United States -.'.- ..
Environmental Protection
Agency ' j , -
^Air &nd Radiation (EN4341W)
EPA 340/1-90-018,
December 1990
Asbestos/NESHAP
Regulated Asbestos
Containing Materials
Guidance
-------
-------
EPA 340/1-90-018
ASBESTOS NESHAP
REGULATED ASBESTOS CONTAINING
MATERIALS GUIDANCE
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
December, 1990
-------
-------
CONTENTS
Section Page
1. INTRODUCTION 6
2. FRIABLE ASBESTOS-CONTAINING MATERIALS ... 8
3. NON-FRIABLE ASBESTOS-CONTAINING
MATERIALS 9
Category I Nonfriable ACM 10
Category H Nonfriable ACM 11
4. INSPECTION PROCEDURES TO DETERMINE
THE POTENTIAL FOR FIBER RELEASE
FROM NONFRIABLE ASBESTOS-
CONTAINING MATERIALS 13
Friability Determination Decision
Trees 14
* General Inspection Procedures 16
Specific Inspection Procedures 17
Category I Nonfriable ACM 17
Category H Nonfriable ACM 19
APPENDICES
A Asbestos NESHAP Coordinators
(For Demolition/Renovation Activities) A-l
B Regional Asbestos Coordinators
(For Schools) B-l
-------
-------
1. INTRODUCTION
Section 112 of the Clean Ak Act (CAA) requires EPA to develop
emission standards for hazardous air pollutants. In response to this
section the Environmental Protection Agency (EPA) published a list
of hazardous air pollutants and promulgated the "National Emission
Standards for Hazardous Ak Pollutants" (NESHAP) regulations.
Since asbestos presents a significant risk to human health as a result
of air emissions from one or more source categories, it is therefore
considered a hazardous ak pollutant. The Asbestos NESHAP (40
CFR 61, Subpart M) addresses milling, manufacturing and
fabricating operations, demolition and renovation activities, waste
disposal issues, active and inactive waste disposal sites and asbestos
conversion processes.
In the initial Asbestos NESHAP rule promulgated in 1973, a
distinction was made between building materials that would readily
release asbestos fibers when damaged or disturbed and those
materials that were unlikely to result in significant fiber release. The
terms "friable" and "non-friable" were used to make this distinction.
EPA has since determined that, if severely damaged, otherwise
nonfriable materials can release significant amounts of asbestos
fibers.
Friable asbestos-containing material (ACM), is defined by the
Asbestos NESHAP, as any material containing more than 1 percent
asbestos as determined using the method specified in Appendix A,
Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy
(PLM), that, when dry, can be crumbled, pulverized or reduced to
powder by hand pressure. (Sec. 61.141)
Nonfriable ACM is any material containing more than 1 percent
asbestos as determined using the method specified in Appendix A,
Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy
-------
ACKNOWLEDGEMENTS
This document was written by Alliance Technologies, Inc.,
based on discussions with a work group from EPA. The group
consisted of the Regional Asbestos NESHAP Coordinators, Ron
Shafer, Scott Throwe, and Omayra Salgado of the Stationary Source
Compliance Division, Charles Garlow and Elise Hoerath of the Air
Enforcement Division and Sims Roy of the Standards Development
Branch. We thank the individuals who reviewed an earlier draft and
provided comments, many of which are incorporated in the final
version. Their input is gratefully acknowledged.
-------
(PLM), that, when dry, cannot be crumbled, pulverized, or reduced
to powder by hand pressure. EPA also defines two categories of
nonfriable ACM, Category I and Category II nonfriable ACM, which
are described later in this guidance.
"Regulated Asbestos-Containing Material" (RACM) is (a) friable
asbestos material, (b) Category I nonfriable ACM that has become
friable, (c) Category I nonfriable ACM that will be or has been
subjected to sanding, grinding, cutting or abrading, or (d) Category n
nonfriable ACM that has a high probability of becoming or has
become crumbled, pulverized, or reduced to powder by the forces
expected to act on the material in the course of demolition or
renovation operations.
The purpose of this document is to assist asbestos inspectors and the
regulated community in determining whether or not a material" is
RACM and thus subject to the Asbestos NESHAP.
The recommendations made in this guidance are solely
recommendations. They are not the exclusive means of complying
with the Asbestos NESHAP requirements. Following these
recommendations is not a guarantee against findings of violation.
The EPA intends for owners/operators to be reasonably certain
whether or not they are subject to the NESHAP. In the end, if a
question arises, determinations of whether asbestos containing
materials are regulated by the Asbestos NESHAP are made by EPA
inspectors on site.
7-
-------
2. FRIABLE ASBESTOS CONTAINING-
MATERIALS
Due to their high tensile strength, incombustibility, corrosion and
friction resistance and other properties, such as acoustical and
thermal insulation abilities, asbestos fibers have been incorporated
into over 3600 commercial products. Thermal system, fireproofing
and acoustical insulation materials have been used extensively in the
construction industry.
Thermal system applications include steam or hot water pipe
coverings and thermal block insulation found on boilers and hot
water tanks. Fireproofing insulation may be found on building
structural beams and decking. Acoustical insulation (soundproofing)
commonly has been applied as a troweled-on plaster in school and
office building stairwells and hallways. Unfortunately, with time and
exposure to damaging forces (e.g., severe weather, chemicals,
mechanical forces, etc.), many asbestos- containing materials may
become crumbled, pulverized or reduced to powder, thereby releasing
asbestos fibers, or may deteriorate to the extent that they may release
fibers if disturbed. Since inhalation of asbestos fibers has been linked
to the development of respiratory and other diseases, any material
which is friable, or has a high probability of releasing fibers, must
be handled in accordance with the Asbestos NESHAP.
The following work practices should be followed whenever
demolition/renovation activities involving RACM occur:
notify EPA of intention to demolish/renovate,
remove all RACM from a facility being demolished or
renovated before any disruptive activity begins or before
access to the material is precluded,
-------
keep RACM adequately wet before, during, and after
removal operation,
conduct demolition/renovation activities in a manner which
produces no visible emissions to the outside air, and
handle and dispose of all RACM in an approved manner.
3. NONFRIABLE ASBESTOS-CONTAINING
MATERIALS
Because of the resilient nature of asbestos, it is used in materials
exposed to a wide variety of stressful environments. These
environments can cause the deterioration of binding materials and
cause nonfriable materials to become friable. For example, asbestos-
containing packings and gaskets (Category I nonfriable ACM) used
in thermal systems may be found in poor condition as a result of the
heat they have encountered. In petrochemical handling facilities,
which may have miles of transfer pipes and fittings which contain
asbestos gaskets and/or packings, profound degradation of the ACM
may occur due to exposure to organic-based liquids and gases or to
corrosive agents used to chemically clean these lines.
When nonfriable ACM is subjected to intense mechanical forces,
such as those encountered during demolition or renovation, it can be
crumbled, pulverized, or reduced to powder, and thereby release
asbestos fibers. When nonfriable materials are damaged or are likely
to become damaged during such activities, they must be handled in
accordance with the Asbestos NESHAP.
There are two categories of nonfriable materials: Category I
Nonfriable ACM and Category II Nonfriable ACM.
-------
CATEGORY I NONFRIABLE ACM
Category I nonfriable ACM is any asbestos-containing packing,
gasket, resilient floor covering or asphalt roofing product which
contains more than 1 percent asbestos as determined using polarized
light microscopy (PLM) according to the method specified in
Appendix A, Subpart F, 40 CFR Part 763. (Sec. 61. 141)
Category I nonfriable ACM must be inspected and tested for
friability if it is in poor condition before demolition to determine
whether or not it is subject to the Asbestos NESHAP. If the ACM
is friable, it must be handled in accordance with the NESHAP.
Asbestos-containing packings, gaskets, resilient floor coverings and
asphalt roofing materials must be removed before demolition only if
they are in poor condition and are friable.
The Asbestos NESHAP further requires that if a facility is
demolished by intentional burning, all of the facility's ACM,
including Category I and n nonfriable ACM, be considered RACM
and be removed prior to burning (Sec. 61.145 (c)(10)). Additionally,
if Category I or Category n nonfriable ACM is to be sanded,
ground, cut, or abraded, the material is considered RACM and the
owner or operator must abide by the following (Sec. 61.145 (c)(l)):
(i) Adequately wet the material during the sanding, grinding,
cutting, or abrading operations.
(ii) Comply with the requirements of 61.145(c)(3)(i) if wetting
would unavoidably damage equipment or present a safety
hazard.
(iii) Handle asbestos material produced by the sanding, grinding,
cutting, or abrading, as asbestos-containing waste material
subject to the waste handling and collection provisions of
Section 61.150.
10
-------
CATEGORY II NONFRIABLE ACM
Category n nonfriable ACM is any material, excluding Category I
nonfriable ACM, containing more than 1 percent asbestos as
determined using polarized light microscopy according to the
methods specified in Appendix A, Subpart F, 40 CFR Part 763 that,
when dry, cannot be crumbled, pulverized, or reduced to powder by
hand pressure. (Sec. 61.141)
Category n nonfriable ACMs (cement siding, transite board shingles,
etc.) subjected to intense weather conditions such as thunderstorms,
high winds or prolonged exposure to high heat and humidity may
become "weathered" to a point where they become friable. The
photograph in Figure 1 demonstrates a split asbestos shingle that has
become friable along the cracked edge.
The following table lists examples and other relevant information
about Category I and Category II nonfriable ACM.
Figure 1. Nonfriable asbestos shingle which has become
friable along the broken axis.
n
-------
TABLE 1.
NONFRIABLE ASBESTOS PRODUCTS
Subdivision Generic name
Asbestos (%) Binder/sizing
Cefnentitious extrusion panels:
concrata-l&e products
(Category II)
corrugated
flat
flexible
flexible perforated
laminated
(outer surface)
roof tiles
clapboard and shingles:
clapboard
siding shingles
roofing shingles
pipe
8
20-45
40-50
30-50
30-50
35-50
20-30
12-15
12-14
20-32
20-15
Roofing felts
(Category I)
Asbestos-containing
compounds
(Category I and II)
smooth surface
mineral surface
shingles
pipelne
caulking putties
adhesive (cold applied)
roofing asphalt
mastics
asphalt tile cement
roof putty
plaster/stucco
sealants fire/water
cement. Insulation
cement, finishing
' cement, magnesia
10-15
10-15
1
10
30
5-25
5
5-25
13-25
10-25
2-10
50-55
20-100
55
15
Asbestos ebony products
Floor tilo and vinyl/asbestos tile
Sheet goods asphalt/asbestos tilo
sheet goods/resilent
50
21
26-33
30
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
asphalt
asphalt
asphalt
asphalt
linseed oil
asphalt
asphalt
asphalt
asphalt
asphalt
Portland cement
castor oil or polyisobuxylene
day
day
magnesium carbonate
Portland cement
poly(vinyl)chlortde
asphalt
dry oils
From EPA Guidance entitled "Guidance for Controlling Asbestos-Containing Materials in
Buildings" (Purple Book). Appendix A, Page A-1; EPA 560/5-85-024.
12
-------
Except for the following, Section 61.145(c) of the Asbestos
NESHAP requires that each owner or operator of a demolition or
renovation activity involving RACM remove all such material from a
facility being demolished or renovated before any activity begins that
would break up, dislodge, or similarly disturb the material or
preclude access to the material for subsequent removal.
ACM need not be removed before demolition if it:
(i) Is a Category I nonfriable ACM that is not friable.
(ii) Is on a facility component that is encased in
concrete or other similarly hard material and is
adequately wet whenever exposed during demolition.
(iii) Was not accessible for testing and therefore was not
discovered until after demolition began and, as a
result of the demolition, cannot be safely removed.
If not removed for safety reasons, the exposed
RACM and any asbestos-contaminated debris -must
be treated as asbestos-containing waste material and
kept adequately wet at all times until disposed of.
(iv) Is a Category n nonfriable ACM and the probability
is low that the material will become crumbled,
pulverized, or reduced to powder during demolition.
4. INSPECTION PROCEDURES TO DETERMINE THE
POTENTIAL FOR FIBER RELEASE FROM
NONFRIABLE ASBESTOS-CONTAINING
MATERIALS
Members of the regulated community (i.e. abatement contractors,
industrial hygienists, building owners & operators, etc.) should
become familiar with these procedures as they are designed to
enhance compliance with the Asbestos NESHAP.
13
-------
Asbestos NESHAP RACM Decision Tree
(Pre Demolition/Renovation Activity)
IF SEVERAL AREAS AREB6KG RENOVATED OR
DEMOLISHED AT ONE THE AS
PARTOF ONE ACnVTTY THEN THE TOTALS OF ALL
FACILITIES MUST BE SUMIB)
-------
Asbestos NESHAP RACM Decision Tree
(Post Demolition/Renovation Activity)
REGULATED AMOUNTS OF A
SUSPECT RACM DISCOVERED I
AFTER DEMO/RENO 7
IS IT CATEGORY II
MATERIAL THAT HAS BEEN
DAMAGED SO THAT IT IS
CRUMBLED, PULVERIZED, OR
REDUCED TO
POWDER
ANALYZE
REPRESENTATIVE
SAMPLE FOR ASBESTOS
CONTENT
NOT COVERED BY
NESHAP
DOES
SAMPLE ;
CONTAIN MORE THAN
1%ASBESTOS?
COVERED BY NESHAP
15
-------
GENERAL INSPECTION PROCEDURES
1. Identify all nonfriable suspect ACM and determine whether
it is Category I or II.
2. If it is Category I nonfriable RACM:
Is it in "poor condition?"
[Is the binding of the ACM losing its integrity? Is
the ACM peeling, cracking, or crumbling?
(Remember, friable ACM may not appear in poor
condition.)]
Is it friable?
Collect a piece of dry ACM and seal it in a
transparent, reclosable sample bag.
Apply hand pressure and observe if the
ACM falls apart to the extent that it is
crumbled, pulverized, or reduced to powder.
Does it occur suddenly, all at once?
Send representative samples of the RACM
to an analytical laboratory which is able to
test them for the presence of asbestos
according to the methods specified in 40
CFR Part 763 Subpart F, Appendix A.
Ask the owner/operator if any ACM or
RACM has been sampled and analyzed. If
so, determine where the samples were taken
and ask if the methods of demolition/
renovation were considered when assessing
16
-------
the fiber release potential of the material. -
Will it or has it been subjected to sanding,
grinding, cutting or abrading?
3. If it is Category n nonfriable ACM:
Has the material been crumbled, pulverized or
reduced to powder or is there a high probability that
it will be crumbled, pulverized or reduced to powder
during the demolition/renovation operations, thus
rendering the material friable and subject to the
Asbestos NESHAP?
If Category n nonfriable ACM has been or will be
crumbled, pulverized, or reduced to powder by
demolition or renovation forces, take representative
samples and send them to a laboratory to test for the
presence of asbestos according to the method
specified in 40 CFR Part 763, Subpart F, Appendix A.
5. SPECIFIC INSPECTION PROCEDURES
Category I Nonfriable ACM
Packings and Gaskets
These materials are often very difficult to find because they are
usually placed inside ovens, doors, pipes, boilers, etc.
Often a packing or gasket is discovered during a stripping or
demolition activity. For example, some boilers have an asbestos-
containing paraffin wax packing between the steam lines that travel
between the mud and fire boxes. The paraffin binding of the
packing may decompose due to the high temperatures, and render the
packing friable. Observe all of the packing and note areas that are in
poor condition. Packings in poor condition appear dry and
17
-------
discolored, and fibers may be visible.
A representative piece of asbestos-containing packing material (in
good or poor condition) should be removed with a utility knife and
sealed in a transparent, reclosable bag. Apply hand pressure to the
packing in the sample bag to determine if any portion is crumbled,
pulverized or reduced to powder. If the material simply deforms, but
does not crumble or reduces to a powder, then the material is
considered nonfriable.
Resilient Floor Covering
There is a wide variety of resilient floor covering applications that
contain asbestos. The most common are linoleum flooring and vinyl
asbestos tile (VAT). VAT is most commonly found in either a
9"x9" or a 12"xl2" square size. The 9"x9" VAT's are normally
found in older buildings because they were manufactured earlier than
the 12"xl2" VAT's; however, floor tile sizes and resilient floor
covering applications vary greatly since many buildings have been
re-tiled several times.
In order to determine if a resilient floor covering is in poor condition
look for sections or tiles which are cracked or peeling to the extent
that they are crumbled. Floor coverings in poor condition can often
be found near doorways or loading/staging areas where the floor has
sustained a lot of stress and traffic. If the floor covering is in poor
condition, collect a small representative sample and seal it in a
transparent, sample bag. Hand pressure should be applied to
determine if the material can be crumbled, pulverized, or reduced to
powder. If it can, the material is considered friable. Resilient floor
covering that will be or has been sanded, ground or abraded is
subject to the Asbestos NESHAP. Figure 2 depicts a VAT which is
in poor condition.
18
-------
aCf^Ffjae3KS^EĞ:ptFt-f^E!l^Ğ&iff-:"-c^^f' Jg-,-j*^wvj;-_,J*ğ,-nil.ğĞ,:., W Ğ V->*--V,T<:. ijf *** **>; JP -"";- , -' ll >**ii- . '.--'-'jS,, 1.i''T .'If .Ğ,,"--["_Ğ". .- --1
Figure 2. VAT in poor condition
Asphalt Roofing Products
Asbestos-containing roofing felts have been widely used in "built-up"
roofs. Built-up roofing was used on flat surfaces and consists of
alternating layers of roofing felt and asphalt. The roofing felt
consists of asbestos paper saturated and coated with asphalt.
Asphalt-asbestos roofing products made from roofing felt coated with
asphalt were reportedly used on residential structures for only a short
time (1971-1974).
To determine if an asphalt roofing product is covered by the
Asbestos NESHAP, examine the RACM to spot any areas where the
material is in poor condition and friable. Figure 3 illustrates a
section of roofing felts which have deteriorated and display fibers.
If possible, sample areas where fibers can be seen protruding from
the matrix of the asphalt. The sample should be sealed into a
transparent, reclosable sample bag and hand pressure applied to see
if the sample can be crumbled, pulverized, or reduced to powder.
19
-------
Figure 3. Asphalt roofing felts which are in poor condition. Notice
the fibers protruding along the edge of this roofing felt.
Category II Nonfriable ACM
Asbestos Cement Pipe and 'Sheet PfbSucis
Asbestos-cement (A-C) pipe has been widely used for water and
sewer mains and occasionally used as electrical conduits, drainage
pipe, and vent pipes. A-C sheet, manufactured in flat or corrugated
panels and shingles (rransite board), has been used primarily for
roofing and siding, but also for cooling tower fill sheets, canal
bulkheads, laboratory tables, and electrical switching gear panels. If
these ACM are crumbled, pulverized or reduced to a powder, they
are friable and thus covered by the Asbestos NESHAP. Broken
edges of these materials typically are friable. The fractured surface
should be rubbed to see if it produces powder.
If Category n nonfriable ACM has not crumbled, been pulverized or
reduced to powder and will not become so during the course of
demolition/renovation operations, it is considered nonfriable and
therefore is not subject to the Asbestos NESHAP. However, if
during the demolition or renovation activity it becomes crumbled,
pulverized^or reduced to powder, it is covered by the Asbestos
NESHAP.
20
-------
APPENDIX A
ASBESTOS NESHAP COORDINATORS
(FOR DEMOLITION/RENOVATION ACTIVITIES
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region I
FFK Federal Building
Boston, MA 02203
[617) 565-3265
2T, MA, ME, NH, RI, VT
Asbestos NESHAP Coordinator
Air & Waste Management Division
[J.S. EPA Region II
16 Federal Plaza
STew York, NY 10278
;212) 264-6770
MJ, NY, PR, VI
Asbestos NESHAP Coordinator
Air Management Division
[J.S. EPA Region HI
541 Chestnut Street
Philadelphia, PA 19107
;215) 597-6550
DC, DE, MD, PA, VA, WV
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region IV
345 Courtland Street, N.E.
(Atlanta, GA 30365
[404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6819
IL, IN, MI, MN, OH, WI
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7223
AR, LA, NM, OK, TX
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
IA, KS, MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA Region VIE
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-7685
CO, MT, ND, SD, UT, WY
A-l
-------
Asbestos NESHAP Coordinator
Air and Toxics Division
U.S. EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 774-5569
American Samoa, AZ, CA, Guam, HI
Northern Marianas, Trust Territories
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(205) 442-1757
AK, ID, OR, WA
-------
APPENDIX B
REGIONAL ASBESTOS COORDINATORS (FOR SCHOOLS)
Regional Asbestos Coordinator
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3835
CT, MA, ME, NH, RI, VT
Regional Asbestos Coordinator
U.S. EPA Region H
Woodbridge Avenue
Raritan Depot, Building 5
Edison, NJ 08837
(201) 321-6671
NJ, NY, PR, VI
Regional Asbestos Coordinator
U.S. EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-3160
DC, DE, MD, PA, VA, WV
Regional Asbestos Coordinator
U.S. EPA Region IV
345 Courtland St. N.E.
Atlanta, GA 30365
(404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Regional Asbestos Coordinator
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6003
IL, IN, MI, MN, OH, WI
Regional Asbestos Coordinator
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244
AR, IA, NM, OK, TX
Regional Asbestos Coordinator
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
IA, KS, MO, NE
Regional Asbestos Coordinator
U.S. EPA Region VUI
1 Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2413
(303) 293-1442
CO, MT, ND, SD, UT, WY
B-l
-------
Regional Asbestos Coordinator
U.S. EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5406
American Samoa, AZ, CA Guam,
Northern Marianas, Trust Territories
Regional Asbestos Coordinator
U.S. EPA Region IV
1200 Sixth Avenue
Seattle, WA 98101
(206)442-4762
AK, ID, OR, WA
* U.S. GOVERNMENT PRINTING OFFICE: 1991518-987
------- |