcement personnel at the beginning of the next day.




         6.  Emergency Exemptions




            Although the NESHAP contains provisions for emergency renovations and




ordered demolitions, the nature of the emergency may require some flexibility in enforcing




the NESHAP.  For example, the NESHAP requires a written notice beforehand, but in no




case later than the following working  day, for ordered demolitions.  It is conceivable that,




under catastrophic emergency conditions, normal mail delivery services and transportation




systems would be so disrupted  as to make it impossible to deliver a written notice in the time




period specified by the NESHAP.  The responsible NESHAP coordinator should be aware




that situations may arise that make strict application of the NESHAP difficult, if not




impossible.  While it is not possible to know in advance all the scenarios that may require




flexibility in applying the NESHAP, it would be advisable to discuss predictable problems




with agency management as well as with other NESHAP enforcement agencies at  the




appropriate Regional, state, or local level.
                                          28

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 VI. EMERGENCY PERIOD

    When a catastrophic emergency occurs, the responsible NESHAP coordinator should

implement those plans developed prior to the emergency. Listed below are some of the more

significant actions to be taken.  Specific actions to be taken will, of course, depend  on the

nature of the emergency.

    •    Contact those agencies listed in the emergency response structure (see Figure 1).

    •    Assess the need to issue press release(s).

    •    Through contact with building and fire departments, determine magnitude  of the
         problem, i.e., number of damaged structures.

    •    Activate previously established procedures with fire and building departments to be
         kept informed of buildings that are ordered to be demolished.

    •    Assess need for additional resources, e.g., inspectors, laboratory capabilities, etc. and
         take steps, as necessary, to augment existing resources.

    «    Provide guidance to delegated agencies, as appropriate.

    •    Assess need to allow selected exemptions to the NESHAP requirements.

    •    Make periodic contacts with agencies listed in the emergency response structure, as
         needed.
                                           29

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vn. CONCLUSIONS




    Efforts to restore the damaged areas to their predisaster condition often involve removing




or repairing damaged structures.  There may be a natural tendency at this stage to overlook




certain hazards, such as asbestos, that are not immediately life threatening. However, such




hazards are serious and may manifest themselves many years from the time of exposure and




should be taken into consideration. Given the health hazards associated with asbestos




exposure, it is reasonable that adequate measures be taken during emergency situations to




minimize exposure to asbestos from the demolition or renovation of buildings. The




applicability of the asbestos NESHAP is not altered as the result of a disaster.  With a few




exceptions for emergency renovations and government-ordered demolitions, all of the




NESHAP requirements are applicable in emergency situations.




    One of the key factors in effectively dealing with asbestos in emergency  situations is




communications.  Communications are needed between the asbestos NESHAP coordinator and




the other emergency response agencies and related agencies.  The first step is for the




Regional asbestos NESHAP coordinator to discuss this matter with Regional FEMA personnel




and assure them of EPA's desire to cooperate with FEMA and other emergency response




agencies. The next step is for the Regional EPA offices to inform their respective state




NESHAP enforcement agencies of the need to coordinate efforts. The delegated state




NESHAP agency should then contact the state emergency preparedness office to discuss the




need to consider asbestos in emergency situations.  Finally, the same communications should




occur at the local level.




    This guidance document is intended to assist asbestos NESHAP coordinators in dealing




with asbestos during catastrophic emergency situations. It provides suggestions for




coordinating with other local and state emergency-related agencies, information  on applicable




                                          30

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statutes and regulations, possible sources of information to help locate asbestos in a




community, and special considerations relevant to clean up and disposal. This  document will




be most useful for advanced planning for emergency situations, although it will still find use




when a disaster strikes.
                                            31

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REFERENCES


1.  U.S. Environmental Protection Agency. Asbestos in Buildings:  A National Survey of
    Asbestos-Containing Friable Materials. EPA 560/5-84-006. Washington, DC.  June
    1984.  260 p.

2.  U.S. Environmental Protection Agency. Additional Analysis of EPA's 1984 Asbestos
    Survey Data. EPA 560/5-88-010. Washington, DC.  September 1988.  87 p.

3.  New York City Department of Environmental Protection.  Assessment of the Public's
    Risk of Exposure to In-place Asbestos. New York, NY. December 1, 1988.
                                         32

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            APPENDIX A

  ASBESTOS NESHAP CHECKLIST FOR
CATASTROPHIC EMERGENCY SITUATIONS
                33

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                                  Appendix A

                     ASBESTOS NESHAP CHECKLIST FOR
                  CATASTROPHIC EMERGENCY SITUATIONS
1.  Regional Coordination Activities

   Regional FEMA
   Other regional NESHAP coordinators
   Delegated state NESHAP agencies

2.  State Coordination Activities

   State emergency preparedness agencies
   Delegated local NESHAP agencies

3.  Local Coordination Activities

   Local emergency preparedness agencies
   Local building departments
   Local fire departments

4.  Link with Emergency Communication System

5.  Emergency Telephone List

6.  Alternate Water Supplies

7.  Coordination with Emergency Response Agency for Hazardous Chemical Contamination

8.  Alternate Waste Disposal Sites

9. Additional Asbestos Inspectors

10. Laboratory Support

11. Press Releases
                                       34

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       APPENDIX B
FEMA REGIONAL DIRECTORS
           35

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                                   Appendix B
                          FEMA REGIONAL DIRECTORS
Region I
Mr. Richard H. Strome
Regional Director
Federal Emergency Management Agency
J.W. McCormack, Post Office and
  Court House, Room 442
Boston, Massachusetts  02109

FTS:  223-9540; Commercial: (617) 223-9540; FAX:  223-9519

Region n

Mr. Phillip Mclntire
Regional Director (Acting)
Federal Emergency Management Agency
26 Federal Plaza, Room 1338
New York, New York  10278

FTS:  649-8208; Commercial: (212) 238-8202; FAX:  238-8245

Region ffl

Mr. Paul Giordano
Regional Director
Federal Emergency Management Agency
Liberty Square Building (Second Floor)
105 S. Seventh Street
Philadelphia, Pennsylvania 19106

FTS:  489-5608; Commercial: (215) 931-5608; FAX:  489-5513

Region IV

Mr. Major P. May
Regional Director
Federal Emergency Management Agency
1371 Peachtree Street, N.E., Suite 700
Atlanta, Georgia 30309

FTS:  230-4200; Commercial: (404) 853-4200; FAX:  230-4230
                                        36

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 Region V

 Mr. Arlyn F. Brower
 Regional Director
 Federal Emergency Management Agency
 175 W. Jackson Boulevard (Fourth Floor)
 Chicago, Illinois 60604

 FTS:  363-5501; Commercial:  (312) 408-5501; FAX:  363-5521

 Region VI

 Mr. Bradley M. Harris
 Regional Director
 Federal Emergency Management Agency
 Federal Regional Center
 800 N. Loop 288, Room 206
 Denton, Texas 76201-3698

 FTS:  749-9104;  Commercial:  (817) 898-9104; FAX:  749-9290

 Region VH

 Mr. S. Richard Mellinger
 Regional  Director
 Federal Emergency Management Agency
 Old Federal Office Building
 911 Walnut Street, Rom 200
Kansas City, Missouri  64106

FTS:  759-7061; Commercial:  (816) 283-7061; FAX:  759-7504

Region
Dr. Marian L. Olson
Regional Director
Federal Emergency Management Agency
Denver Federal Center, Building 710
Box 25267
Denver,  Colorado  80225-0267

FTS:  322-4812; Commercial: (303) 235-4815; FAX: 322-4976
                                        37

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Region IX

Mr. William M. Medigovich
Regional Director
Federal Emergency Management Agency
Building 105
Presidio of San Francisco
San Francisco, California  94129

FTS:  469-7100; Commercial:  (415) 923-7100; FAX:  469-7157

Region X

Mr. Raymond C. Williams
Regional Director (Acting)
Federal Emergency Management Agency
Federal Regional Center
130 228th Street, S.W.
Bothell, Washington 98021-9796

FTS:  390-4604; Commercial:  (206)487-4604: FAX: 390-4707
Source:  Directory of Governors, State Officials and Adjutants General Responsible for
         Disaster Operations and Emergency Planning, FEMA-9.  Washington, D.C.:  Federal
         Emergency Management Agency, July 1990.
                                         38

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          APPENDIX C
STATE OFFICIAL RESPONSIBLE FOR
     DISASTER OPERATIONS
              39

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                                            Appendix C
                               STATE OFFICIAL RESPONSIBLE
                                FOR DISASTER OPERATIONS
STATE          STATE EMERGENCY DIRECTOR

ALABAMA      Mr. William O. Brock
                Director, Alabama Emergency
                 Management Agency
                520 South Court Street
                Montgomery, Alabama 36130

                (205) 834-1375
ALASKA
AMERICAN
SAMOA
Mr. Ervin P. Martin
Director, Division of Emergency
Services, Dept. of Military
 and Veterans Affairs
3501 E. Bogard Road
Wasilla, Alaska  99687-2689

(907) 376-2337
Mr. Maiava (Oliver) F. Hunkin
Disaster Program Coordinator
  Department of Public Safety
American Samoa Government
P.O. Box 1086
Fagatogo, American Samoa  96799

011-684-633-2331
ARIZONA       Mr. William D. Lockwood
                Director, Arizona Division of
                 Emergency Services
                National Guard Building
                5636 East McDowell Road
                Phoenix, Arizona 85008

                (602) 244-0504
                                          RESPONSIBLE SENIOR
                                             OFFICIAL

                                          same
Maj. Gen. John W.Schaeffer
The Adjutant General
Dept. of Military
Veterans Affairs
1800 E. Dimond Boulevard
Suite 3-450
Anchorage, Alaska
99515-2097

(907) 249-1565

Mr. Tuilefano M. Vaela's
Acting Commissioner of
 Public Safety, Depart-
 ment of Public Safety
American Samoa Government
P.O. Box 1086
Fagatogo, American Samoa
96799

011-684-633-1111

Maj. Gen. Donald L. Owens
The Adjutant General
National Guard Building
5636 East McDowell Road
Phoenix, Arizona  85008

(602) 273-9710
                                             40

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ARKANSAS
CALIFORNIA
COLORADO
Mr. James Lee Witt
Dkector, Office of Emergency
 Services
P.O. Box 758
Conway, Arkansas 72032

(501) 329-5601, Ext. 201
(501) 374-1201 (Little Rock)

Mr. Donald R. Irwin
Dkector, Office of Emergency
 Services, State of California
2800 Meadowview Road
Sacramento, California
95832-1499

(916) 427-4201

Mr. Richard E. Hatten
Dkector, Disaster Emergency
 Services
EOC, Camp George West
Golden, Colorado  80401

(303) 273-1624
Same
CONNECTICUT
DELAWARE
Mr. Frank Mancusco
State Dkector, Office of
 Emergency Management
360 Broad Street
Hartford, Connecticut  06105

(203) 566-3180/4338
FAX (203) 247-0664

Mr. James W. Hoffman
Dkector, Division of Emergency
 Planning and Operations
P.O. Box 527
Delaware City, Delaware  19706

(302) 834-4531
Same
Mr. David J. Thomas
Executive Dkector
Colorado Department of
 Public Safety
700 Kipling Street
Suite 3000
Lakewood, Colorado
80215-5865

(303) 239-4398

Same
Mr. Patrick W. Murray
Secretary of Public Safety
Department of Public Safety
Highway Administration
 Building
Dover, Delaware  19901
(302) 736-4321
                                             41

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DISTRICT
OF
COLUMBIA
FLORIDA
GEORGIA
GUAM
HAWAII
Mr. Joseph P. Yeldell
Dkector, Office of Emergency
 Preparedness
2000 14th Street, NW, Eighth FL.
Washington, DC 20009

(202) 727-6161

Mr. Gordon L.  Guthrie
Director, Division of Emergency
 Management
2740 Centerview Drive
Tallahassee, Florida  32399

(904) 487-4918

Mr. Billy J. Clack
Executive Director, Georgia
Emergency Management Agency
P.O. Box 18055
Atlanta, Georgia 30316-0055

(404) 624-7000
Mr. Jose T. Terlaje
Dkector, Civil Defense/Guam
Emergency Services Office
Territory of Guam
P.O. Box 2877
Agana, Guam 96910

011-671-477-9841

Mr. Roy C. Price, Sr.
Vice Director of Civil Defense
Department of Defense
3949 Diamond Head Road
Honolulu, Hawaii 96816

(808)734-2161
Same
Mr. Tom Pelham
Secretary, Department of
 Community Affairs
2740 Crestview Drive
Tallahassee, Florida 32399

(904) 488-8466

*Maj. Gen. Joseph W. Griffin
The Adjutant General and
 Dkector, Georgia Emergency
 Management Agency
P.O. Box 18055
Atlanta, Georgia 30316-0055

(404) 624-6000

Same
*Maj. Gen. Alexis T. Lum
The Adjutant General of the
National Guard and Dkector
  of Civil Defense
Department of Defense
3949 Diamond Head Road
Honolulu, Hawaii 96816

(808) 734-2195
                                              42

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IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
Mr. Darrell G. Waller
Coordinator, Bureau of
  Disaster Services
Military Division
650 West State Street
Boise, Idaho  83720

(208) 334-3460

Mr. John Plunk, Acting Director
Illinois Emergency Services
  and Disaster Agency
110 East Adams Street
Springfield, Illinois  62706

(217) 782-6818 - FTS 372-7851

Mr. Jerome Hauer, Director
Indiana State Emergency
  Management Agency
State Office Building, Room 315
100 North Senate Avenue
Indianapolis, Indiana 46204

(317) 232-3830 - FTS 372-7852

Ms. Ellen Gordon
Administrator, Disaster Services
  Division
Hoover State Office  Bldg.
Level A, Room 29
Des Moines, Iowa 50319

(515)272-5211
Vacant
Deputy Director, Division
 of Emergency Preparedness
P.O. Box C-300
Topeka, Kansas 66601

(913) 233-9253 X 301
Maj. Gen. Darrell V.
  Manning
The Adjutant General
Military Division
P.O. Box 45
Boise, Idaho  83707

(208) 385-5242

Same
Same
Maj. Gen. Warren G. Lawson
The Adjutant General and
  Executive Dkector
Department of Public
  Defense
Camp Dodge
7700 N.W. Beaver Drive
Johnston, Iowa  50131-1902

(515) 278-9211

Maj. Gen. Phillip B. Finley
The Adjutant General and
Dkector, Division of
Emergency Services
P.O. Box C-300
Topeka, Kansas 66601

(913) 233-7560 X 101
                                               43

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KENTUCKY
LOUISIANA
MAINE
MARSHALL
ISLAND
Mr. James H. "Mike" Molloy
Executive Director, Kentucky
Disaster and Emergency Services
Boone Center, Parkside Drive
Frankfort, Kentucky  40601

(502) 564-8680
Mr. Robert Warren, Director
Office of Emergency Preparedness
Department of Public Safety
P.O. Box 66536, Audubon Station
Baton Rouge, Louisiana 70896

(504) 342-5470
Mr. David D. Brown
Director, Maine Emergency
  Management Agency
State Office Bldg., Station 72
Augusta, Maine  04333

(207) 289-4080
FTS: 289-4080
Mr. Phil Kabua
Disaster Control Officer,
  Republic of the Marshall
  Islands
Majuro, Marshall Islands  96960

93-011-692-9-3234
Brig. Gen. Michael W.
 Davidson
The Adjutant General and
State Director of Disaster
 and Emergency Services
Boone National Guard Center
Frankfort, Kentucky  40601
Attn:  James H. Molloy

(502) 564-8558

Col. (Ret.) Marlin A.
 Flores
Deputy Secretary
Department of Public Safety
P.O. Box 66614
Baton Rouge, Louisiana
70896

(504)925-6117

Gen. Ernest Park
The Adjutant  General and
  Commissioner, Department
  of Defense and Veterans
  Services
Maine National Guard
Camp Keyes
Augusta, Maine 04333

(207) 626-4225

Mr. Phil Kabua
Republic of the Marshall
  Islands
Majuro, Marshall Islands
96960
                                               44

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MARYLAND
Mr. David A. McMillion
Dkector, Maryland Emergency
  Management Agency
Two Sudbrook Lane, East
Pikesville, Maryland 21208

(301) 486-4422
FTS 486-4422
MASSACHUSETTS
                Mr. Robert J. Boulay
                Director, Massachusetts Civil
                Defense Agency and Office of
                  Emergency Preparedness
                400 Worcester Road
                Framingham, Massachusetts
                01701
MICHIGAN
MICRONESIA
(508) 820-2000

Dave Charney
State Director
Emergency Management Division
 Michigan State Police
300 S. Washington Square,
 Suite 300
Lansing, Michigan 48913

(517) 373-6271 - FTS 372-7853
Mr. Ehson D. Johnson
Dkector, Disaster Control
 Officer
The Federated States
 of Micronesia  96941

(Oil) 691-9228
Brig. Gen. John Barshay
Maryland Military
  Department
National Guard
5th Regiment Armory
29th Division Street
Baltimore, Maryland 21201

(301) 764-4004
Mr. Charles V. Barry
Secretary, Department of
  Public Safety
One Ashburton Place,
  Room 2133
Boston, Massachusetts
02108

(617) 727-7775

Col. R. T. Davis
Acting Dkector, Department
  of State Police and State
  Division of Emergency
  Services
714 S. Harrison Road
East Lansing, Michigan
48823

(517) 337-6157

Same
                                              45

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MINNESOTA
MISSISSIPPI
MISSOURI
 MONTANA
 NEBRASKA
Mr. Thomas Motherway
Director, Division of Emergency
  Services
Department of Public Safety
State Capitol, B-5
St. Paul, Minnesota  55155

(612) 296-2233 - FTS 372-7854

Mr. James E. Maher
Director, Emergency Management
  Agency
P.O. Box 4501, Fondren Station
Jackson, Mississippi 39216

(601) 352-9100

Mr. Richard D. Ross
Director, State Emergency
  Management Agency
P.O. Box 116
Jefferson City, Missouri
65102

(314) 751-9571

Mr. F. Guy Youngblood
Administrator, Disaster
  and Emergency Services
  Division
Department of Military Affairs
P.O. Box 4789
Helena, Montana 59604-4789

(406) 444-6911

Mr. Richard L. Semm
Assistant Director, Nebraska
  Civil Defense Agency
National Guard Center
 1300 Military Road
 Lincoln, Nebraska 68508

 (402) 473-1410
Mr. Paul Tschida
Commissioner, Department
 of Public Safety
211 Transportation Bldg.
St. Paul, Minnesota 55155

(612) 296-6642
Same
Maj. Gen. Charles Kiefher
The Adjutant General
1717 Industrial Drive
Jefferson City, Missouri
65101

(314) 751-9710
 Maj. Gen. James W. Duffy
 The Adjutant General
 Department of Military
  Affairs
 P.O. Box 4789
 Helena, Montana 59604

 (406) 444-6910
 Maj. Gen. Stanley M. Heng
 The Adjutant General and
 Director, Nebraska Civil
  Defense Agency
 National Guard Center
 1300 Military Road
 Lincoln, Nebraska 68508

 (402)473-1100
                                               46

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NEVADA
NEW
HAMPSHIRE
NEW JERSEY
NEW MEXICO
Mr. Robert R. King
Dkector, Nevada Division
  of Emergency Services
Military Department
2525 S. Carson Street,
Capitol Complex
Carson City, Nevada  89710

(702) 885-4240

Colonel George Iverson
Director, Governor's Office
  of Emergency Management
State Office Park South
107 Pleasant Street
Concord, New  Hampshire 03301

(603) 271-2231
FAX (603) 225-7341

Maj. Joseph J.  Craparotta
Deputy State Dkector
Office of Emergency Management
  New Jersey State Police
P.O. Box 7068
West Trenton, New Jersey 08628

(609) 882-2000

Mr. Thomas H. Johnson
Dkector, Technical and
  Emergency Support Division
Department of Public Safety
4491 CerrUlos Road
P.O. Box 1628
Santa Fe, New Mexico  87504

(505) 827-3375
Maj. Gen. Robert Dwyer
The Adjutant General
Military Department
2525 S. Carson Street,
Capitol Complex
Carson City, Nevada  89710

(702) 887-7302
Same
Justin J. Dintino
Superintendent of State
  Police
P.O. Box 7068
West Trenton, New Jersey
08628

(609) 882-2000

Col. Robert Kemble
Secretary, Office of the
  Secretary
Department of Public Safety
4491 Cerrillos Road
P.O. Box 1628
Santa Fe, New  Mexico 87504

(505) 827-3370
                                              47

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NEW YORK
NORTH
CAROLINA
NORTH
DAKOTA
NORTHERN
MARIANA
ISLANDS
Mr. Donald A. DeVito
Dkector, State Emergency
 Management Office
Division of Military and
 Naval Affairs
Public Security Bldg.
State Campus
Albany, New York  12226-5000

(518) 457-2222

Mr. Joseph F. Myers
Director, North Carolina
Division of Emergency
 Management
Administration Building
116 West Jones Street
Raleigh, North Carolina 27611

(919) 733-3867

Mr. Ronald D. Affeldt
Dkector, North Dakota Division
 of Emergency Management
P.O. Box 5511
Bismarck, North Dakota
58502-5511

(701) 224-2111

Mr. Felix A. Sasamoto
Disaster Control Officer
Office of the Governor
Commonwealth of the Northern
 Mariana Islands
Saipan, Mariana Islands 96950

011-670-322-9529/9572
Maj. Gen. Lawrence P. Flynn
Adjutant General, NYS
 Division of Military and
 Naval Affairs
330 Old Niskayuna Road
Latham, New York
12110-2224

(518) 786-4502
Mr. Joseph W. Dean
Secretary, Department of
  Crime Control and
  Public Safety
P.O. Box 27687
Raleigh, North Carolina
27611

(919) 733-2126

Maj. Gen.  Alexander
  MacDonald
The Adjutant General
P.O. Box 5511
Bismarck,  North Dakota
58502-5511

(701) 224-5102

Same
                                              48

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 OHIO
 OKLAHOMA
 OREGON
 Mr. Dale W. Shipley
 Deputy Dkector, Ohio
   Emergency Management
   Agency
 2825 West Granville Road
 Columbus, Ohio 43235-2712

 (614) 889-7155
 FTS 372-7855

 Mr. Woodrow Goins
 Director, Oklahoma Civil
   Defense Agency
 P.O. Box 53365
 Oklahoma City, Oklahoma 73152

 (405) 521-2481

 Ms. Myra T. Lee
 Administrator, Emergency
  Management Division
 Executive Department
 603 Chemeketa Street, NE
 Salem, Oregon 97310

 (503) 378-4124
PENNSYLVANIA
PUERTO
RICO
                Mr. Joseph LaFleur
                Director, Pennsylvania
                  Emergency Management Agency
                Transportation and Safety
                Building, B-151
                Harrisburg, Pennsylvania  17120

                (717) 783-8150
Mr. Heriberto Acevedo
Dkector, State Civil
  Defense Agency
P.O. Box 5127
San Juan, Puerto Rico 00906

(809) 724-0124
 Adjutant General's
   Department
 Ohio Emergency Management
   Agency
 2825 West Granville Road
 Columbus, Ohio 43235-2712
 Attn:  Dale W. Shipley

 (614) 889-7150

 Same
                                                            Mr. Fred Miller, Director
                                                            Executive Department
                                                            15 Cottage Street, NE
                                                            Salem, Oregon  97310

                                                            (503) 378-3104
Lt. Gov. Mark S. Singel
Chairman, Pennsylvania
  Emergency Management
  Council
State Capitol
Harrisburg, Pennsylvania
17120

(717) 787-3300

Same
                                             49

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RHODE
ISLAND
SOUTH
CAROLINA
 SOUTH
 DAKOTA
 TENNESSEE
Mr. Edward A. Cotugno
Executive Dkector, Rhode Island
  Emergency Management Agency
State House
Providence, Rhode Island 02903

(401) 421-7333
FAX (401) 751-0827
Mr. Paul Lunsford
Dkector, Emergency Preparedness
  Division
1429 Senate Street
Columbia, South Carolina 29201

(803) 734-8020
 Mr. Gray N. Whitney
 Dkector, Division of Emergency
  and Disaster Services
 Department of Military Affaks
 EOC-State Capitol
 Pierre, South Dakota
 57501-5060

 (605) 773-3231

 Mr. Lacy E. Suiter
 Dkector, Tennessee Emergency
  Management Agency
 3041 Sidco Drive
 Nashville, Tennessee 37204

 (615) 252-3300
Maj. Gen. Andre Trudeau
The Adjutant General and
 Dkector, Rhode Island
 Emergency Management
 Agency
Armory of Mounted Commands
1051 North Main Street
Providence, Rhode Island
02904

(401) 277-2100

Maj. Gen. T. Eston Marchanit
The Adjutant General
Rembert C. Dennis Building
1000 Assembly Street
Columbia, South Carolina
29201

(803) 748-4200

Maj. Gen. Harold J. Sykora
The Adjutant General
State Dkector of Civil
  Defense
State Capitol
Pierre, South Dakota
57501-5060

(605) 773-5340

Maj. Gen. Carl Wallace
The Adjutant General
3041 Sidco Drive
Nashville, Tennessee  37204

 (615) 252-3001
                                               50

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TEXAS
TRUST
TERRITORY
OF THE
PACIFIC
UTAH
VERMONT
Mr. Robert A. Lansford
State Coordinator, Division of
  Emergency Management
Texas Department of Public
  Safety
Box 4087, N. Austin Station
Austin, Texas 78773

(512) 465-2000 x 2138

Mr. Charles Jordan
Chief, Office of Planning
  and Statistics
Office of the High Commissioner
Trust Territory Headquarters
Saipan, Mariana Islands 96950

011-670-322-9333

Mrs. Lorayne Frank
Director, Division of
Comprehensive Emergency
  Management
Department of Public Safety
1543 Sunnyside Avenue
Salt Lake City, Utah 84105-0136

(801) 533-5271

Mr. George Lowe
Director, State of Vermont
Department of Public Safety
Division of Emergency Management
  Waterbury State Complex
103 S. Main Street
Waterbury, Vermont 05676

(802) 244-8721
FAX (802) 244-8655
Mr. Joe E. Milner
Director, Texas Department of
  Public Safety and Division
  of Emergency Management
Box 4087, N, Austin Station
Austin, Texas  78773

(512) 465-2000 x 370
Same
Mr. D. Douglas Bodiero
Commissioner, Department
  of Public Safety
4501 South 2700 West
Salt Lake City, Utah 84119

(801) 965-4463
Mr. Charles E. Bristow
Commissioner, Department of
 Public Safety
103 S. Main Street
Waterbury, Vermont 05676

(802) 244-8718
                                              51

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VIRGINIA      Mr. Addison E. Slayton, Jr.
                State Coordinator
                Office of Emergency Services
                310 Turner Road
                Richmond, Virginia  23225

                (804) 674-2497
VIRGIN        Mr. William S. Harvey
ISLANDS       Director, Virgin Island
                  Territorial
                VITEMA
                #3-4 King Street
                Christiansted, US VI  00820

                (809) 774-2244
WASHINGTON Ms. Kate Heimbach
                Assistant Director,
                Division of Emergency Management
                Dept. of Community Development
                4220 East Martin Way, PT-11
                Olympia, Washington  98504-8611

                (206) 753-5255
WEST
VIRGINIA
 WISCONSIN
Mr. Bill R. Joplin
Acting Dkector, West Virginia
Office of Emergency Services
State Capitol Complex, EB 80
Charleston, West Virginia 25305

(304) 348-5380

BG Richard I. Braund, USNG (Ret.)
Administrator, Division of
  Emergency Government
Department of Administration
4802 Sheboygan Avenue, Rm. 99A
Madison, Wisconsin 53707

(606) 266-3232  - FTS 372-7856
Col. Robert Suthard
Secretary, Department of
Public Safety
Ninth Street Office Bldg.
Sixth Floor
Richmond, Virginia
23225-6491

(804) 786-5351

Maj. Gen. Charles Hood
The Adjutant General
Virgin Islands Territorial
Emergency Management Agency
Foreign Arrivals Bldg.
Alexander Hamilton Airport
St. Croix, US 00850

(809) 772-7443

Mr. Chuck Clarke
Dkector, Department of
Community Development
  State of Washington
Ninth & Columbia Building,
MS/GH-51
Olympia, Washington
98504-4151

(206) 753-5625

Same
 BG Jerald D. Slack
 The Adjutant General
 Wisconsin National Guard
 3020 Wright Street
 Madison, Wisconsin 53708

 (608) 241-6312
                                               52

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WYOMING      Mr. Edwin S. Usui
                 Coordinator, Wyoming Disaster
                  and Civil Defense Division
                 P.O. Box 1709
                 Cheyenne, Wyoming  82003

                 (307) 777-7566
                                             Maj. Gen. Charles Wing
                                             The Adjutant General
                                             P.O. Box 1709
                                             Cheyenne, Wyoming  82003

                                             (307) 772-6233
Source:
Directory of Governors, State Officials and Adjutants General Responsible for Disaster
Operations and Emergency Planning, FEMA-9.  Washington, DC:  Federal Emergency
Management Agency, July 1990.
                                              53

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          APPENDIX D
REGIONAL ASBESTOS COORDINATORS
                54

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                                     Appendix D

                      REGIONAL ASBESTOS COORDINATORS
 Regional Asbestos Coordinator,
 US EPA, Region I
 JFK Federal Building
 Boston, MA  02203
 (617) 565-3835

 Regional Asbestos Coordinator
 US EPA, Region 2
 Woodbridge Avenue
 Edison, NJ 08837
 (201) 321-6671

 Regional Asbestos Coordinator
 US EPA, Region 3
 841 Chestnut Street
 Philadelphia, PA  19107
 (215) 597-3160

 Regional Asbestos Coordinator
 US EPA, Region 4
 345 Courdand Street
 Atlanta, GA 30365
 (404) 347-5014

Regional Asbestos Coordinator
US EPA, Region 5
230 South Dearborn Street
Chicago, IL  60604
(312) 353-6003
 Regional Asbestos Coordinator
 US EPA, Region 6
 Allied Bank Tower
 1445 Ross Avenue
 Suite 1200
 Dallas, TX 75720
 (214) 655-7244

 Regional Asbestos  Coordinator
 US EPA, Region 7
 726 Minnesota Avenue
 Kansas City, KS 66101
 (913) 551-7381

 Regional Asbestos Coordinator
 US EPA, Region 8
 One Denver Place
 999 18th Street
 Suite  500
 Denver, CO  80202-2405
 (303) 293-1442

 Regional Asbestos Coordinator
 US EPA, Region 9
 75 Hawthorne Street
 San Francisco, CA  94105
 (415)  556-5406

Regional Asbestos Coordinator
US EPA, Region 10
 1200 6th Avenue
Seattle, WA  98101
(206) 442-4762
                               *U.S. Government Printing office : 1992 -  312-014/40056
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