R  E  S  E
R  C H
                                            N  G  L  E
                                           N  S  T  I  T  U  T E
                                         REVIEW OF
                          NATIONAL EMISSION STANDARD FOR ASBESTOS
                                           DRAFT
                                RTI Project No. 44U-1736-13
                                   EPA Project No. 80/41
                                        Prepared for
                            U.S. Environmental Protection Agency
                        Office of Air Quality Planning and Standards
                        Emission Standards and Engineering Division
                                  Contract No. 68-02-2056
RESEARCH  TRIANGLE   PARK,   NORTH   CAROLINA  27709

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                         Research Triangle  Institute
                                P.O. Box 12194
                 Research Triangle Park, North Carolina 27709
                                  REVIEW OF


                   NATIONAL EMISSION STANDARD FOR ASBESTOS



                                    DRAFT
                         RTI Project No. 44U-1736-13
                            EPA Project No. 80/41
                                 Prepared for

                     U.S. Environmental Protection Agency
                 Office of Air Quality Planning and Standards
                 Emission Standards and Engineering Division

                           Contract No. 68-02-3056

                                John Copeland
                                Lead Engineer
                                 Prepared by

                               Michael N. Laney
                               Laura A. Conrad
October 21, 1981	
                                                Dean F. Tolman, Manager
                                                Applied Ecology Department
                                                Operations Analysis  Division

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                              TABLE OF CONTENTS
Chapter

1    SUMMARY 	 ,
     1.1  Introduction 	 ,
     1.2  Industry Description 	 ,
     1.3  Control  Methods	
     1.4  Sampling and Analysis	
     1.5  Environmental  and Health Impacts . . .
     1.6  Enforcement and Compliance Experience.
     1.7  Other Federal  Regulatory Activities. .
     INTRODUCTION	
     2.1  Background 	
          2.1.1  Clean Air Act	
          2.1.2  The 1973 Asbestos Emission Standard
                   (40 CFR 61.22)
2.1.3 The 1974 Revisions. . . . ,
2.1.4 The 1975 Revisions. . . . ,
2.1.5 The 1977 Revisions. . . . ,
2.1.6 The 1973 Revisions. . . . ,

2.1.8 Executive Order 12044 . . ,
2.1.9 Adamo Wrecking Company vs.
2.1.10 Executive Order 12291 . . ,

Aooroach 	 ,










     2.3

     INDUSTRY DESCRIPTION:   MINING, MILLING, MANUFACTURING,
     AND FABRICATING	     3-1
     3.1  Mining	     3-1
          3.1.1  Industry' Statistics	     3-1
          3.1.2  Process Description 	     3-1
          3.1.3  Emission Sources	     3-3
          3.1.4  Control Techniques	     3-3
          3.1.5  Waste Disposal	     3-4
          3.1.6  Costs	     3-4
     3.2  Milling	     3-4
          3.2.1  Industry Statistics 	     3-4
          3.2.2  Process Description 	     3-5
          3.2.3  Emission Sources	     3-7
          3.2.4  Control Techniques	     3-7
          3.2.5  Waste Disposal	     3-10
          3.2.6  Costs	     3-11
     3.3  Asbestos  Paper Products	     3-11
          3.3.1  Industry Statistics	     3-11
          3.3.2  Process Description 	     3-11
          3.3.3  Emission Sources	     3-17
          3.3.4  Control Techniques	     3-19
          3.3.5  Waste Disposal	     3-19
          3.3.6  Costs	     3-19

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                        TABLE OF CONTENTS  (Continued)


.Chapter                                                                _P_age

     3.4  Asbestos Friction Materials. ..... 	  .  .  •     3-19
          3.4.1   Industry Statistics  	     3'19
          3.4.2   Process Description  .......... 	     3-20
          3.4.3   Emission Sources. 	     3-25
          3.4.4   Control Techniques	     3-28
          3.4.5   Waste Disposal	     3~28
          3.4.6   Costs	     3-28
     3.5  Asbestos-Cement Products .  .	     3'29
          3.5.1   Industry Statistics  ^	     3~29
          3.5.2   Process Description  	     3-33
          3.5.3   Emission Sources	     3-35
          3.5.4   Control Techniques   	     3-39
          3.5.5   Waste Disposal  	     3-41
     3.6  Vinyl-Asbestos Floor Tile	     3-42
          3.6.1   Industry Statistics	     3-42
          3.6.2   Process Description	     3-44
          3.6.3   Emission Sources  .  . 	 ......     3-45
          3.6.4   Control  Techniques   	     3-45
          3.6.5   Waste Disposal  	     3-45
          3.6.6   Costs	     3-45
     3.7  Asbestos-Reinforced Plastics .... 	     3-45
          3.7.1   Industry Statistics	     3-45
          3.7.2   Process Description  	     3-47
          3.7.3   Emission Sources  	     3-49
          3.7.4  Control  Techniques	     3-49
          3.7.5  Waste Disposal   	     3-51
          3.7.6  Costs .	     3-51
     3.8  Asbestos Paints,  Coatings, and  Sealants  	     3-51
          3.8.1  Industry Statistics	     3-51
          3.8.2  Process  Description  	     3-53
          3.8.3  Emission Sources  	     3-56
          3.8.4  Control  Techniques   	     3-56
          3.8.5  Waste Disposal   	     3-57
          3.8.6  Costs	     3-57
     3.9  Asbestos Gaskets  and Packings  	     3-57
          3.9.1  Industry Statistics	     3-57
          3.9.2  Process  Description  	     3-61
          3.9.3  Emission Sources  	     3-63
          3.9.4  Control  Techniques   	     3-63
          3.9.5  Waste Disposal   	     3-63
          3.9.6  Costs	     3-63
     3.10  Asbestos Textiles   	     3-63
          3.10.1  Industry Statistics  	     3-63
          3.10.2  Process  Description  	     3-64
          3.10.3  Emission Sources  	     3-67
          3.10.4  Control  Techniques   	     3-67

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                        TABLE OF CONTENTS (Continued)


Chapter                                                                Page

          3.10.5 Waste Disposal   	      3-69
          3.10.6 Costs 	      3-69
     3.11 Chlorine Manufacturing 	      3-69
          3.11.1 Industry Statistics 	      3-69
          3.11.2 Process Description 	      3-70
          3.11.3 Emission Sources  	      3-72
          3.11.4 Control  Techniques  	      3-72
          3.11.5 Waste Disposal   	      3-72
     3.12 Asbestos Insulation  	      3-73
     3.13 Shotgun Shells	      3-73
          3.13.1 Industry Statistics 	      3-73
          3.13.2 Process Description 	      3-74
          3.13.3 Emission Sources  	      3-74
          3.13.4 Control  Techniques  	      3-74
          3.13.5 Waste Disposal   	      3-74
          3.13.6 Costs 	      3-74
     3.14 Asphalt Concrete 	      3-74
          3.14.1 Industry Statistics 	      3-74
          3.14.2 Process Description 	      3-75
          3.14.3 Emission Sources  	      3-75
          3.14.4 Control  Techniques  	      3-75
          3.14.5 Waste Disposal   	      3-75
          3.14.6 Costs 	      3-75
     3.15 Fabricating	      3-76
          3.15.1 Industry Statistics 	      3-76
                 3.15.1.1 A/C Products  	      3-76
                 3.15.1.2 Asbestos Friction Materials	      3-77
                 3.15.1.3 V/A Floor Tile	      3-78
                 3.15.1.4 Asbestos-Reinforced  Plastics  	      3-78
                 3.15.1.5 Asbestos Paper Products	      3-78
                 3.15.1.6 Asbestos Paints,  Coatings,
                            and  Sealants	      3-79
                 3.15.1.7 Asbestos Gaskets, Seals,  and  Packing
                            Materials	      3-79
                 3.15.1.8 Asbestos Textiles	      3-79
          3.15.2 Process Description 	      3-80
          3.15.3 Emission Sources  	      3-80
          3.15.4 Control  Techniques  	      3-80
          3.15.5 Waste Disposal	      3-81
          3.15.6 Costs 	      3-81
     3.16 References	      3-81

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                        TABLE OF CONTENTS  (Continued)


Chapter
4    INDUSTRY DESCRIPTION:  DEMOLITION, RENOVATION, AND
     CONSTRUCTION	      4-1
     4.1  Industry Description:  Construction	      4-1
          4.1.1 Industry Statistics	      4-1
          4.1.2 Renovation	      4-5
          4.1.3 Demolition	      4-11
     4.2  Process Descriptions 	  .......      4-16
          4.2.1 Introduction	      4-16
          4.2.2 Construction	      4-20
          4.2.3 Renovation	      4-27
          4.2.4 Demolition	      4-28
     4.3  Emission Sources and Emissions 	      4-28
     4.4  Control Techniques	      4-29
          4.4.1  A/C Pipe Installation	      4-29
          4.4.2  A/C Sheet Installation	      4-32
          4.4.3  Drywall Removal	      4-33
          4.4.4  Installation and Removal  of Roofing  Felts  ....   •   4-33
          4.4.5  Removal of Nonfriable Insulation	      4-34
          4.4.6  Ecapsulation with Sealants		      4-34
          4.4.7  Renovation and Demolition	      4-34
     4.5  Waste Disposal	      4-34
     4.6  Costs	      4-35
     4.7  Status of Occupational  Health Standards. .  . 	      4-35
     4.8  References 	 ......      4-36

 5    CONTROL METHODS 	 ......      5-1
     5.1  Fabric Filters	      5-1
     5.2  Wet Collectors	      5-11
     5.3  Electrostatic Precipitators  	      5-12
     5.4  Demolition, Renovation, and Construction 	      5_13
          5.4.1 Demolition and Renovation	      5,13
          5.4.2 Construction	      5_lg
     5.5  Substitutes	      5_17
     5.6  References	      5_19

 6    SAMPLING AND ANALYSIS 	 ......      6-1
     6.1  Sampling Criteria  	      g_l
     6.2  Current Sampling Methods 	      g_4
     6.3  Analytical Methods	'  \      g_5
          6.3.1 Optical Methods	[  '      6_6
          6.3.2 Electron Microscopy	      g_g
          6.3.3 Physical and Chemical Analysis	]      g_g
     6.4  Other Sampling and Analysis Methods.	      g_^Q
     6.5  Bulk Sample Analysis	'.'.'.      6-11
          6.5.1 Petrographic Microscopy	'.'.'.      6-11
          6.5.2 X-Ray Diffraction	'.'.'.      6-12
          6.5.3 Electron Microscopy	*  ]      6-12
     6.6  Availability  of Emission Data	 .  .      6-12
     6.7  References	      6-13

                                      vi

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                        TABLE OF CONTENTS (Continued)


Chapter                                                                Page

7    HUMAN HEALTH EFFECTS ASSOCIATED WITH INHALATION OF ASBESTOS .     7-1
     7.1  Introduction	     7-1
     7.2  Health Hazards of Chrysotile Exposure	     7-1
          7.2.1  Asbestos Mortality	     7-1
          7.2.2  Lung Cancer Mortality	     7-1
          7.2.3  Pleura!  and Peritoreal Mesothelioma 	     7-3
     7.3  Nonoccupational Exposure to Asbestos 	     7-3
     7.4  Factors that Modify Risk of Asbestos-Induced Disease . .     7-4
          7.4.1  Smoking Habits	     7-4
          7.4.2  Age	     7-4
     7.5  Fiber Characteristics	     7-5
          7.5.1  Fiber Size	     7-5
          7.5.2  Fiber Type	     7-6
     7.6  Summary of Health Effects	     7-6
     7.7  References . .	     7-7

8    ENFORCEMENT AND COMPLIANCE EXPERIENCE 	     8-1
     8.1  Jurisdiction:  State vs. Federal 	     8-1
     8.2  Industry Concerns  	     8-1
     8.3  Regional EPA Concerns	     8-5
          8.3.1 Work Practice Enforcement	     8-5
          8.3.2 Regulatory Language	 . . .     8-5
          8.3.3 Notification	     8-5
          8.3.4 Emission Limitation	     8-6
          8.3.5 Unregulated Source 	     8-6
     8.4  Applicability Determinations 	     8-6
     8.5  Unregulated Emission Sources 	     8-6
          8.5.1 Onsite Fabrication 	     8-6
          8.5.2 Demolition	     8-6
          8.5.3 Contaminant Sources  	     8-9
          8.5.4 Asbestos Mining	     8-9
          8.5.5 Fabricators	     8-9
          8.5.6 Encapsulants	     8-10
          8.5.7 Drilling Muds	     8-10
     8.6  References	     8-11

9    OTHER FEDERAL REGULATORY ACTIVITIES 	     9-1
     9.1  Environmental Protection Agency	     9-1
          9.1.1 Clean Air Act	     9-1
          9.1.2 Resource Conservation and Recovery Act 	     9-2
          9.1.3 Toxic Substances Control  Act 	     9-2
          9.1.4 Clean Water Act	     9-3
     9.2  Occupational  Safety and Health Administration	     9-4
     9.3  Consumer Product Safety Commission 	     9-4
     9.4  Food and Drug Administration	     9-4
     9.5  Department of Transportation 	     9-5
     9.6  Mine Safety and Health Administration  	     9-5
     9.7  Other Federal Agencies 	     9-5
                                     VII

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                                LIST OF TABLES


jjumber

2- 1   Provisions of the Current Standard	    2-6
3- 1   United States Asbestos Production 	    3-2
3- 2   Estimated Total Annual Emissions from Asbestos  Mining
          in the United States	    3-2
3- 3   Baghouse Emissions and Collection Efficiencies  for
          Asbestos Milling	    3-8
3- 4   Ambient Air Concentrations of Fibers in the Vicinity of
          Asbestos Mill Tailings Pile, Coalinga, California  	    3-8
3- 5   Summary of Ambient Asbestos Monitoring Data in  Vicinities
          of Asbestos Mill, Hyde Park, Vermont	    3-9
3- 6   Estimated Total Annual Emissions From Asbestos  Milling
          in the United States	    3-9
3- 7   Asbestos Consumption and Production of Asbestos Paper  ....    3-12
3- 8   United States Asbestos Paper Products Industry  Production,
          1975 and 1979	    3-13
3- 9   Producers of Asbestos Paper Products	    3-14
3-10   Composition of Asbestos Paper Products	•.    3-16
3-11   Estimates of Annual  Asbestos Emissions from Asbestos Paper
          Manufacturing in the United States, 1969	    3-18
3-12   Estimates of Total Annual Environmental  Releases of Asbestos
          from Paper Manufacture in the United States,  1976 	    3-18
3-13   Domestic Producers of Asbestos Friction Materials 	    3-21
3-14   Estimates of Total Annual Asbestos Emissions from Friction
          Material Processing in the United States	    3-26
3-15   Estimates of Total Annual Asbestos Emissions from Friction
          Product Manufacturing in the United States	    3-26
3-16   Estimates of Total Annual Environmental  Release of Asbestos
          from Friction Material Manufacture in the United States . .    3-27
3-17   Producers of A/C Pipe	    3-30
3-18   Manufacturers of A/C Sheet Products 	    3-31
3-19   U.S. Consumption of Asbestos in A/C Industry Compared
          to Total U.S. Consumption, 1969-1980	    3-32
3-20   Baghouse Emissions and Fiber Removal  Efficiencies from
          A/C Pipe Plants	    3-37
3-21   Size Distribution and Fractional  Removal Efficiencies
          from Two A/C Pipe Plants	    3-38
3-22   Estimates of Total Annual Emissions from Processing Asbestos
          for A/C Pipe and Sheet Products in the United States. . . .    3-38
3-23   Estimated Total Annual Environmental  Release of Asbestos
          from A/C Pipe Manufacture in the United States	    3-40
3-24   Estimated Total Annual Environmental  Release of Asbestos
          from A/C Sheet Manufacture in the United States	    3-40
3-25   Producers of V/A Floor Tile	    3-43
3-26   Estimates of Total Annual Emissions from V/A Floor
          Tile Manufacture in the United States, 1969	    3-46
3-27   Manufacturers of Asbestos-Reinforced Phenolic
          Molding Compounds  	    3-48
3-28   Asbestos Consumed in Production of Asbestos-Reinforced
          Plastics (Metric Tons)	    3-48

                                     v i i i

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                          LIST OF TABLES (Continued)


Number                                                                 Page

3-29   Estimates of Total Annual Asbestos Emissions from the
         Manufacture of Asbestos-Reinforced Plastics in the
         United States 	   3-50
3-30   Manufacturers of Asbestos Coatings and Sealants 	   3-52
3-31   Asbestos Paint, Coating, and Sealant Consumption of Asbestos
         (Short Tons)  	   3'52
3-32   1978 Net Sales for Producers of Asbestos Coatings and
         Sealants	   3-54
3-33   Primary Manufacturers of Asbestos Gaskets
         and Packings	   3-58
3-34   Asbestos Consumed in the Production of Gaskets
         and Packings	   3-62
3-35   Estimates of Total Annual Asbestos Emissions from the
         Manufacture of Asbestos Gaskets and Packing
         in the United States	   3-62
3-36   Manufacturers of Asbestos Textiles	   3-65
3-37   Asbestos Consumed in Textile Production in the
         United States, 1978 to 1980 (Metric Ton)	   3-65
3-38   Total Fiber Counts and Fiber Removal  Efficiencies
         for an Asbestos Textile Manufacturer	   3-68
3-39   Chlorine Producers with Diaphragm Cells 	   3-71

4-1    Summary Statistics for Establishments With and Without
         Payroll:  1977 and 1972	   4-3
4-2    General Statistics For Establishments With Payroll  By
         Industry:  1977	   4-6
4-3    Maintenance and Repair Receipt Data for Buildings Other than
         Single-Family Dwellings 	   4-9
4-4    Maintenance and Repair Receipt Data for Nonbuilding
         Construction  .	   4-10
4-5    Summary of Demolition-Data  	   4-17
4-6    Asbestos Products Consumed by the Construction Industry . .  .   4-19
4-7    Distribution of Activities Among Different Construction
         Types	   4-21
4-8    Emission Sources and Occupational  Exposures 	   4-30

5-1    Dust Control Devices	   5-3
5-2    Bag Fabric	   5-4
5-3    Bag Cleaning Mechanism	   5-5
5-4    Air-to-Cloth Ratio  	   5-5
5-5    Pressure Drop Across Bag	   5-6
5-6    Processes and Number of Sites Visited 	   5-7
5-7    Control Device Use	   5-7
5-8    Baghouse-Cleaning Mechanisms  	   5-8
5-9    Comparison of Methods in Removal of an 8- x 12-foot Ceiling
         Section	   5-14
5-10   Inhibition of Asbestos Movement by Polyethylene Barriers. .  .   5-14
                                      IX

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                          LIST OF TABLES  (Continued)


_N umber                                                                  Pagi

6-1    Criteria for a Source Sampling Method for Asbestos  for the
         Acquisition of a Representative  Sampling	    6-2
6-2    Criteria for a Source Sampling Method for Asbestos  to be
         Compatible with the Analytical Method for Asbestos
         Determination 	    6-3

8-1    States with NESHAP Authority	    8-2
8-2    Asbestos NESHAP Determinations	    8-7

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                               LIST OF FIGURES
Number                                                                 Page

4-1    Types of Demolition Work	     4-12
4-2    Permanent Employee Distribution  	  .  ........     4-13
4-3    Average Temporary Employee Distribution   	     4-14
4-4    Comparison Between the Number of Permanent  Employees  and
         the Average Number of Temporary Employees  	     4-15

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                                 1.  SUMMARY

1.1  INTRODUCTION
     This Phase I review assesses the current national emission standard for
asbestos as part of the U.S. Environmental Protection Agency (EPA) project
number 80/41, "Review of Asbestos National Emission Standard," under EPA
contract number 68-02-3056, "New Source Performance Standards (NSPS) and
National Emission Standards for Hazardous Air Pollutants (NESHAPs)."
     The impetus for this review was Presidential Executive Order 12044,
issued in March 1978, directing Federal agencies to improve existing and
future regulations.  Existing regulations were to be reviewed periodically to
determine whether they were achieving policy goals of the Order.  As a result,
review of the asbestos NESHAP was initiated.  The Phase I review was continued
under authority of Executive Order 12291, which superseded Executive Order
12044 in February 1981.
     This chapter summarizes information contained in this report.

1.2  INDUSTRY DESCRIPTION
     Potential  asbestos emission sources include companies that mine and mill
asbestos; manufacture intermediate or end products from, or use in their
operations, raw asbestos fibers; further process manufactured intermediate
products to produce a finished product; install asbestos-containing end
products; and remove asbestos-containing materials during renovation or
demolition of any building or structure.  In 1980, U.S. asbestos production
totaled about 80,000 metric tons, 14 percent below the 1979 level, and imports
were about 327,000 metric tons, 36 percent below the 1979 level.  Asbestos
consumption was nearly 359,000 metric tons, 36 percent below the 1979 level.
The construction industry accounts for two-thirds of U.S. asbestos
consumption, and U.S. demand appears to be leveling off or decreasing
slightly.  Increasing regulations over health concerns associated with
asbestos, competition from substitutes, and an economic recession are largely
responsible for lessening asbestos demand.

                                     1-1

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     The following list of asbestos consumption, by product category,
indicates the relative sizes (in metric tons)  of the various industry segments
in 1980.
                  Asbestos/cement (A/C) pipe    144,000
                  Flooring products '  ' v ^      90^200
                  Friction products              43,700
                  Roofing products               26,500
                  Packing and gaskets            12,300
                  Coatings and compounds         10,900
                  Insulation                      8,900
                  A/C sheet                       7,900
                  Textiles                        1,900
                  Plastics                        1 300
                  Paper                             500
                  Other                          10,600
                  Total                         358,700
     The breakdown of asbestos consumption by  product category will  vary
depending on the definition of product category; e.g., the above list defines
the paper category to exclude flooring felt and roofing felt.
     Major emission sources in mining include  drilling, blasting,  ore loading,
ore hauling, and ore dumping at the mill.  Emission sources at mills include
primary processing (crushing and screening), drying,  conveying, screening,
grading, fiberizing, fiber bagging, and tailings disposal.  In manufacturing,
major emission sources generally include bag opening  and dumping,  mixing,  and
finishing operations (drilling, cutting, and grinding).  Fabricating resembles
finishing operations in manufacturing, so emissions are generally  from
drilling, cutting, and grinding.  Emissions from construction  are  not
considered significant since only a small amount of fabrication is onsite.
Emissions during demolition and renovation occur when asbestos-containing
building material  or insulation is disturbed as in  removing it from  surfaces.
Very few emission test data exist for the asbestos  industry.

1.3  CONTROL METHODS
     The asbestos industry commonly uses local  exhaust ventilation (LEV) with
hoods and enclosures to remove asbestos dust from the worker's environment.
Captured dust is exhausted to baghouses where  it is collected.   Pulse-jet  and
mechanically shaken baghouses are used most frequently.
     Electrostatic augmentation of fabric filtration  is the only significant
control technology development that might be applicable to asbestos  emissions.
Apparently, the rate of pressure drop decreases and collection efficiency
increases.  This method has not yet been applied on a full-scale basis
                                     1-2

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although pilot baghouse studies controlling fly ash are promising.  Other
efforts directed toward optimizing baghouse performance through variations in
cleaning frequency, duration, and intensity have been only partially
successful.
     For installation of asbestos-containing products and demolition and
renovation of asbestos-containing structures, a variety of techniques are used
to control emissions.  Special cutting tools are used in field fabrication of
asbestos products; LEV systems for portable tools are not used extensively.
Asbestos emissions resulting from renovation and removal of friable materials
containing asbestos are controlled by use of amended water before scraping,
picking, and drilling and by containing emissions within areas where removal
is undertaken.
     Little work is being done to improve emission control  methods for use in
demolition and renovation.  The United States Navy presently is developing an
asbestos-removal method for use in ship repair, still  in experimental  stages.
     Restrictions on the quantity of asbestos used in products and complete
elimination of some asbestos-containing products by industry probably have
also reduced asbestos emissions.  These methods are largely a response to
regulatory activities to reduce the potential  for human exposure to asbestos.

1.4  SAMPLING AND ANALYSIS
     Techniques are developed for analyzing bulk samples for asbestos content.
However, there is presently no reference method for measuring asbestos stack
emissions.  While progress has been made in refining the provisional  electron
microscopy method, interlaboratory and intralaboratory variations, high costs,
and lengthy analysis continue to prevent its acceptance as  a reference
analysis method.  A feasibility study recently has been performed regarding
development of a measurement method compatible with the provisional analytical
method, and actual development is at least 2 years away.

1.5  ENVIRONMENTAL AND HEALTH IMPACTS
     Inhalation of asbestos fibers has been associated with asbestosis,
respiratory cancer, and mesothelioma.  The original  decision to control
asbestos emissions into the atmosphere was based largely on a National Academy
of Science report.  Since then, researchers have been unable to determine if
                                     1-3

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there is a safe exposure level below which asbestos-induced cancer will not
occur.  Consequently, EPA still believes human exposure to airborne asbestos
should be reduced to the greatest extent practicable.

1.6  ENFORCEMENT AND COMPLIANCE EXPERIENCE
     Major hindrances to enforcing the asbestos NESHAP include the apparent
difficulty with enforcing nonemission provisions, difficulty in interpreting
the standard, and inadequate reporting by demolition contractors.  Generally,
the asbestos industry believes the standard to be workable and effective in
reducing asbestos exposures.

1.7  OTHER FEDERAL REGULATORY ACTIVITIES
     At least six Federal agencies, excluding EPA, currently have or are
proposing regulations aimed specifically at regulating asbestos.  Within EPA,
several regulations exist or are proposed that are directed specifically at
asbestos or that are generic in nature but result in regulation of asbestos.
These standards should be assessed during Phase II to determine the extent to
which they interface with revision of the asbestos NESHAP.
                                     1-4

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                             2.  INTRODUCTION
     This Phase I study reviews and recommends alternatives for revising
the national emission standard for asbestos.  It is submitted to the U.S.
Environmental Protection Agency (EPA) as part of EPA Project Number 80/41,
EPA Contract Number 68-02-3056, "New Source Performance Standards and
National Emission Standards for Hazardous Air Pollutants."
     This chapter discusses the background for review of the asbestos
national emission standard and summarizes the study objectives and
approach.  Chapters 3 and 4 of this report describe the manufacturing
industry and the demolition and renovation industry, respectively.  Chapter
5 discusses control systems, Chapter 6 discusses sampling and analysis, and
Chapter 7 summarizes environmental  impacts.  Chapter 8 examines enforcement
activities, and Chapter 9 reviews other applicable Federal regulations.
2.1  BACKGROUND
     Legal  and Congressional actions that resulted in development of the
asbestos emission standard, subsequent actions that amended the standard,
and events responsible for this review are presented here.  The Clean Air
Act, the 1973 national emission standard for asbestos and subsequent
amendments, Executive Orders 12044 and 12291, and the U.S. Court decision
in the Adamo Wrecking Company vs. the United States are summarized in the
following passages.
2.1.1 Clean Air Act
     In 1963, by enacting the Clean Air Act, the U.S. Congress established
a national  program to control air pollution in response to growing public
concern.  This program established funds for air pollution control
research.  The Act was amended by the Air Quality Act of 1967, which
expanded research functions, authorized assistance to both State and
municipal programs, provided a means to force polluters to control air
                                  2-1

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pollution, and authorized the Federal  Government to file suit against
industries responsible for air pollution emergencies.
     In 1970, Congress further amended the Clean Air Act with the Clean Air
Act Amendments.  Through these amendments, Congress created EPA and
directed it to promulgate and set standards to control  air pollution.
Congress gave EPA the authority, under Sections 110, 111, and 112 of the
amended Act, to create National  Ambient Air Quality Standards (NAAQS), New
Source Performance Standards (NSPS), and National  Emission Standards for
Hazardous Air Pollutants (NESHAPs), respectively.   Under this authority,
EPA designated asbestos a hazardous air pollutant.
     Congress amended the 1970 Clean Air Act in August  1977, after 7 months
of hearings and numerous markup sessions during the years 1972 through
1976.  Sections 110, 111, and 112 were all affected.  Section 112 of the
Clean Air Act was amended to allow EPA to promulgate design, equipment, or
operational standards to control hazardous emission sources, where an
emission limit is not feasible.
2.1.2  The 1973 Asbestos Emission Standard (40 CFR  61.22)
     On April 6, 1973 (38 FR 8826), EPA promulgated the national  emission
standard for asbestos.  It prohibited  visible emissions from asbestos mills
and nine different manufacturing industries, specified  certain work
practices for demolition of structures that contain friable asbestos,
limited to less than 1 percent asbestos content of  spray-on materials used
for certain insulation applications, and prohibited most  uses of  asbestos
tailings for surfacing roadways.
2.1.3  The 1974 Revisions
     Revisions to the standard were promulgated on  May  3, 1974 (39 FR
15398), to clarify some portions of the regulation.  Revisions included
definitions for asbestos mill, commercial  asbestos, manufacturing, and
demolition.  Language in the paragraphs under demolition  was revised for
clarity.  Paragraph (g) was added, which exempted sources from no visible
emissions requirements where the presence of uncombined water was the sole
reason for violation.
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2.1.4  The 1975 Revisions
     On October 14, 1975 (40 FR 48292), EPA amended the asbestos standard.
The 1975 changes clarified the definition of demolition by including
removal or stripping of friable asbestos materials.  Revisions defined the
following terms:  friable asbestos material, control device asbestos waste,
renovation, planned renovation, emergency renovation, adequately wetted,
removing, stripping, fabricating, inactive waste disposal  site, active
waste disposal site, roadways, and asbestos-containing waste material.
     The provision regarding surfacing of roadways was revised to prohibit
use of asbestos-containing waste and asbestos tailings.  EPA revised
coverage of the asbestos emission standard by extending no visible emission
requirements to two additional manufacturers:  manufacturers of shotgun
shells and manufacturers of asphalt concrete.  For clarification, EPA
specified that there shall be no visible emissions from manufacturing
operations ". . . if they use commercial asbestos. . ."
     Provisions regarding demolition were expanded to include renovation.
In the 1975 revisions, demolition and renovation operations Included
stripping and removing requirements for certain items insulated or
fireproofed with asbestos materials in addition to pipes,  boilers, and
load-support ing structural members itemized in the original  standard.
Revisions suspended wetting requirements under freezing weather conditions
and granted use of local exhaust ventilation (LEV) and collection systems
in lieu of wetting when, as a result of wetting, equipment damage would be
unavoidable during renovation operations.
     Revisions extended additional  requirements to demolition of facilities
authorized by State or local  governments besides notification requirements
already in effect.  Requirements for stripping of friable  asbestos material
from previously removed units and for wetting were made applicable to
State-authorized demolitions.  The uncombined water condition in paragraph
(g) of the standard was also extended to State-authorized  demolitions.
     The 1975 revisions added requirements for fabrication using commercial
asbestos and extended the no visible emissions requirement to fabricators
of cement building products,  friction products, and cement or silicate
board.
                                  2-3

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     EPA found it necessary to divide fabrication operations into two main
categories:   field fabrication and central shop fabrication.  From its
investigation, EPA concluded that asbestos products other than friable
insulating products are field fabricated to only a limited extent and that
fabrication  of certain asbestos products in central shops is a major
emission source.   Therefore, field fabrication was not included in the
revisions.
     Reporting requirements were revised to exempt any owner or operator
who intends  to spray materials containing less than 1 percent asbestos to
insulate or  fireproof equipment and machinery.
     The option of using specified air-cleaning methods in place of
complying with no visible emissions requirements was extended to demolition
and renovation, fabrication, and waste disposal.
     The 1975 revisions prohibited insulating with either friable, molded
insulating materials or wet-applied insulating materials that are friable
after drying.
     Waste disposal requirements for manufacturing, fabricating, demolition
and renovation, and spraying operations were added by the 1975 revisions.
Visible emissions were prohibited by the 1975 revisions during collection,
processing,  packaging, transporting, or deposition of any asbestos-
containing waste material.  Revisions specify two alternative waste
disposal methods, which could be used instead of the no visible emissions
requirement.  The 1975 revisions also specified operating conditions  for
asbestos waste disposal sites.
     Waste disposal requirements for asbestos mills were given separately
from other waste disposal provisions in the 1975 revisions.   However, they
are similar  to the other waste disposal  provisions except that they allow a
wetting agent to be mixed with asbestos-containing waste from mills.
     Requirements for owners of inactive waste disposal  sites, which  were
operated by  milling, manufacturing, and fabricating sources, were added
with the 1975 revisions.  These requirements included no visible emissions
to the outside air and methods to prevent emissions from asbestos-
containing waste material and asbestos tailings piles.
                                  2-4

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     Air-cleaning requirements (40 CFR 161.23) were not changed by the 1975
revisions, but reporting requirements (40 CFR 61.24) were revised to
include waste disposal activities.
2.1.5  The 1977 Revisions
     The 1977 revisions clarified that the standard's demolition and
renovation provisions apply when friable asbestos is removed from nonload-
supporting structural members.
2.1.6  The 1978 Revisions
     In June 1978 (43 FR 26372), requirements for demolition and renovation
were extended to cover operations involving friable asbestos-containing
material; references to asbestos-containing insulation and fireproofing
were removed.  Coverage of the asbestos-spraying provisions was also
extended to all materials (not just insulating and fireproofing materials)
that contain more than 1 percent asbestos.  Also, EPA exempted from the
spraying provisions spray-on applications of materials in which asbestos
fibers are encapsulated with bituminous or resinous binders.
2.1.7  The Current Standard
     Provisions of the current standard limit emissions from milling and
manufacturing, prohibit uses of asbestos-containing materials, provide for
work practices in demolition and renovation operations, and require certain
procedures for waste disposal  and disposal site maintenance.  The standard
is summarized in Table 2-1.
2.1.8  Executive Order 12044
     On March 23, 1978, President Jimmy Carter issued Executive Order
12044, which directed the executive agencies to improve existing and future
regulations.  Among the requirements of the Executive Order were those that
required Federal agencies to ". . . periodically review their existing
regulations to determine whether they are achieving the policy goals of
this Order."
     In May 1979, EPA published its response to the Order in the Federal
Register (44 FR 30988).  The response contained the criteria and process
EPA would use in selecting regulations for review.  EPA responded that the
first reviews were to be those previously scheduled in response to
statutory or judicial authorities.  However, NESHAPs were not under
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                TABLE 2-1.   PROVISIONS OF THE CURRENT STANDARD
  Operation
                       Provisions
Mi 11 i ng
Surfacing roadways
No visible emissions
 permitted
are
Manufacturing
Demolition  and
 renovation
Surfacing roadways with
 asbestos tailings or
 asbestos-containing waste
 from manufacturing, demo-
 lition, spraying, or fabrica-
 ting is prohibited

No visible emissions are
 permitted from the manu-
 facture of the following
 materials that use commercial
 asbestos:
Or, air-cleaning methods
 in Section 61.23 must be
 used to collect emissions
 before venting

Provision not required for
 temporary roadways on
 an area of asbestos ore
 deposits
           Or,  air-cleaning methods
            in  Section 61.23 must be
            used to collect emissions
            before venting
 1. Cloth, cord wicks, tubing,
    tape, twine, rope, thread,
    yarn, roving, lap, or
    other textile materials;
 2. Cement products
 3. Fireproofing and insulating
    materials
 4. Friction products
 5. Paper, millboard, and felt
 6. Floor tile
 7. Paints, coatings, caulks,
    adhesives, and sealants
 8. Plastics and rubber
    materials
 9. Chlorine
10. Shotgun shells
11. Asphalt concrete

Written notification with
 specific information
 regarding demolition or
 renovation projects must be
 given to EPA
           Only  the  name and address
            of the  project  owner or
            operator is  required
            when the amount of
            friable  asbestos material
            is less  than 80 meters
            (ca.  260 feet)  on pipes
            or 15 square meters  (ca.
            160  square feet)  on  other
            structural members
                                      2-6
                                             (Continued)

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           TABLE 2-1.  PROVISIONS OF THE CURRENT STANDARD (Continued)
  Operation
                       Provisions
Demolition and
 renovation
 (continued)
Renovation
                                                  be
Friable asbestos materials
 must be removed before
 wrecking

Friable asbestos materials
 must be adequately wetted
 during stripping
Friable asbestos materials
 exposed during cutting or
 disjointing of units or
 sections of structural
 members being removed must
 adequately wetted


Friable asbestos materials
 must be adequately wetted
 during stripping of units or
 sections of structural
 members being removed
All  friable asbestos materials
 removed or stripped must be
 adequately wetted for the
 remainder of demolition or
 renovation operation.  Do not
 throw to ground;  if more than
 50  feet above ground level
 (except units or  sections),
 transport to ground via dust-
 tight chutes or containers

If equipment damage results
 from wetting friable asbestos
 materials during  stripping,
 LEV and collection systems
 that exhibit no visible
 emissions must be used; prior
 to  use, approval  must be
 obtained from EPA
Provision not required for
 structural members
 encased in concrete

Provision not required
 when temperatures drop
 below 0° C, but structur-
 al members coated with
 friable asbestos must be
 removed in sections or
 units

Provision not required
 when temperatures drop
 below 0° C, but structur-
 al members coated with
 friable asbestos must be
 removed in sections or
 units, if possible

Or, LEV and collection
 systems that exhibit no
 visible emissions must be
 used

Or, air-cleaning methods
in Section 61.23 must be
used
Or, air-cleaning methods
 in Section 61.23 must be
 used
                                      2-7
                                                                   (Continued)

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           TABLE 2-1.   PROVISIONS OF THE CURRENT STANDARD (Continued)
  Operation
                       Provisions
Sprayi ng
Fabrication
Insulating
Waste disposal
No visible emissions are
 permitted when materials con-
 taining more than 1 percent
 asbestos are sprayed on
 equipment or machinery
Materials sprayed on other
 structures or structural
 members cannot contain 1
 percent or more of asbestos

Written notification with
 site-specific information
 must be provided to EPA when
 the intent is to spray
 materials containing more
 than 1 percent asbestos on
 equipment or machinery

No visible emissions from
 fabrication of the following
 products are permitted if
 performed in a central
 location:

 1. Cement bulding products
 2. Friction products, except
    those installed on motor
    vehicles
 3. Cement or silicate board

Application of molded and  wet-
 applied insulating materials
 that contain asbestos and are
 friable are not permitted

No visible emissions are
 permitted from the collec-
 tion, processing, packaging,
 transporting, or deposition
 of asbestos-containing waste
 material generated from an
 asbestos emission source
Or, air-cleaning  methods
 in Section 61.23 must  be
 used; provision  not
 required for materials in
 which asbestos fibers  are
 encapsulated with binders
                                                      Notification not required
                                                       for spraying of materials
                                                       in which asbestos fibers
                                                       are encapsulated with
                                                       binders
Or, air-cleaning methods
 in Section 61.23 must be
 used
Or, asbestos-containing
 waste must be treated
 with water, sealed into
 leak-tight containers,
 and containers labelled
 with a warning
                                      2-8
                                                                   (Continued)

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           TABLE  2-1.   PROVISIONS  OF  THE  CURRENT  STANDARD  (Continued)
  Operation
                       Provisions
Waste disposal
 (continued)
                      No visible emissions are
                       permitted from wetting
                       asbestos mill waste that
                       contains asbestos
.Inactive disposal
 sites
No visible emissions are
 permitted from inactive
 disposal sites containing
 asbestos waste
Air-cleaning
  methods
Fabric filter collection
 devices must be used
Or, the waste must be
 processed into a
 nonfriable form

Or, for milling oper-
 ations, asbestos-contain-
 ing waste must be treated
 with a wetting agent
 prior to disposal

Or, air-cleaning methods
 in Section 61.23 must be
 used

Provision not required
 when the temperature at
 the disposal  site is less
 than -9.5° C (15° F)

Or, the waste must be
 covered with 15
 centimeters (ca. 6
 inches) of compacted non-
 asbestos-containing
 material  and vegetation

Or, the waste must be
 covered with 60
 centimeters (ca. 2 feet)
 of compacted nonasbestos-
 containing material

Or, for tailings disposal
 sites, a resinous or
 petroleum-based, dust-
 suppressant must be
 appl ied

Provision not required if
 fabric filtration methods
 create a fire or explo-
 sion hazard
                                                                    (Continued)
                                      2-9

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           TABLE 2-1.  PROVISIONS OF THE CURRENT STANDARD (Continued)
  Operation
                       Provisions
Ai r cleaning
 methods
  (continued)
Reporting
Waste disposal
 sites
                                Or, another filtering
                                 method equivalent to
                                 fabric filtration methods
                                 must be used
The pressure drop of the
 collection device must be
 maintained at or below 4
 inches of water

Air permeability must not
 exceed 30 cubic feet per
 minute per square foot of
 woven fabric or 35 cubic feet
 per minute per square foot of
 felted fabric

A unit contacting energy of at
 least 40 inches water gage
 pressure must be used if wet
 collectors are permitted

The following information
 regarding collection devices
 shall be provided to EPA:

 1. Description of the
    emission control  equip-
    ment
 2. Pressure drop
 3. Air flow permeability of
    woven fabric and  type of
    yarn used
 4. Density, minimum  thick-
    ness, and air flow
    permeability

No visible emissions  are
 permitted from active waste
 disposal sites where
 asbestos-containing  waste has
 been deposited
                                                      40 and 45 cubic feet per
                                                       minute per square foot of
                                                       woven and felted fabric,
                                                       respectively, is per-
                                                       mitted for ore driers
Or, the asbestos-contain-
 ing waste material must
 be covered with
 15 centimeters (ca. 6 in-
 ches)  of nonasbestos-
 containing material at
 the end of each operating
 day or at least once
 every 24-hour period
                                      2-10
                                                                    (Continued)

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           TABLE 2-1.  PROVISIONS OF THE CURRENT STANDARD  (Continued)
  Operation
        Provisions
Waste disposal
 sites
 (continued)
                      Signs shall  be
                       entrances and
                       property line
posted at
along the
all
Or, the deposited
 asbestos-containing waste
 must be covered with a
 resinous or petroleum-
 based dust suppressant at
 the end of each operating
 day or at least once
 every 24-hour period

Posting not required when
 the asbestos-containing
 waste is covered with 15
 centimeters (ca. 6
 inches)  of nonasbestos-
 containing material  or a
 natural  barrier hinders
 access
                      Warning signs must be 20 inches
                       by 14 inches and conform to
                       the format required by the
                       Occupational Safety and Health
                       Administration (OSHA)  Standard,
                       29 CFR 1910.145(d)(4)
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statutory mandate to undergo review and were selected under the following
criteria developed in response to the Order:
          Estimated high actual  costs to the public of implementing and
          maintaining the regulation,
          Estimated low actual benefits,
          Existence of overlap with other regulations (issued by EPA or
          another agency),
          Need for integration with other programs,
          Existence of preferable alternatives,
          Low degree of compliance,
          Low enforceability,
          High reporting burden,
          Lack of clear language,
          Length of time since the regulation became effective or was last
          substantively amended,
          Intensity of public sentiment in favor of changing the
          regulation, and
          Availability of adequate data for analyzing the  regulation's
          effectiveness and cost.
     EPA responded that it would summarize its assessment  of each
regulation and choose those for formal  review.  Reviews  were to be
conducted within 5 years.
     Once regulations were selected, review would follow procedures for
new standards development and would not duplicate any previously prepared
analysis still val id.
     Based on the above procedures, review for the asbestos  NESHAP was
initiated.
2.1.9  Adamo Wrecking Company vs. United States
     The 1978 decision by the U.S. Supreme Court in Adamo  Wrecking Company
vs. United States, held that the work practice provisions  in the asbestos
standard were not emission standards and that the Clean  Air  Act Amendments
of 1970 did not empower EPA to issue nonemission (e.g.,  work practice)
standards.  However, Congress acted in  1977 to broaden EPA's authority by
amending Section 112 of the Act.  The 1977 Amendments allow  EPA to
promulgate design, equipment, and operational  standards  to control
hazardous emission sources where a numerical  emission limit  is not
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feasible.  The 1977 Amendments, although they allowed promulgation of
nonemission standards, did not specifically provide authority to enforce
these standards.  The question of enforceability of nonemission standards,
in general, was resolved through passage in 1978 of the Health Services
Research, Health Statistics, and Health Care Technology Act.  This act
equated design, equipment, work practice, and operational  standards with
emission standards, thereby allowing EPA to enforce both emission and
nonemission standards.  However, as a result of these actions, EPA needs to
repropose the work practice provisions promulgated prior to the 1977
Amendments.
2.1.10  Executive Order 12291
     On February 17, 1981, President Reagan signed Executive Order 12291.
This order requires all agencies to prepare a regulatory impact analysis
(RIA) for all proposed regulations and to continue reviewing all  proposed
and existing regulations.

2.2  OBJECTIVES
     The objective of the Phase I review is to determine the need for
revising the current asbestos NESHAP.  The determination will  reflect
technological and regulatory development occurring since promulgation of
the NESHAP and other information pertinent to determining  the  standard's
adequacy.  In addition, the review is tc identify gaps,  if any, in the
asbestos NESHAP.  If revision of the standard is recommended,  suggestions
concerning the extent and form of revisions will  be presented.

2.3  APPROACH
     The result of Phase I will  be a recommendation to revise  or not to
revise the NESHAP and a discussion of findings and conclusions.  The
following information is examined:
          Use by affected industries of best available technology (BAT),
          Availability of sampling and analytical  methods  for  determining
          emission concentrations,
          Information linking health risks to exposure levels,
          Experience with enforcing the asbestos NESHAP,
          Other regulatory activities pertaining to asbestos,  and
          Deficiencies in the asbestos NESHAP.
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     The approach used in gathering  and  evaluating  this information
involved the following:
          Examination of EPA's  background  documents on the current
          standard and amendments,
          Use of computerized  literature search,
          Visits to asbestos mining, milling,  manufacturing,  and  demolition
          sites,
          Contacts with EPA and with EPA contractors,
          Contacts with EPA regional offices,
          Contacts with other  Federal  regulatory  agencies,
          Contacts with trade  associations,  and
          Contacts with control  equipment  vendors.
                                  2-14

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        3.0  INDUSTRY DESCRIPTION:   MINING,  MILLING,  MANUFACTURING,
                              AND FABRICATING

3.1  MINING
3.1.1  Industry Statistics
     Currently, four asbestos mines  are  operating  in  this  country.
California is the site for two mines:  Calaveras Asbestos  Corporation  in
Copperopolis (Calaveras County),  which led  the  nation in output  in  1980,  and
Union Carbide Corporation in Santa Rita  (San Benito County).   The Vermont
Asbestos Group's Lowell mine (Orleans County, Vermont)  was second in
production in 1980, while Jaquays Mining Corporation  in Gila  County,
Arizona, is the State's only active  mine.*   Mines  that  have closed  recently
include Atlas Asbestos Corporation in Santa Cruz,  California,  and Powhatan
Mining Company in Burnsville, North  Carolina.1  The Alaska Asbestos Company,
jointly owned by International Paper Company, Mclntyre  Mines,  Limited,  and
Tanana Asbestos Corporation, maintains an active program of drilling and
engineering feasibility at the Eagle property owned by  Doyon,  Limited.1  All
of the mines are far removed from large  population centers.
     In 1979, the United States produced 17 percent—93,000 metric  tons—of
domestic consumption, which totaled  561,000 metric tons.2   Total production
in 1980 was 80,079 tons, down approximately 14  percent  from 1979.1  Table 3-1
presents 1979 production information and fiber  grades produced by each
mining operation.
3.1.2  Process Description
     The asbestos content of ore bodies  varies  with location,  from  2 to 3
percent asbestos by weight at the Vermont mine  to  60  percent  at  Union
Carbide's mine in San Benito, California.  Surface mining  methods are  used
where the asbestos-containing ore lies near the surface and is not  bound
within massive rock deposits.  Such  ore  can be  bulldozed or removed by a
power shovel, a method used at the Union Carbide mine.   An initial  size
classification step is also carried  out  at the  site.   In Vermont and the
Copperopolis district of California, open pit mining  is used,  and blasting
is required to loosen the overburden for removal.   Holes are  drilled for
placement of explosives.  Secondary  blasting may  follow primary  blasting  to

                                   3-1

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TABLE 3-1.  UNITED STATES ASBESTOS PRODUCTION3*4.5

Mining
company
Calaveras
Union Carbide
Vermont Asbestos
Group
Jaquay
TABLE 3-2.

Source
Mining and milling
Mining
Uncontrolled
50% controlled
80% controlled
Mining

Type of
asbestos
Chrysotile
Chrysotile
Chrysotile
Chrysotile
ESTIMATED TOTAL
MINING IN THE

Year
1968

1969
1969
1969
1974

Grades
4-7
7
3-7
Mostly Grade 3
ANNUAL EMISSIONS FROM
UNITED STATES6 »7>8
Annual emissions
(metric tons)
5,105

578
288
110
373
Annual
production, 1979
(metric tons)
32,000
32,000
30,000
550
ASBESTOS

Reference
6

7
7
7
8
                      3-2

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reduce large boulders to manageable size.  The ore is loaded by mechanical
shovels into ore-hauling trucks and transported to a stockpile located at a
primary jaw crusher.   In Arizona where asbestos deposits are often narrow
veins extending far below the surface, it is necessary to resort to
underground mining.  The ore is freed by drilling and blasting, and the
fiber is mined in drifts and stopes using a modified room and pillar
method.6
3.1.3  Emission Sources
     Potential emission sources during mining include drilling, blasting,
bulldozing, loading ore into hauling trucks, hauling ore and other traffic
within the mine, initial processing at the mine site, and dumping ore in
stockpiles at the mill.  Emissions will  be influenced by meteorological
conditions, with wet  conditions helping  reduce emissions in  most mine
activities.  Ores with high moisture content will  be less likely to produce
emissions due to disturbances such as wind, loading, and dumping.
Estimates, not based  on sampling data, of annual  emissions from mines are
presented in Table 3-2.  One esimate is  based on  observations made and
information obtained  during field trips.6  The author of one report states
that the estimates are uncertain and may be off by at least  an.order of
magnitude.8
3.1.4  Control Techniques
     Control methods  currently used in asbestos mining have  changed little
in recent years and appear to represent  best available technology (BAT).
Emissions from drilling are controlled through use of fabric filters
situated on the drilling rigs.  Drilling is accomplished through a hood  over
the drilled hole; rubber aprons form its sides. -Air is exhausted from the
hood to the fabric filter.  The area under the hood acts as  a settling
chamber, preventing large chips from being drawn  into the fabric filter.9
The use of wet drilling methods to control  emissions is excluded from some
asbestos mining; e.g., in Vermont, where cold weather would  cause the water
to freeze.
     Emissions from blasting are difficult to control.  Control  methods
presently used in this country include use of gel  blasting agents and
injection of water containing a wetting  agent into the drilled holes prior
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to blasting.  The ore's moisture content helps control emissions during
blasting.
     Removal of overburden, shoveling of ore into trucks for hauling,
preliminary screening at the mine, and surface scraping of ore are
uncontrolled emission sources, which the water content of fresh ore helps
reduce.
     Emissions caused by trucking ore from the mine to the mill's storage
piles are reduced by wetting the roads in and around the mine.  Large water
tankers are used for this purpose.  Also, requiring trucks to travel slowly
in and around the mine helps reduce emissions both from the road surface and
the loaded ore.  Large-capacity trucks reduce the trips necessary between
mine and mill.  Ore stockpiled at the mill may be wetted from time to time
to control emissions.
     The current emission standard does not regulate the mining of asbestos.
Previously regulated by the Bureau of Mines, asbestos mining is now
regulated by the Mine Safety and Health Administration (MSHA).
3.1.5  Waste Disposal
     Overburden from mining is hauled and dumped to create a large pile.  No
attempts are made to stabilize these piles in any way.
3.1.6  Costs
     Mining costs and emission control costs were not collected during
Phase I.
3.2  MILLING
3.2.1  Industry Statistics
     The four mining sites currently operating in the United States also
operate the only four active mills in this country.  They are Calaveras
Asbestos Corporation and Union Carbide Corporation in California,  Vermont
Asbestos Group in Vermont, and Jaquays Mining Corporation in Arizona.   The
mills of Calaveras Asbestos Corporation and Vermont Asbestos Group are
located at the mine sites.  Union Carbide's mill  is near King City, about 90
kilometers (55 miles) from its Coalinga mine site.  Jaquays Mining
Corporation's mill is in Globe, Arizona, approximately 48 kilometers (30
miles) from the Gil a County mine site.  Table 3-1 summarizes production
                                   3-4

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information for each mining and milling company and the asbestos grade
produced by each company.  Total domestic production in 1980 was 80,079
tons.l
3.2.2  Process Description
     Asbestos milling is a complex operation primarily involving separation
of fiber from rock, and classifying fiber by length; the basic method has
changed little over the past several  years.2  The following description of
asbestos milling is excerpted from Control  Techniques for Asbestos Air
Pollutants.10
     Separation of asbestos fibers from rock typically is initiated by
conveying mine ore by a large hopper and pan feeder to a primary, jaw-type
crusher that accepts boulders up to 48 inches in diameter and reduces these
to fragments not larger than 6 inches in diameter.   Subsequently, this
crushed rock is transported by belt conveyor to trommel  screens, which are
rotating cylinders with various sized openings, or  to a stationary-bar
grizzly, a type of screen, for the sizing operation.  Ore fragments greater
than 1-1/4 inch in diameter are routed to a  secondary cone-type crusher for
further reduction, and outputs of primary and secondary crushers are
conveyed to a wet-ore storage pile exterior  to the  mill.  This stockpile
usually contains sufficient ore to sustain mill operation for an extended
time.
     Wet ore is extracted from the bottom of the wet-ore stockpile by a
vibrating-chute feeder located in an  underground tunnel.  The wet ore enters
slowly rotating cylindrical dryers that permit baffles internal  to the
dryers to pick up and release the wet ore continually, thereby exposing it
to a drying current of hot air.
     The dried ore is conveyed by belt to a  vibrating screen that sizes the
ore for fine crushing.  The undersized screenings and the output of the
final crushers form a dry-rock stockpile, which is  housed to protect it from
the exterior environment.
     The finely crushed, dried asbestos ore  next traverses a rock circuit,
where it undergoes several  screenings, fiberizing,  and aspiration to remove
freed fibers and further disintegrate rock.   The principal purpose of
                                   3-5

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this set of operations is to separate asbestos fibers from rock, but the
circuit secondarily functions to grade fibers according to length.
     In the rock circuit, cleaned rock is finally expelled to an exterior
tailings dump.  As the air streams that convey aspirated asbestos fibers
pass through cyclone collectors, the fibers are removed for cleaning and
additional grading.  Exhausts from these collectors are ventilated to
gas-cleaning devices.
     Fiber-cleaning circuits are intended to perform additional  fiber
opening, to classify and separate opened fibers from rock and unopened
material, and to carry out further fiber-length grading.  Grading,
screening, aspirating, and opening are involved in this circuit; in
addition, some material is rejected as waste.  The aspirated asbestos fibers
are deposited into cyclone collectors and subsequently delivered to the
grading circuit as long, medium, short, and extra-short fibers.   Cyclone
exhausts are directed to a gas-cleaning device.
     Asbestos fibers are separated into numerous standard grades and
cleansed further in the grading circuit.  Standard grading machines affect
additional opening of fibers and facilitate shorter fiber removal.   Air
aspiration from vibrating screens separates additional  fine dust, fine rock
fragments, and unopened fibers.  Cyclone collectors are exhausted through
fabric filters to control asbestos-containing dusts.  Asbestos fibers are
machine packaged either by compressing the material  into a dense bundle or
by blowing the material into bags.
     The Coalinga deposit of asbestos ore in California presents an
exception to the above practices in that no primary crushing is  carried out
prior to ore drying.  Furthermore, a wet process is employed for milling.
An ore-water mixture is carried through a proprietary grinding and
separating process to mill the asbestos almost entirely into fibrils.  A
subsequent dewatering operation produces cylindrical pellets of  asbestos
fibers, which measure approximately 3/8 inch in diameter and as  much as 3/4
inch in length and are formed and subsequently dried without a binder.   Some
of the asbestos is marketed in pellet form to end users.  If a completely
opened form of asbestos is needed for a manufacturing process, the  dry
pellets can be ground either at the mill  or by the end user.
                                   3-6

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3.2.3  Emission Sources
     Most phases of asbestos milling are potential  emission sources, which
may occur from the following:
          Dumping mine ore onto wet-ore stockpiles  or into receiving
          hoppers;
          Stockpile surfaces that have become dry and are subject to wind
          erosion;
          Belt conveying of asbestos ore,  fibers, and asbestos-containing
          tailings;
          Conveyor system transfer points;
          Feed and discharge ports of crushers;
          Ore dryers;
          Dry ore storage;
          Grading screens;
          Bagging of asbestos; and
          Tailings piles.
     Few emission data are available for asbestos milling operations.   Table
3-3 presents results of emission tests performed  on baghouses during the
early 1970s at the Vermont mill and at a Canadian mill.   Samples were taken
upstream and downstream from the baghouse  and collection efficiency
calculated.  Both phase contrast and electron microscopy were used to count
fibers.  Table 3-4 presents emission test  results for sampling at the
tailings pile of an asbestos mill (currently  not  open)  near Coalinga,
California.  Samples were taken between rain  showers and the only tailings
dumped were in a dry, dusty state.9  Results  of ambient  air samples taken in
the vicinity of an asbestos mill in Hyde Park, Vermont,  are presented in
Table 3-5.   Engineering estimates—and not precise  quantities—of annual
emissions from asbestos milling in the United States are given in Table 3-6.
3.2.4  Control Techniques
     Wet-ore stockpiles at the mill may be sprayed  with  water to control
emissions.   This apparently represents BAT and is done at Union Carbide's
mill where  enough ore is stockpiled to supply the mill  during the 6 months
the mine is closed.  The addition of water to the ore poses no operational
problems since the ore is milled wet (the  ore does  not require drying before
being processed)  and water is plentiful.  Furthermore, the Coalinga,
                                   3-7

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         TABLE 3-3.   BAGHOUSE EMISSIONS AND COLLECTION EFFICIENCIES
                           FOR ASBESTOS MILLING!!
Mill
location
Asbestos,
Quebec
Eden Mills,
Vermont
Samp! ing
location
Upstream
Downstream
Upstream
Downstream
Optical microscope
500X
Total
fibers Efficiency
(f/m3) (%)
2.19 x 109
8.33 x 105 99.96
1.42 x 109
4.52 x 104 > 99.99
Electron
16,
Total
fibers
f/m3)
1.24 x 1012
1.44 x 109
1.36 x 10l3
1.29 x 108
microscope
364X
Efficiency
99.88
> 99.99
    TABLE 3-4.  AMBIENT AIR CONCENTRATIONS OF FIBERS IN THE VICINITY OF
             ASBESTOS MILL TAILINGS PILE,  COALINGA, CALIFORNIA9
     Sampling data3
  Approximate sampling
location with respect to
active face of tailings
   pile, (m [ft])a
 Fiber concentration
by optical  microscopy
        (f/m3)
     conveyor transfer

   3 (10) at last
     conveyor transfer

   224 (736) downwind

   224 (736) downwind
      9.51  x 105


      9.31  x 105

      7.31  x 105
 Fiber concentration
by electron microscopy
       (f/m3)
330 (1,082) upwind
330 (1,082) upwind
3 (10) at last
0.75 x 105
0.86 x 105
7.39 x 105
1.54 x
-
1.58 x
ID8

108
     5.93 x 108
a Samples were taken at an elevation  of 2 meters (6.6 feet).

                                     3-8

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   TABLE 3-5.   SUMMARY OF AMBIENT ASBESTOS MONITORING DATA IN VICINITIES
                   OF ASBESTOS MILL, HYDE PARK, VERMONT*?
Emission source
Range of average asbestos
  concentrations (yg/m^)
Tailings pile, wet-rock storage,
  mill, dryer, conveyors

Primary crushing, conveyor,
  wet-ore storage

Dryer, dry rock storage,
  crushing, mill
          0.03-33.56


           5.2-18.81


          9.76-24
         TABLE 3-6.  ESTIMATED TOTAL ANNUAL EMISSIONS FROM ASBESTOS
                     MILLING IN THE UNITED STATES6»7>8
Source
Mining and milling
Mi 1 1 i ng
Uncontrolled
80% controlled
99% controlled
Milling (80% controlled)
Year
1968

1969
1969
1969
1974
Annual emissions
(metric tons)3
5,110

5,780
1,100
60
1,040
Reference
6

7
7
7
8
a These are  engineering estimates only,  not  precise quantities.
                                    3-9

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California, ore is 60 percent asbestos, and emissions from such stockpiles
can be assumed to have a relatively high content of asbestos.  Ore from the
other sites contains only 4 to 6  percent asbestos; emissions would probably
contain a similarly low concentration.   Because the other mines operate year
round, very little wet ore is stockpiled, typically enough for only 1 or 2
days.
     Exterior conveyor belts are  typically enclosed or their contents are
wet.  Points where conveyors drop waste onto tailings piles are either
exhausted or sprayed with additional  water.  Conveyor transfer points and
bucket elevators are enclosed and locally exhausted to baghouses.
     Crushing, fiberizing, screening, and grading operations are typically
contained under negative pressure; dust-laden air from these processes is
typically exhausted through a single primary baghouse.  Cyclone exhausts are
cleaned in baghouses, and dryer exhausts are vented through baghouses, which
frequently use Nomex® fabric filters due to high temperatures of exhaust
gases.  High-velocity, low-volume local  exhaust ventilation (LEV)  is used at
bagging stations to control occupational  exposure; dust is exhausted through
a baghouse.  Central and portable vacuum equipment is used to clean floors
and around equipment.  Control  technology used in asbestos milling has not
changed in recent years and still  appears to represent BAT.
3.2.5  Waste Disposal
     Millions of tons of waste, or tailings, are produced each year by
domestic asbestos milling and are deposited by conveyor belts onto large
tailings piles.  They usually are dumped wet onto the piles  to prevent
emissions.  Attempts to vegetate  the surface of tailings piles have met with
limited success due to the high alkalinity of the tailings,  which  inhibits
plant growth, and the expense of  hauling sufficient soil  cover in  which to
establish vegetation.  Chemicals  have been added to wet tailings prior to
dumping that help bind the particles and help the tailings resist  wind
erosion.  Upon drying, some tailings form a protective crust-like  cover that
resists erosion and protects underlying  material.  In some instances,
tailings piles from the milling of long-fiber asbestos ores  are
self-stabilizing because of the low percentage of fine dust,  the tendency of
meteorological conditions to form a layer of larger particles that protect
                                   3-10

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the pile's interior, and the consolidation of the pile by freezing during
much of the year.iO
3.2.6  Costs
     Information on control and process costs was not collected during
Phase I.

3.3  ASBESTOS PAPER PRODUCTS
3.3.1  Industry Statistics
     Asbestos paper products are used in a wide variety of applications but
have in common their production on papermaking machines.  Paper products can
be grouped according to categories in Table 3-7, which also presents, for
each category, asbestos consumption and asbestos paper production.  Flooring
felt alone accounts for nearly 50 percent of total  asbestos consumed in
paper products.  Asbestos consumed by flooring felt,  roofing felt, and
beater-add gasketing paper accounts for nearly 90 percent of total asbestos
consumed in asbestos paper products.  Production of flooring felt, roofing
felt, beater-add gasketing paper, and specialty paper increased from 1975
to 1979, as shown in Table 3-8.  During the same period, total  production
was up roughly 10 percent and production of millboard and roll board was
apparently declining.3
     Producers of asbestos paper, production location, specific products by
individual  plant, and employee information are shown  in Table 3-9.
3.3.2  Process Description
     Chrysotile is the predominant form of asbestos used in making asbestos
paper, but various binders and fillers may be added to produce desired
properties.  Table 3-10 shows typical  compositions  of various asbestos paper
categories.
     The process for making asbestos paper is similar to that for making
wood fiber paper and board.  The description below  is derived from a study
of the U.S. asbestos paper market.13
     Asbestos goes into a pulper or beater and is screened and cleaned to
achieve required properties.  The slurry is regulated to a consistency of
1/2 to 1 percent solids and fillers, binders, and other modifiers are added.
A sheet is  formed on either a Fourdrinier or cylinder machine and dewatered
                                   3-11

-------
    TABLE 3-7.  ASBESTOS CONSUMPTION AND  PRODUCTION  OF  ASBESTOS  PAPER3
Paper
category
Flooring felt
Roofing felt
Beater-add
gasketing paper
Pipeline wrap
Specialty papers
Millboard and
roll board
Commercial paper
Electrical paper
Total
Asbestos fiber consumed
(short tons)
120,000
90,000
25,000
15,000
6,600
4,500
4,200
1,000
266,300
Production
(short tons)
141,200
138,500
35,700
23,100
7,800
6,000a
4,400
1,050
357,750
a This estimate was  especially difficult,  given  the  rapidly  declining market
  for this product.   This  figure was  reached  from  consulting previous
  studies, contacts  with  industry  representatives, and  general  knowledge of
  the industry.
                                   3-12

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   TABLE 3-8.  UNITED STATES ASBESTOS PAPER PRODUCTS INDUSTRY  PRODUCTION,
                             1975 AND 19793>13
Paper category
Flooring felt
Roofing felt
Beater-add gasketing paper
Pipeline wrap
Specialty papers
Millboard and roll board
Commercial paper
Electrical paper
Total
(
1975
125,000
120,000
30,000
26,000
5,000+a
17,500
b
—
323,500+
Production
short tons)
1979
141,200
138,500
35,700
23,100
7,800
6,000
4,400
1,050
357,750
a Production estimate may be slightly understated since not all specialty
  products were included.

b Included in figure for millboard and roll board above.
                                    3-13

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TABLE 3-9.   PRODUCERS OF ASBESTOS  PAPER PRODUCTS3
Total
Producer employees
Alsop Engineering
Mlldale, Connecticut
Armstrong Cork
Fulton, New York
Boise Cascade
(Latex Fiber
Division)
Beaver Falls, New York
Cellulo
Fresno, California
Sandusky, Ohio
Congoleura
Cedar Hurst, Maryland
Ertel Engineering
Kingston, New York
Fllpaco
Chicago, Illinois
GAP
Erie, Pennsylvania
Whitehall, Pennsylvania
H S K Filters
Richmond, California
Holl Ingsworth 4 Vose
E. Walpole,
Massachusetts
Johns-Manville
Manvllle, New Jersey
Waukegan, Illinois
Lydall
(Colonial Fibre)
Covington, Tennessee
Rochester, New Hampshire
N/A

328

102




10
30
303

N/A

N/A
•

154
650
21-22

174



2,000
1,018


132
92
Production Flooring Roofing Gasketlng Pipeline Specialty Millboard/ Commercial Electrical
workers felt felt paper wrap papers rollboard papers paper
N/A X

287 X X

50 X




6-7 X
N/A X
268 X

N/A X

N/A X


N/A X X X XXX
412 X
15 X

90 XX



1,550 X XX X
824 X X X X X


112 X X
64 X
                                                                       (Continued)

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co
i
                               .TABLE  3-9.   PRODUCERS OF ASBESTOS  PAPER  PRODUCTS3  (Continued)
Producer
Nlcolet
NorMstown,
Pennsylvania
Ambler, Pennsylvania
Qu1n-T
Til ton. New Hampshire
Rogers
Rogers, Connecticut
Jim Walter
(Celotex)
Linden, New Jersey
locklund, Ohio
Total
employees
100-150
143
67
173
45
890
Production Flooring
workers felt
50-75 X
105
47
134
38
725
Roofing Gasketlng
felt paper
X X
•
X
X X
X X
Pipeline Specialty Millboard/ Commercial
wrap papers roll board papers
XX X
X
X

XXX
XXX
Electrical
paper

X



-------
          TABLE 3-10.  COMPOSITION OF ASBESTOS PAPER  PRODUCTS3.13
        Product and composition               Percent of composition
Asbestos flooring felt
  Asbestos                                              85
  Latex                                                 15

Asbestos roofing felt
  Asbestos                                            85-87
  Cellulose fibers                                     8-12
  Starch binders                                       3-5

Beater-add gasketing paper
  Asbestos                                            60-80
  Polymer                                             20-40

Pipe!ine wrap
  Asbestos                                              85
  Cellulose and starch binder                           15

Specialty paper
  Asbestos                                              85
  Cellulose, binder, and filler                         15

Commercial asbestos paper and millboard
  Asbestos                                            95-98
  Starch filler                                        2-5

Electrical paper
  Asbestos                                            80-100
  Organic fiber                                        0-20
                                   3-16

-------
to approximately 20 percent by passing over suction boxes.  The Fourdrinier
machine uses a travelling screen for sheet formation and is suited for both
high- and low-speed operations, making it preferable for production of
lighter grades or for a variety of grades on a single machine.  The cylinder
type uses a rotating vacuum roll for sheet formation and is operated at
lower speeds, making it suitable for producing heavier board grades.  Solids
content is increased to 35 to 40 percent by mechanical  and vacuum dewatering
on press rolls.  Finally, the sheet is dried on dryers such as steam-heated
cans or air dryers to give a solids content of 90 percent or more.
     Various finishing operations may be performed at the paper-
manufacturing site or the paper may be transported and finished at other
company-owned sites to reduce transportation costs.  The paper product may
be sold unfinished on the open market.  Depending on the product, finishing
steps include saturation with asphalt, tar, and resins; vinyl  coating;
cutting; and laminating.
3.3.3  Emission Sources
     Potential emission sources include storing and warehousing the bags of
asbestos, opening the bags and dumping the fibers into the pul per or beater,
mixing ingredients (although not likely due to the wet conditions), and
slitting the finished stock.  Emissions from sheet formation and subsequent
dewatering are unlikely because of the wet state of the product and the
presence of binders that hold the fibers in the product matrix.  Finishing
operations, such as saturating with asphalt and tar, are not likely to
produce asbestos emissions.  Little asbestos waste is created  by asbestos
paper production.  However, when wet waste is not removed from floors or
equipment, it may dry out and, if disturbed, release fibers.
     Engineering estimates of asbestos emissions from paper manufacture are
not precise.  Table 3-11 presents emission estimates based on  1969 asbestos
consumption for paper manufacture from uncontrolled and controlled sources.
Table 3-12 presents emission estimates from paper production based on 1976
asbestos consumption.  Estimates in Table 3-12 do not include  emissions from
production of roofing felts, insulating paper, or beater-add gasketing paper
due to differences in product classification by the report's authors.
                                   3-17

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       TABLE 3-11.  ESTIMATES OF TOTAL ANNUAL ASBESTOS EMISSIONS FROM
          ASBESTOS PAPER MANUFACTURING IN THE UNITED STATES, 19697
      Emissions to air
                Quantity3
               (short tons)
  Emissions, if uncontrolled
  Emissions, 75% controlled
  Emissions, 99% controlled
                   60
                   15
                  0.6
a Based on 1969 asbestos consumption data,
      TABLE 3-12.  ESTIMATES OF TOTAL ANNUAL ENVIRONMENTAL RELEASES OF
       ASBESTOS FROM PAPER MANUFACTURE IN THE UNITED STATES, 1976a14
         Emissions
  Quantity
(short tons)
       Comment
To air:
  From baghouse emissions
    (99.99% efficient)
To waste dump or landfill:
  Rejected product and  scrap

  Baghouse fines
  Process wastewater solids
To water:
  From process wastewater
  0.014-1.0
Not available

     140
     283
  5.4-11.6
Free-fibers
Small  because it can
  be recycled
Free-fibers
Fibers matted
  together by
  binders, but free-
  fibers are a
  possibility
Free-fibers with some
  binders
a Does not include asbestos  roofing,  insulation,  or gasket  paper.
  are based on 1976 consumption  data.
                              Estimates
                                   3-18

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3.3.4  Control Techniques
     Emissions from bag opening, dumping, .and mixing are controlled with use
of high-volume, low-velocity LEV.  Asbestos may be packaged in pulpable
bags, which can be added to the beater, in some cases alleviating the need
to open bags.  In other instances, pulpable bags still  must be opened; but
the bags can be put in the slurry, eliminating the problem of storing and
disposing of fiber-contaminated bags.  Baghouses and wet collectors are used
to clean exhaust air from the bag opening and mixing area.  With the use of
pulpable bags and elimination of bag opening and dumping, fiber release may
be sufficiently low to preclude the need for LEV and subsequent air-cleaning
devices.  LEV may be used at the paper slitting step.  Trimmings may be
returned pneumatically to the procsss through a mechanical collector; fine
material exhausted from the mechanical  collector is exhausted through a
baghouse to the atmosphere.  Baghouse and wet collector wastes can be
returned to the process.
     Following paper production, various finishing or additional  processing
steps may produce the desired product.   Examples include polyvinyl  coating
for vinyl  sheet flooring and asphalt saturation for roofing felt.  Very
little fiber is released during these processes and the .only controls
involved are to prevent effluent emissions associated with asphalt, tar, and
solvents.
3.3.5  Waste Disposal
     It has been noted that scrap and collection device wastes are often
returned to the process with the result that little solid waste is produced
for disposal; sludge collected from wastewater treatment commonly is
landfilled.
3.3.6  Costs
     Cost information for control equipment was not collected during
Phase I.

3.4  ASBESTOS FRICTION MATERIALS
3.4.1  Industry Statistics
     Asbestos friction materials include drum brakes, disc pads for disc
brakes, brake blocks,  clutch facings, and industrial  linings for
manufacturing equipment.  The largest segment of asbestos friction material
                                   3-19

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shipments by value is drum brake linings (molded and woven drum brake
linings), accounting for nearly 70  percent of the 1977 value of shipments
for all  asbestos friction materials.15  In 1972, disc brake pads accounted
for 6.8 percent of shipment value for all  friction material shipments.
Although 1977 shipment values  for disc brake pads are not available,
shipment values for the disc brake  pad segments probably have increased
since 1972 since disc brake systems have replaced drum brake lining systems
on many domestic automobiles.3  The only information available on production
quantities is a combined shipment quantity for disc brake pads and woven and
molded clutch facings of 94 million pieces.15
     Table 3-13 lists domestic producers of asbestos friction materials,
plants and their locations, employment information, asbestos and nonasbestos
product line, markets supplied by each manufacturer, and 1979 estimated
sales.  Information is incomplete,  depending on information withheld by the
company.
3.4.2  Process Description
     The general  formulation of asbestos friction materials is:
          Asbestos:  50 to 80  percent,
          Binder:  16 to 45 percent,  and
          Friction modifiers:   5 percent.16
     Brake linings and clutch  facings  may  be manufactured  by either a  molded
or woven process.  The molded  process  is further characterized by the
"dry-mix" and "wet-mix" processes.   The following descriptions are from an
EPA study.17
     Manufacturing steps typically  used in "dry-mix" molded  brake lining
manufacture begin with weighing and mixing in a two-stage  mixer  the bonding
agents,  metallic constituents, asbestos fibers, and additives.   The mix is
then hand-tamped into a metal  mold, which  is placed in  a preforming
press that partially cures the molded  asbestos sheet.   The asbestos sheet  is
taken from the preforming press and put in a steam-preheating  mold to  soften
the resin in the molded sheet.  The molded sheet is formed to  the proper arc
by a steam-heated arc former,  which resets the resin.   The arc-formed  sheets
are then cut to proper size.   The lining is  baked in compression molds to
retain the arc shape and convert the  resin to a thermoset  or permanent
                                   3-20

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                                TABLE  3-13.   DOMESTIC PRODUCERS OF  ASBESTOS  FRICTION  MATERIALS3
CO
Company
General Motors
Corporation
Chrysler
Corporation
Bendix


Raybestos-
Manhattan
Abex Corporation
(1C Industries)
Carlisle
Corporation
Auto Friction
Corporation
Plant
Delco-Moraine Division
(Dayton, Ohio)
Inland Division
(Dayton, Ohio)
Trenton Chemical
Green Island, New York
Cleveland, Tennessee
St. Joseph, Michigan
Stratford, Connecticut
Manheim, Pennsylvania
Crawfordsvllle, Indiana
American Brake Blok
Division
(Winchester, Virginia)
Salisbury,
North Carolina
Ridgeway, Pennsylvania
Lawrence, Massachusetts
Empl oyment
Total Production
2,300a 	
N/A N/A
N/A N/A
497 404
930 684
l,569d 1,219
846°" 657
484d 376
700-1,000 525-750
150 140
425 300
400 300
Product line
Asbestos
Disc brake pads
Clutch facings
and drum brake
linings
Clutch facings
and disc and
dr.um brake
linings
Brake linings
Brake linings
Disc brakes
Brake linings and
disc brake pads
for light and
heavy vehicles;
other friction
material s
Disc pads, drum
brakes, truck
blocks, brakes for
off-the-road
brake blocks
Drum brake linings
for light and
heavy trucks, disc
brakes
Disc and drum
brake linings for
passenger cars and
1 ight trucks
Nonasbestos Market
Disc brake pads and CMC
other auto parts
Delco-Moraine
(GMC)
Chrysler

Friction materials OEM and
after-market
Semlmetallic and
cermet disc brake,
master cylinders
Friction materials OEM and
and brake parts aftermarket
None6 OEM and
aftermarket
None6
Drum brake linings N/A
None6 Aftermarket
1979 estimated
sales
$16.225,000b
(asbestos
friction
materials only)
N/A

J94.555.OOOC

$165,000,000b
(asbestos
friction
materials only)
$66.593.000
$28.. 161, 000
$26,505,000
      (Footnotes on last page of table.)
(Continued)

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                         TABLE 3-13.   DOMESTIC  PRODUCERS  OF ASBESTOS  FRICTION  MATERIALS3  (Continued)
co
i
ro
ro
Company
H. K. Porter
Nuturn
Royal Industrial
Brake Products
(Lear-Siegler)
National Friction
Products
Corporation
Gatke Corporation
Standee Industries
Brassbestos
Manufacturing
Corporation
Thiokol Chemical
Corporation
Plant
Huntington, Indiana
Paulding, Ohio
New Castle, Indiana
Smithville, Tennessee
Danville, Kentucky
Logans Port, Indiana
Warsaw, Indiana
Houston, Texas
Paterson, New Jersey
Trenton, New Jersey
Employment
Total Production
400 200
115
80-100
120
241d 175-200
180 145
180d 150
131 106
120-130 98
147d 114
Product line
Asbestos Nonasbestos
Disc and drum Semlmetal 1 ic disc
brake linings and brakes; nonasbestos
clutch facings clutch facings
for passenger
cars; brake
blocks; heavy duty
brake linings and
industrial parts
Disc pads and
drum brakes for
passenger cars; None6
clutch facings
and truck blocks
Disc and drum None6
brake linings
for passenger cars
and light trucks
Brake linings and None
clutch facings for
off-the-road
vehicles
Friction materials Friction materials
Nonautomotlve None6
brake linings and
clutch facings;
oil-well brake
blocks
Brake linings for None6
passenger cars
and light trucks
Disc brake pads None6
and drum brake
linings for
passenger cars
Market
OEM and
aftermarket
301 OEM
701 aftermarket
Aftermarket
Off-the-road
vehicle manu-
facturers
(tractors, lawn
mowers, etc.)
Aftermarket
Oil companies,
industrial
equipment
manufacturers
Aftermarket
OEM and
aftermarket
1979 estimated
sales
$26.505,000
$21,535,000
$15,969,000
$11,927,000
$11,927,000
$8,680,000
$8,283,000
$9,740,000
      (Footnotes on last page of table.)
(Continued)

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                               TABLE  3-13.   DOMESTIC PRODUCERS  OF  ASBESTOS  FRICTION  MATERIALS3  (Continued)
co
t
ro
co
Employment
Company Plant
Wheeling Brake Bridgeport, Ohio
Block
Lasco Brake Oakland, California
Products
Total
61
58d
Production
51
40.-50
Product
Asbestos
Brake linings for
off-the-road
vehicles
Disc and drum
brake linings
line
Nonasbestos
None6
Nonasbestos
friction materials;
Market
Distribution,
mining, and
construction
companies; all
for replacement
After-market
1979 estimated
sales
$4,042,000
$3,843,000
Molded Industrial
  Friction
  Corporation

Scan-Pac
  Manufacturing
  Company
        Reddaway
          Manufacturing
          Company
                             Prattville,  Alabama
                             Menomonee Falls,
                               Wisconsin
                     Newark,  New Jersey
  54d        42         Brake linings for
                       tractors
40-45      33-38        Brake linings for
                       off-the-road
                       nonautomotive use
  31         22         Brake linings for
                       Industrial,  non-
                       automotive  uses
                                                                                                     manufacture other
                                                                                                     nonasbestos products
None (plant  in
Kentucky manufac-
turers nonasbestos
linings)

None
                                        $3,578,000
Primary manu-
facturers of
lawn mowers,
snow mobiles, etc.

Primary manu-
facturers of
elevators and
washing machines
$2.816,000
$3,000,000°
Red ford


Auto Specialties
Manufacturing
Corporation


National Brake
Block
Boston. Massachusetts


St. Joseph, Michigan




Mobile, Alabama

15 14 Brake linings for-
passenger cars and
light trucks
10d 8 Brake linings for
tractors and
combines


6d 3-6 Brake linings for
passenger cars
None Guardian
Corporation
(assemblers)
No substitute frlc- OEM In farm
tion materials; machinery
other auto parts
produced (plant has
total of 185 employees)
None After-market

$994,000


$663,000




$398,000

Borg-Warner Corporation^
        N/A:  Company would not supply Information.

        a Only a fraction of these workers  are  involved in friction  material manufacture.
        b This estimate, of 1979 sales of asbestos friction materials,  was  supplied by the company.
        c This estimate is understated because  Bendix would not supply  employment figures for the New York  plant.
        d Total  employees were estimated  from the number of production  employees (supplied by plant  personnel) by applying an average ratio  of  production workers
          to total employment.  The ratio was calculated from plants from which both production and  total employment figures were available.
        e Plans  to produce nonasbestos friction materials.
        f No Information provided.

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condition, finished, inspected, and packaged.  Finishing steps include
sanding and grinding of both sides to correct thickness, edge grinding, and
drilling holes for rivets.  Following drilling, the lining is vacuum
cleaned, inspected, branded, and packaged.
     "Wet-mix" process is a misnomer, because the molded lining ingredients
are relatively dry.  The designation "wet-mix" arises from solvent use in
production.
     After the ingredients are weighed,  they are combined in  a sigma blade
mixer and are then sent to grinding screens where the mixture's particle
size is corrected.  The mixture is conveyed to a hopper where it is forced
into the nip of two form rollers that compress the mixture into a continuous
strip of friction materials.  The strip  is  cut into proper lengths and
arc-formed on a round press bar, each operation by separate units.  The
linings are then placed in racks and either air dried or oven dried to
remove the solvent.  An alternative is to place the arc-formed linings in
metal molds for oven baking.  From the ovens, the linings are finished,
inspected, and packaged.
     Molded clutch facings are produced  in  a manner similar to the wet-mixed
process.  The rubber friction compound,  solvent, and  asbestos fibers are
placed in a mixer churn, and the mixture is conveyed  to a sheeter mill  that
forms a sheet or slab of the materials.   The sheet is then diced  by a rotary
cutter into small pieces, which are placed  in an extrusion machine that
forms sheets of the diced material.  The sheets are cut into  proper size and
punch-pressed into doughnut-shaped sheets;  scraps are returned to the
extrusion machine.  The punched sheets are  placed on  racks and sent to a
drying oven and then to a baking oven for final  curing and solvent
evaporation.  The oven-dried sheets are  sent to the finishing operations.
     Woven clutch facings and brake linings are manufactured  of high-
strength asbestos fabric frequently reinforced with wire.   The fabric is
predried in an oven or by an autoclave to prepare it  for impregnation with
resin.  The fabric can be impregnated with  resin by several techniques:
          Immersion in a bath of resin,
          Introducing the binder into an autoclave under pressure,
                                   3-24

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          Introducing dry impregnating material  into carded fiber before
          producing yarn, and
          Imparting binder into the fabric from the surface of a roll.
After the solvents are evaporated from the fabric, the fabric is made into
brake linings or clutch facings.  Brake linings are made by calendering or
hot pressing the fabric in molds.  The linings are then cut, rough ground,
placed in molds, and placed in a baking oven for final curing.  Following
curing, the lining is finished, inspected, and packaged.
     In the manufacture of woven clutch facings, the treated fabric is cut
into tape-width strips by a slitting machine.  The strips are wound around a
mandrel to form a roll of the fabric.  The roll  is pressed in a steam-heated
press and then baked in an oven to cure the resin in, the clutch facing.
Following the curing, the clutch facing is finished, inspected, and
packaged.
   The friction products industry is a mature one with only marginal  changes
occurring in the production processes over the years;  older plants are labor
intensive as opposed to capital  intensive.18
3.4.3  Emission Sources
     Potential sources of asbestos emissions in  friction materials
manufacture include the unloading and warehousing of palletized bags,
weighing, bag opening, charging of mixers, blending of ingredients,
discharging of mixers, forming or rolling, curing, and finishing operations.
Finishing operations generate large quantities of asbestos-containing
dust.!0
     Emissions from these sources are collected  using  LEV and exhausted  to
fabric filters or wet collectors.  Disposal  of waste dust from collection
devices is another potential  emission source.  Wastewaters from wet
collectors are held in settling ponds; settled material  occasionally  is
dredged from the pond and is  another potential  emission  source upon drying.
   Emission concentration data for friction material manufacturers were  not
available.  However, various  estimates have been made  of total  annual
emissions and are presented in Tables 3-14,  3-15,  and  3-16.   These estimates
are not precise and project only a general magnitude of  release.  Estimates
in Table 3-14 are based on a  series of estimates of collection efficiency.
Estimates in Table 3-15 are,  in most instances,  based  on emission estimates
                                   3-25

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        TABLE 3-14.   ESTIMATES OF TOTAL ANNUAL ASBESTOS EMISSIONS FROM
              FRICTION MATERIAL PROCESSING IN THE UNITED STATES7
                                                         Quantity
          Emissions to aira                          (metric tons/yr)
      Emissions, if uncontrolled                          5,711
      Emissions, 95% controlled                             286
      Emissions, 99% controlled                              57

a Based on 1969 asbestos consumption.
        TABLE 3-15.   ESTIMATES OF TOTAL ANNUAL ASBESTOS EMISSIONS FROM
           FRICTION  PRODUCT MANUFACTURING IN THE UNITED STATES8.19
                                                      Quantity
          Emissions to air                         (metric tons)3
            From process                                  18
            From disposal                                 36

a Based on 1974 asbestos  consumption.
                                     3-26

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       TABLE 3-16.  ESTIMATES OF TOTAL ANNUAL ENVIRONMENTAL RELEASE  OF
      ASBESTOS FROM FRICTION MATERIAL MANUFACTURE IN THE UNITED STATES14
              Emissions3
  Quantity
(short tons)
                  Comment
 To air:
      Baghouse emissions
      Air scrubber emissions

 To waste dump or landfill:
      Baghouse fine and product scraps
      Wastewater solids from air
        scrubbers

 To water:
      Wastewaters from air scrubbers
  0.61-6.0     Free-fibersb
    0.14       Free-fibers'3
8,130

 6.7


 0.3
               Mostly free-fibers15

               Wet free-fibers^


               Free-fibers13
a Based on 1976 asbestos consumption.

b These "free-fibers" may be coated with resin;  however, "free" indicates a
  potentially  respirable fiber.
                                     3-27

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from individual  plants, production rates, number of fibers per unit of
weight, and extent of control  present in the asbestos industry;8 the limit
of accuracy is an order of magnitude.8,19  Emissions to air given in Table
3-16 were estimated similarly; the smaller number for baghouse emissions was
calculated using a materials balance approach.14
3.4.4  Control Techniques
     There has been no apparent change in BAT in the friction products
industry.  LEV systems are employed extensively in the manufacture of
friction materials.  Captured  air typically is exhausted through baghouses,
although wet collectors are used in a few plants.1?  Central  vacuum-cleaning
systems are also used for in-house cleanup around the various operations.
These units use fabric filtration for cleaning exhaust air.   To  help control
emissions from the process of  removing waste from baghouses  for  disposal,
some manufacturers of friction materials convey (pneumatically or by screw
conveyor) baghouse waste to a  device that, through the addition  of water,
converts the waste to small pellets.  Such pellets can be handled more
easily without the dust problem of loose baghouse waste.^0
3.4.5  Waste Disposal
     Friction material waste consists of rejects, material  collected in
baghouses, vacuum cleaner waste, dredged solids from wastewater  settling
ponds, empty asbestos bags, baghouse bags, and disposable personal
protective equipment.  Wastes  are typically disposed of in landfills.
Plants either dispose of waste themselves on their own property  or contract
with a private waste-handling  company for waste transport and disposal.
Waste disposal sites may be either publicly (municipal  or county)  or
privately owned and operated.   As discussed above, baghouse waste may  be
pelletized to facilitate handling and dust control.   Recycling of friction
material waste back into the manufacturing process is not commonly
practiced.
3.4.6  Costs
     Information on control equipment and process costs was not  collected
during Phase I.
                                   3-28

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3.5  ASBESTOS-CEMENT PRODUCTS
3.5.1  Industry Statistics
     Asbestos/cement (A/C) products manufactured in the United States
usually fall under one of two categories:  sheet or pipe.  However, a small
market exists for A/C molded and extruded products.  Six U.S. manufacturers
produce A/C products, of which Johns-Manville, Cement Asbestos Products
Company (a subsidiary of Asarco), and CertainTeed Corporation produce A/C
pipe; and Johns-Manville, International Building Products (formerly National
Gypsum), Nicolet, and Supradur produce A/C sheet.
     The six manufacturers employ approximately 3,100 workers, which is
about 20 to 25 percent of total employment in the asbestos manufacturing
industry.  Employment characteristics for each of the A/C pipe and sheet
manufacturers and their plant locations are summarized in Tables 3-17 and
3-18, respectively.21,22  individual plant production quantities were not
available.
     In 1977, shipment value of A/C pipe, conduit, and ducts was $215
million, approximately 25 percent of total value of the asbestos industry
market.  The 1977 shipment value for A/C sheet was $52 million,
approximately 5.4 percent of the value for all asbestos products.21
     Since 1969, asbestos consumption by the A/C industry has fluctuated
between 148,000 and 288,000 metric tons with 1980 consumption (152,000
metric tons) the lowest reported except for 1976 consumption.  Overall
asbestos demand within the pipe industry stayed relatively stable until
1980, as opposed to a steady decline in demand in the sheeting industry.
Table 3-19 presents U.S. asbestos consumption in the A/C industry and total
U.S. consumption for the period from 1969 to 1980.1»21
   The A/C pipe market share of water and sewer pipe has declined slightly
due to availability of substitute materials and citizen concern over
possible release of asbestos fibers into water systems.23  Although the
demand for A/C sheet has declined due to the introduction of substitutes,
further decline is not likely without performance improvements among
substitutes or a large increase in cost of A/C sheet.23
     In 1977, the Bureau of Mines projected U.S. demand for asbestos in the
year 2000 was 274,000 short tons for the pipe industry and 116,000 short
                                   3-29

-------
                  TABLE 3-17.  PRODUCERS OF A/C PIPE21.22
  Producer and location
  Total
empl oyees
     Product line
Asarco, Inc.
  Cement Asbestos Products
  Company
  Ragland, Alabama
CertainTeed Corporation
  Santa Clara, California
  Riverside, California
  Ambler, Pennsylvania
  Hillsboro, Texas
Johns-Manville Corporation
  Denison, Texas
  Long Beach, California
  Stockton, California
   140

   140
   115
   165
   180
   204

   362
   247
A/C pipe

A/C pipe
A/C pipe
A/C pipe
A/C pipe
A/C pipe and polyvinyl
chloride pipe
A/C pipe
A/C pipe and polyvinyl
chloride pipe
                                   3-30

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             TABLE 3-18.  MANUFACTURERS OF A/C SHEET PRODUCTS2!
Producer and location
  Total
employees
Product line
Johns-Manville

  Nashua, New Hampshire        86

  Waukegan, Illinois        1,018


International Building
  Products (formerly
  National Gypsum)

  New Orleans, Louisiana      200

Ni colet

  Ambler, Pennsylvania        143



Supradur

Wingap, Pennsylvania        125-130
                       A/C sheet products only

                       A/C sheet and asbestos
                       papers
                       A/C flat and corrugated
                       sheet; siding
                       A/C flat sheet; asbestos
                       millboard and roll board;
                       compressed asbestos
                       gasketing
                       A/C roofing and siding
                                   3-31

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     TABLE 3-19.   U.S.  CONSUMPTION OF ASBESTOS IN A/C
INDUSTRY  COMPARED TO TOTAL U.S.  CONSUMPTION,  1969-198Q1*2
                  (Thousand metric tons)

1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Asbestos
pipe
135
126
131
140
151
202
139
127
145
217
213
144
Cement
sheet
50
46
48
52
58
86
40
21
40
36
11
8
Total
cement
products
185
172
179
192
209
288
179
148
185
253
224
152
Total U.S. consumption
711
666
689
734
795
768
552
659
610
619
560
359
                           3-32

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tons for the sheet industry.24  The 1980 projections show a change in
expected asbestos demand for the year 2000:   the pipe industry is expected
to consume 210,000 metric tons and asbestos  will no longer be used in the
sheet industry.^
3.5.2  Process Description
     In the United States, A/C products are  made from varying amounts of
asbestos, cement, and silica.  On a weight basis, A/C pipe normally contains
from 15 to 25 percent asbestos, 42 to 53 percent Portland cement, and 34 to
40 percent finely ground silica.21  The A/C  products may have an asbestos
content range of 10 to 70 percent, but such  extremes are used for specialty
items only.25  Chrysotile is the principal type of asbestos used in A/C
pipe.  In 1980, 83.13 percent of asbestos used in A/C pipe was chrysotile,
16.74 percent was crocidolite, and 0.13 percent was amosite
(cummingtonite-grunerite asbestos).21  up to 6 percent of finely ground
solids from damaged pipe also are used by some plants as filler material.25
The average asbestos content of A/C pipe, by weight, has been calculated at
about 18 percent.  An average asbestos content of 25 percent has been
reported,26 while another report stated that asbestos content is normally
below 20 percent.27  Grades of asbestos-fiber commonly used for A/C pipe are
4 and 5.21
     Nearly all asbestos presently used in A/C sheet is chrysotile; a small
amount of amosite and anthophyllite asbestos is used also.  A/C sheets
contain 12 to 35 percent asbestos, 45 to 54  percent cement, and 30 to 40
percent silica.27  Grades 4, 5, and 6 commonly are used in A/C sheet.21
     Manufacturing processes for A/C pipe and sheet may vary slightly from
plant to plant, but the overall processes are the same.  In general,  the
method used to make A/C pipe and A/C sheet is similar to methods used to
make asbestos paper and asbestos millboard.   Also, A/C processes can  be wet,
dry, molded, or extruded.
     The following description of the basic  process for pipe manufacture is
reproduced- here from an EPA document.25
     "After thorough blending of the raw materials, the mixture is
     transferred to a wet mixer or beater.   Underflow solids and water from
     the save-all are added to form a slurry containing about 97 percent
                                   3-33

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     water.   After thorough mixing,  the slurry is pumped  to the cylinder
     vats for deposition onto one or more horizontal  screen cylinders.  The
     circumferential  surface of each cylinder is a fine wire mesh screen
     that allows water to be removed from the underside of the slurry layer
     picked  up by the cylinder.  The resulting layer  of asbestos-cement
     material  is usually from 0.02 to 0.10 inch in thickness.  The layer
     from each cylinder is transferred to an  endless  felt conveyor to build
     up a single mat  for further processing.   A vacuum  box removes
     additional  water from the mat prior to its transfer  to mandrel  or
     accumulator roll.  This winds the mat into sheet or  pipe stock  of the
     desired thickness.  Pressure rollers bond the mat  to the stock  already
     deposited on the mandrel or roll  and remove excess water.   Pipe
     sections are removed from the mandrel, air cured,  steam cured in an
     autoclave,  and then machined on each end."
     Although the general description may apply to all  A/C processes,
differences  often exist in methods of fiber opening,  raw  material  mixing,
and product  forming.   For example, raw materials usually  are blended dry
after fiber  opening in a willow or a similar  device.  However,  fiber opening
and blending of raw materials can be achieved using wet methods.
     A/C sheet is manufactured using either a dry process,  a  wet  process,  or
a wet mechanical  process.  In the dry process, raw materials  are  dry mixed,
and the mixture is spread evenly over a moving belt,  sprayed  with water, and
compressed by rolls to required thickness.   The moving  sheet  is cut  to
desired sizes and shapes and is autoclaved.  The dry  process  is generally
used for shingle and  siding products.   Flat or corrugated  sheets  are
produced in  the wet process by introducing  the A/C slurry into  a  mold and
hydraulic press.  The slurry is squeezed to remove water  from the mold.  The
sheet is ejected from the mold and cured as in other  A/C  products.   The  wet
mechanical process is similar to the process  for making A/C pipe,  except the
A/C material  on the accumulator roll  is slit  across the roll  to produce  a
sheet.
     Molding processes are used to make small, irregularly  shaped A/C
products. This  process and the extrusion process are limited to  speciality
products.
                                   3-34

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3.5.3  Emission Sources
     Asbestos emission sources and their number are determined by process
design.  Both wet-mix and dry-mix processes have in common eight emission
sources of asbestos fiber:  unloading and storage of asbestos fibers, bag
opening and dumping, fiber opening, weighing, transferring, blending of raw
materials, dust collection, solid waste, and wastewater disposal.  Unloading
asbestos involves use of forklifts to remove pallets of bags containing
asbestos from rail cars or trucks.  Asbestos pallets are usually unitized;
i.e, wrapped in plastic to help prevent damage to bags during transport.
Mixing is an additional emission source in processes that use dry mixing.
This emission source is absent in processes that wet mix raw materials.  In
addition, wet-mix processes open fibers and blend raw materials in a slurry,
thus eliminating two emission sources common to dry mixing.
     Disposal of asbestos fibers removed by LEV and filtering devices and
not recirculated into the production process may be an emission source
depending upon precautions taken in containing fibers during transportation
and at the disposal site.  Disposal of A/C solids dredged from process
wastewater settling ponds is also a potential asbestos emission source.
     Finishing operations also produce emissions.  However, it has been
reported that 90 percent of the fibers with aerodynamic diameters less than
7 micrometers produced by cutting, grinding, buffing, and other finishing
steps differ from pure asbestos fibers.28
     Attempts have been made to characterize asbestos emissions from various
industries, but few data on fiber emissions have been reported.29  The
majority of studies that characterize asbestos fibers and airborne
concentrations are concerned with evaluating occupational  hazards.  However,
there are two references in which asbestos fiber emissions from several
sources including A/C processors have been estimated.  In a 1971 study, it
was estimated that 825 tons of fiber per year are emitted nationwide from
uncontrolled A/C plants and 8.3 tons per year from controlled A/C plants
(assuming 99 percent collection efficiency)-'7  These estimates were based on
use of 1969 asbestos consumption data to calculate an emission factor for
uncontrolled sources of 4 pounds of fiber per ton of asbestos consumed.  In
                                   3-35

-------
a 1975 study, an emission factor of 1 pound per ton from controlled emission
sources in the A/C industry was estimated.30
     In both studies cited above,?»30 emission rates are engineering
estimates and are not accurate.29  However, the two studies demonstrate that
emission rates may be reduced significantly by application of appropriate
and adequate controls.29  The numbers reported in both studies suggested
relative emission rates of various sources.29  Emissions from the A/C
industry and asbestos paper and floor tile are low, relative to emissions
from textiles, friction products, mining and milling, and consumptive users
of asbestos.29
   In 1974, EPA determined fiber counts and removal efficiencies for control
equipment used in the industry.11  The Agency also determined size
distribution and fractional removal  efficiences of collected asbestos
fibers11 (see Tables 3-20 and 3-21).  The EPA study showed that the number
of fibers less than 1.5 micrometers emitted is greater than the number of
fibers larger than 1.5 micrometers emitted.  The study also determined that
collection efficiency for smaller fibers was slightly lower than that for
larger fibers.  It was concluded that the greater number of small  fibers
emitted was due to a large concentration of small  fibers caught by the LEV
system rather than a low baghouse collection efficiency.11  However, due to
the low removal efficiency of one piece of demonstrated control  equipment,
the authors of the report had to qualify this conclusion by claiming a
possible error in sampling the A/C pipe plant emissions.
     A National Institutes of Health (NIH) study19 reported emission
estimates from processing asbestos for A/C pipe and sheet products based
upon 1974 production data and EPA's data11 on baghouse emissions.   These
estimates reproduced in Table 3-22 were calculated from algorithms derived
in an unpublished report.^  An emission factor of 0.1 kilogram of fiber
emissions per metric ton of processed asbestos was calculated for A/C pipe
and for A/C sheet.8  This emission factor was compared with another of 0.5
kilogram per metric ton based upon 1968 data and reported by Anderson in
1973.  The emission reduction was attributed to substantial  improvements in
control technology since 1968.8
                                   3-36

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              TABLE 3-20.   BAGHOUSE EMISSIONS AND FIBER REMOVAL
                   EFFICIENCIES FROM A/C PIPE PLANTS, 1974H
                       Optical  microscope              Electron microscope
                   Total  fiber                   Total fiber
                    emissions                     emissions
                >1.5 micrometers               <1.5 micrometers
Plant sampling      (number of                     (number of
  location          fibers)       % efficiency      fibers)       % efficiency


Denison,  TX

  Upstream          1.02  x 10&                   3.20 x 10?

  Downstream        2.88  x 104       97.18       1.38 x 107          57.90

Waukegan, IL

  Upstream          >1010            	        >1014                	

  Downstream        6.37  x 103       >99.99      1.08 x 107         >99.99
                                     3-37

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     TABLE 3-21.   SIZE DISTRIBUTION AND FRACTIONAL REMOVAL  EFFICIENCIES
                          FROM TWO A/C PIPE PLANTS1!

Size distribution
(wn)
>30
20-30
10-20
1.5-10
0.54-1.5
0.36-0.54
0.18-0.36
0.06-0.18
99.99
>99.99
>99.99
>99.99
>99.99
>99.99
>99.99
100
100

       TABLE 3-22.  ESTIMATES OF TOTAL ANNUAL EMISSIONS FROM PROCESSING
      ASBESTOS FOR A/C PIPE AND SHEET PRODUCTS IN THE UNITED STATES8>19
                               Emissions to air (metric tons)3
 Product                  From processs             From disposal
A/C pipe
A/C sheet
20
9
101
43
aBased on 1974 asbestos consumption.
                                     3-38

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     In 1978, EPA published estimates of asbestos emissions to disposal
sites, to water, and to air from A/C pipe and sheet manufacturing sources
based upon engineering assumptions.  As in earlier studies, the EPA study
noted that data required to calculate actual emissions were not available.
EPA's published estimates provide only a general  magnitude of asbestos
release.  These estimates are reproduced in Table 3-23 and Table 3-24.
3.5.4  Control  Techniques
     Wetting of raw fiber may be the simplest control technique.  However,
wetting methods must be compatible with process design and must not alter
product specifications.  Asbestos fiber emissions from mixing, fiber
opening, and blending can be controlled by wet process methods.  However,
such methods are not commonly employed in A/C pipe manufacture.  Also,
emissions from some finishing operations can be controlled by wet dust
suppression systems.
     Engineering measures are generally chosen to control  asbestos emissions
in the A/C manufacturing industries.  Extensive use of LEV to control
occupational exposures and use of fabric filtration to control atmospheric
emissions are common practice in A/C product manufacturing and represent
BAT.
   An estimated 95 percent of controls in asbestos manufacturing and
fabricating operations are by exhaust ventilation.  The air-cleaning device
most used in conjunction with LEV, central  vacuum systems, and air-cooling
and heating systems is the baghouse.  A survey of the asbestos industry in
1973 and 1974 showed that 80 percent of the plants used baghouses, 90
percent of control devices in place were baghouses, 4 percent of the
plants used a combination cyclone and baghouse, and 3 percent of the control
devices were a cyclone-baghouse combination.H  In a 1976  study of
the efficiency of asbestos baghouse filters, it was concluded that for
all fabrics and values of the baghouse operating  parameters tested, the
mass efficiencies of asbestos collection exceeded 99.99 percent.31
     Baghouses in conjunction with local  exhaust  systems,  operation
enclosures, enclosed screw conveyors and belt conveyors, and pneumatic
conveyors commonly are used to control  fiber emissions from bag-opening
                                   3-39

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         TABLE 3-23.  ESTIMATED TOTAL ANNUAL ENVIRONMENTAL RELEASE OF
           ASBESTOS FROM A/C PIPE MANUFACTURE IN THE UNITED STATES14
          Emissions
  Quantity
(short tons)3
         Comments
To waste, dump, or landfill:

     Rejected pipe and scrap
     Baghouse fines
     Process wastewater solids

To water:

     From process wastewater

To air:

     From baghouse emissions
  10,680
     737
     480
 11-12.5
 0.1-2.2
Fibers bound in cement matrix
Free-fibers
Fibers bound in cement matrix
Fibers coated with cement
Free-fibers
aBased on 1976 asbestos consumption.
     TABLE 3-24.  ESTIMATED TOTAL ANNUAL ENVIRONMENTAL RELEASE OF ASBESTOS
                FROM A/C SHEET MANUFACTURE IN THE UNITED STATES14
           Emissions
  Quantity
(short tons)3
         Comments
To waste, dump, or landfill:

     Rejected sheet and scrap
     Baghouse fines
     Process wastewater solids

To water:

     From process wastewater

To air:

     From baghouse emissions
  1,525         Fibers bound in cement matrix
    105         Free-fibers
     74         Fibers bound in cement matrix
    1.9          Fibers coated with cement
  0.01-1.5       Free-fibers
aBased on 1976 consumption.
                                   3-40

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operations; from fiber opening, weighing, and blending operations; and from
conveying fiber prior to adding water to the A/C mix.
     Emissions are controlled by maintaining storage bins and workspace
under negative pressure and by exhausting air through a baghouse.  However,
emissions will not be kept to the minimum if such air-cleaning devices are
not maintained at optimal  performance.  Makeup air provided to the work
spaces must be cleaned to  prevent employee exposure to airborne toxic
substances.
     Central  vacuuming systems exhausted through baghouses and portable
systems with filtering devices are used extensively to clean spills from
broken bags; dust accumulations around grinding, lathing, and other
machining operations; and  dust accumulations on employees'  clothes.
Procedures that eliminate  the need for sweeping considerably reduce employee
exposure to asbestos fiber and potential  for atmospheric emissions.
     The 1973-1974 survey  of the asbestos industry showed that scrubbers
were used by nearly 7 percent of the plants (but only 2 percent of the
control devices were scrubbers) and that cyclones alone were used in 4
percent of the plants (but only 2 percent of the control  devices were
cyclones used alone) .H Cyclones were being replaced rapidly by
baghouses.1!
     Current control  measures also include returning fiber collected by LEV
and baghouses to the process.  This is becoming an integrated process in the
A/C industry.  In addition, some processes have been designed or are being
designed to accept fiber filtered from underflow, thereby reducing asbestos
content of wastewater.
     In Chapter 5 of this  report, additional  and more specific information
will be provided regarding control  equipment, such as filtering devices,
scrubbers, and electrostatic precipitators.  In addition to engineering
control techniques, Chapter 5 provides information on asbestos substitutes,
including those presently  available for cement pipe and sheeting products.
3.5.5  Waste Disposal
     A/C product waste consists of broken, unusable pieces; material
captured by LEV and central  vacuum systems and subsequently captured by
baghouses; portable vacuum cleaner waste; process wastewater solids that
                                   3-41

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have been dredged from a settling pond;  and asbestos fibers remaining in
wastewater.  Waste also includes empty bags that contained asbestos fibers
and throwaway personal protectiva clothing.
     Waste disposal  procedures include loading waste onto a vehicle for
transport to a landfill that may or may not be owned by the manufacturing
company.  Waste may be transported by the manufacturer or hauling may be
contracted to another company.
     Current waste disposal  procedures minimize emissions by handling
baghouse dust in plastic bags.  Putting  empty asbestos bags into other
plastic bags directly after opening and  dumping helps to control  asbestos
emissions.  One A/C plant puts its empty asbestos bags into another large
plastic bag and then puts the whole package into the autoclave prior to
disposal.  This acts to shrink wrap the  empty asbestos bags and "lock in"
the asbestos.  It also reduces the volume of solid waste.

3.6  VINYL-ASBESTOS FLOOR TILE
3.6.1  Industry Statistics
     Vinyl asbestos (V/A) floor tiles are manufactured from filled polyvinyl
chloride polymers or copolymers and produced in squares usually 9 inches x 9
inches or 12 inches x 12 inches with thicknesses varying from  1/32 to 3/32
inch.  They are widely used because of ease of installation and maintenance,
durability, and rot resistance.  Tiles are fastened down with  asphalt-based
adhesives or a self-sticking adhesive, which is put on at the  manufacturing
facility and covered with release paper.32
     V/A floor tiles are manufactured by 7 companies at 14 sites.
Producers, production location, and employment information are listed in
Table 3-25.  Employment figures indicate that Armstrong Cork,  Kentile
Floors, and GAP are the largest V/A floor tile producers.  American Biltrite
is closing one of its facilities.
     In 1977, approximately 122 million  square yards of V/A floor tile were
produced.33  This production figure includes asphalt floor tile,  which was
not reported separately for 1977; however, in 1972 asphalt floor tile
production amounted to 9.8 million square yards.33  The value  of V/A and
asphalt floor tile shipments was about $232 million in 1977, up from about
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            TABLE 3-25.  PRODUCERS OF V/A FLOOR TILE3
  Producer and
   location
Production     Total
 workers     employees
                   Product
                    line
American Biltrite
  (Amtico Tile)
    Trenton, NJ
    Plant #1
    Plant #2

Armstrong Cork
  Company3
    South Gate, CA
    Kankakee, IL
    Jackson, MS
    Lancaster, PA

Flintkote Corporation
    Los Angeles, CA
    Chicago, IL

GAP Corporation
    Long Beach, CA
    Vails Gate, NY

Kentile Floors
    Brooklyn, NY
    Chicago, IL

Uvalde Rock Asphalt
    Houston, TX
Winburn Tile
  Manufacturing
  Company^
 190-200
   2,700
     88
     60
    117
    200
    352
    405
   N/A
    175
                  90
  250
3,600
  123
   80
  201
  470
  514
  491
 N/A
  200
Administrative offices;
  plant in process of
  phased shutdown

V/A floor tiles only
V/A floor tile and
  other products
V/A floor tiles only
V/A floor tiles only
V/A floor tiles
V/A floor tiles; small
  quantity of product
  substitutes

Ceramic-mosaic tile and
  V/A tile
a Armstrong Cork estimated 1,000 to 1,050 production employees involved in
  production of V/A floor tiles.
b Two-thirds of sales volume generated by ceramic-mosaic tile.
                                    3-43

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$208 million in 1972.   About $9 million of the total 1972 shipment value,
$208 million, was attributable to asphalt floor tile.  Bureau of Mines
information on asbestos consumption is not disaggregated sufficiently to
determine the amount of asbestos consumed in V/A floor tile.
     V/A floor tile competes with vinyl-sheet roll goods, solid vinyl floor
tile, ceramic tile, carpeting, and wood.3  information on shipment value in
constant dollars indicates a fairly stable market for V/A floor tile,
although periods of negative and positive growth have occurred.3
3.6.2  Process Description
     Information presented here on manufacturing V/A floor tile is from
a manufacturer1s product bulletin.33
     Grade 7 chrysotile is used in the manufacture of V/A floor tile.
Formul ations are:
          Asbestos:'  5 to 20%,
          Binder:  15  to 20%,
          Limestone:  53 to 73%,
          Plasticizer:  5%, and
          Stabilizer:   2%.
     Asbestos is received in polyethylene film bags, which can  be introduced
unopened into a Banbury or Baker Perkins-type mixer.  The other ingredients
are added at this step and mixing proceeds at about 150  °C (300 °F)  until  a
coherent mass is obtained.  The hot material  is transferred to  a two-roll
mill where the two heated, horizontal, rotating steel  cylinders mix  the
material further and blanket it out to desired thickness, usually 1  to 2
inches.  Chips of contrasting colors can be added at the end of the  milling
operation to create a  marblized or veined pattern as the slab is processed
further.  The slab is  passed through a series of calender rolls to bring it
to the desired finished product thickness.
     After leaving the calenders, the hot material  is partially cooled by
water spray and a wax  solution is applied.  Further cooling by  air is
necessary before dye cutting to minimize shrinkage after cutting.  Embossing
is done before cutting when the material  is soft enough  to take the  pattern.
Scrap and rejected tile are reworked and returned to the mixer  for
recovery.
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3.6.3  Emission Sources
  ,   Fiber receiving and storage, opening bags, dumping the fibers into the
mixer, mixing, and chopping waste for recycling represent potential  emission
sources in V/A floor tile production.  The potential  for fiber release is
reduced substantially once the ingredients have been  worked into a hot,
homogenized plastic mass.
     Asbestos emission sampling and analysis have not been performed for V/A
floor tile plants.  Engineering estimates of annual,  nationwide emissions
are shown in Table 3-26.  These quantities cannot be  considered precise and
are presented here for completeness.   A 1978 report^ estimated annual
emissions of 0.0207 metric ton (0.0227 short ton)  based on 1976 Bureau of
Mines asbestos consumption figures for the flooring product category.
However, this category also includes  asbestos felt under! ayment, so  the
0.0207-metric ton emission estimates  are over what the figure should be.
3.6.4  Control Techniques
     Floor tile manufacturers use LEV and routine floor cleaning to  control
asbestos.  Because the mixing and forming steps do not cause significant
asbestos fiber loss, the fiber introduction step (for opened bags)
represents the prime concern for controlling emissions.  Dust capture  hoods
are applied at bag opening, and dust  is commonly exhausted to fabric
filters.  The material-handling equipment, including  mixers, is kept under
negative pressure with exhaust air directed to a fabric filter.  Scrap
material is conveyed to an isolated or enclosed area  where automated
choppers process scrap into chips; this operation usually is exhausted
locally to a baghouse.34
3.6.5  Waste Disposal
     Trimmings and rejected tile squares are chopped  up and reused.
Therefore, only minor manufacturing scraps are disposed to landfills.14
3.6.6  Costs
     No control  or operations costs were collected during Phase I.

3.7   ASBESTOS-REINFORCED PLASTICS
3.7.1  Industry Statistics
     Asbestos-reinforced plastics are polymeric materials to which asbestos
fibers are added to modify the composite's physical and chemical
                                   3-45

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 TABLE 3-26.   ESTIMATES OF TOTAL ANNUAL EMISSIONS FROM V/A
     FLOOR TILE MANUFACTURE IN THE UNITED STATES, 19697
                                         Emission quantity
   Emissions                               (metric tons)
Uncontrolled                                    366

75J controlled                                   92

99% controlled                                    4
                            3-46

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characteristics.  These composite materials are multicomponent blends in
which the asbestos fiber is the load-carrying member and the polymeric
matrix fills the gaps between the fiber and distributes the applied stress
to the fibers.  The plastic material  provides a shape and a smooth surface
to protect the fibers and also may provide thermal  or electrical  resistance.
Asbestos fibers are used to reinforce phenolic, polyester, and epoxy resins
and in a wide range of thermoplastic  polymers.35
     Primary applications of asbestos-reinforced plastics are V/A and
asphalt floor tiles, friction materials, and gasketing,3 discussed
separately in sections specific to these product categories.  Phenolic
molding compounds are the major asbestos users in reinforced plastic
applications other than the above primary appl ications.3  In this section,
discussion is limited to phenolic molding compounds.
     Major markets for phenolic molding compounds are automotive, printing,
household appliances, and electronics.   Other markets include wiring
devices, communications, and closures.34  Producers  of asbestos phenolic
molding compounds and employment information are listed in Table  3-27.
     Data on quantity and value of product shipments for asbestos-reinforced
phenolic compounds are not compiled by  the Bureau of the Census.   Data on
asbestos consumed in plastics (other  than in flooring, gasketing, and
friction materials) are collected by  the Bureau of Mines.  Consumption of
asbestos in plastics for the years 1978 through 1980 is presented in Table
3-28.  Asbestos consumption in plastics declined 40  percent between 1978 and
1979 and 55 percent between 1979 and  1980.  The market for asbestos phenolic
molding compounds is characterized by decreased production, exit  from the
industry, and increased production and  use of substitutes.3
3.7.2  Process Description
     Chrysotile, primarily the Group  7  fibers, is used in the manufacture  of
asbestos-reinforced plastics.  Although manufacture  of asbestos-reinforced
plastics varies, the following description, summarized from a 1976 report,35
is common to most producers of asbestos-reinforced plastics.
     In the fiber-opening stage, bags of asbestos are normally opened
manually, and the contents are dumped into a storage hopper and subsequently
conveyed to the dry blending stage.  Alternatively,  asbestos may  be dumped
                                   3-47

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             TABLE 3-27.   MANUFACTURERS OF ASBESTOS-REINFORCED
                        PHENOLIC MOLDING COMPOUNDS3
  Manufacturer and
      location
Production
 workers
  Total
employees
        Product
         line
PI asl ok
    Buffalo,  NY
    Lock port, NY
   N/A
     50
Plastics Engineering
    Sheboygan,  WI

Reichhold Chemicals,
    Incorporated
    Carteret,  NJ
Resinoid
    Skokie,  IL
    LaPort,  IN
    Newark,  OH
   N/A
   N/A
   N/A
    175
    350
Asbestos phenolic
  molding compounds
  (Less than 25 percent
  of sales) and
  nonasbestos molding
  compounds
Asbestos phenolic
  molding compounds,
  plasticizers, and
  polyethylenes

Asbestos phenolic
  molding compounds
  (80 to 85 percent of
  sales), nonasbestos
  molding compounds,
  and custom molding
  items
Rogers Corporation
    Manchester,  CT
  90-95
 130-140     Asbestos  phenolic
               molding compounds,
               nonasbestos molding
               compounds,  and
               phenolic board
              TABLE 3-28.   ASBESTOS CONSUMED  IN  PRODUCTION  OF
               ASBESTOS-REINFORCED PLASTICS  (METRIC  TONS)23.36
                1980

                1979

                1978
                           1,300

                           2,900

                           4,900
                                   3-48

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directly into the blending stage without intermediate storage or handling.
During blending, dry asbestos, catalysts, and additions are mixed.  From
this step, the mixture is formed into a resin either by heat and extrusion
or by internal shearing frictions in a Banbury mixer.  The product of these
"preforming" steps is a pellet, powder, or some similar "preform," which is
either packaged and sold as an intermediate product or conveyed directly to
a type of forming process.
     Forming may include a variety of processes:   rolling, stamping,
pressing, or molding, depending on the product desired.  Following this
process, the product is cured, thus allowing thermosetting reactions to take
place.  Finally, the rough product is sent to a finishing operation, which
may involve sanding, grinding, polishing, drilling, and sawing.  The degree
of finishing is dictated by the end-product use.
     .Product scrap is not recovered for reuse because of the cost of
recovering the fibers once the resins have set up.14  scrap is landfilled;
baghouse waste may be recovered as filler.^
3.7.3  Emission Sources
     Potential emission sources include the opening and emptying of bags of
asbestos; the emptied bags, which are not suitable  to incorporate into the
mixture; the dry blending of ingredients; and resin formation.  During
forming and curing, the potential  for emissions,  although still present, is
somewhat reduced.  Other potential  emission sources include finishing of the
cured products, waste disposal, housekeeping, and baghouse exhausts.
     The only emission estimates available are based on engineering
estimates and cannot be considered precise.  Table  3-29 contains estimates
of annual asbestos emissions from the manufacture of asbestos-reinforced
plastics.
3.7.4  Control Tecnniquests
     Controls for bag opening involve use of hoods  connected to exhaust
ventilation systems and baghouses.   Some large manufacturers use limited
enclosure of their areas to better control  exhaust  air flow. 'Control
equipment in the dry blending area, resin-forming area, forming area, and
curing area includes exhaust hoods, local  process exhaust equipment, and
partial  enclosures to control  air flow and minimize asbestos dust exposure
                                   3-49

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     TABLE 3-29.   ESTIMATES OF TOTAL ANNUAL ASBESTOS EMISSIONS FROM THE
    MANUFACTURE OF ASBESTOS-REINFORCED PLASTICS IN THE UNITED STATES14
              Emissions
  Quantity
(short tons)3
   Comment
 To air:
      Baghouse emissions
 To water:
<0.1 to -0.9


   None
Free-fibers
 To landfill:
      Product  scraps
    390
Fibers coated with
  polymer matrix
a Based  on  1976  asbestos  consumption data.
                                    3-50

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in surrounding areas.  Dust is normally exhausted to baghouses.  In
finishing, hand and portable tools are normally supplied with LEVs connected
to the central ventilation/collection system.  Larger stationary machines
are supplied with local exhausts near the finishing surface and, in some
cases, are supplemented with hoods over the finishing machine.  Area or
machine partial enclosures are used to some extent where larger quantities
of dust are released.  Housekeeping and maintenance practices include
central vacuum-clean ing systems, mobile floor sweeping/vacuum ing equipment,
and manual floor/equipment cleaning.
3.7.5  Waste Disposal
     Product scrap typically is disposed of in landfills while baghouse
waste is recovered and reused in the  process.  Vacuum and other housekeeping
waste is bagged and disposed of in a  landfill.
3.7.6  Costs
     Cost information was not collected during Phase I.

3.8  ASBESTOS PAINTS, COATINGS, AND SEALANTS
     Asphalt-asbestos coatings represent the major product in this industry
segment.  Industrial, construction, and automotive industries use these
coatings to protect metals and tanks, to insulate pipes  and tanks, and  to
control sound.  They have a variety of uses as undercoatings for
automobiles, flashing cements, tile cements and roof coatings but are
primarily used for the latter.37  interviews with paint  manufacturers
indicate that asbestos-containing paints are no longer manufactured.38
3.8.1  Industry Statistics
     Statistics on asbestos coatings, sealants, and paints that include
nunber of establishments, employment, total  dollar volume, and production
are difficult to report because information available in the Census of
Manufacturers is not disaggregated sufficiently to extract specific data.
     The five manufacturers of asbestos coatings and sealants are Jim Walter
Company (Celotex), Flintkote Company, GAP Corporation, Johns-Manvil le
Company, and Koppers Company, which together number 15 establishments in
this country (see Table 3-30).  The Census of Manufacturers reports
statistics on 23 companies with shipments over $100,000  for SIC 29522 51,
                                   3-51

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       TABLE  3-30.   MANUFACTURERS OF ASBESTOS COATINGS AND SEALANTS37


           Manufactuer                           Plant locations


       Jim Walter (Celotex)                  Perth Amboy,  New Jersey
                                            Chicago,  Illinois
                                            Port Clinton, Ohio
                                            Edgewater, New Jersey
                                            Philadelphia, Pennsylvania
                                            Locklund,  Ohio
                                            Houston,  Texas
                                            Los  Angeles,  California
                                            Birmingham, Alabama

       Flintkote Company                    Chicago Heights,  Illinois
                                            E. Rutherford, New Jersey

       GAF Corporation                      S. Bound  Brook,  New  Jersey

       Johns-Manville Company               Manville,  New Jersey

       Koppers Company                      Youngstown, Ohio
                                            Wickliffe, Ohio
             TABLE 3-31.   ASBESTOS  PAINT.  COATING.  AND SEALANT
                 CONSUMPTION OF  ASBESTOS1.36,42,43,44,45,46
                                (Short  tons)
                Year                      Quantity of asbestos consumed3


                1980                             10,900

                1979                             19,500

                1978                             19,100

                1977                             20,500

                1976                             19,900/36,250b

                1975                             31,500

                1974                             37,900
a Excludes  asbestos consumption  in  roof coating  production.
b The Bureau of Mines reported two  widely  different  numbers  for  1976,

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Fibrated Asphaltic Coatings, which is largely attributable to asbestos-
containing coatings.39  Because these data are not sufficiently
disaggregated, employment data for the 15 establishments using asbestos
cannot be reported.  However, the best available estimate from a 1978 report
is 725 production workers in 90 of these pi ants.40
     Consumption of asbestos for asbestos coatings and sealants, other than
roof coatings, radically decreased in recent years (see Table 3-31).  Three
percent of asbestos consumed in this country was used to produce these
coatings.
     The 20,500 short tons of asbestos consumed in 1977 produced 51 million
gallons of coatings and sealants, assuming an asbestos content of 10
percent.37  Assuming the 1977 ratio of gallons of coatings and sealants
produced to asbestos consumed remained constant, 1980 production totals 27
million gallons.
     In 1978 asbestos fiber consumption for use in roof coatins was 1,150
short tons (1,050 metric tons),37 roughly 2 percent of the 63,800 short tons
(58,000 metric tons) of asbestos consumed in all  roofing products.41  if the
1980 roof coating share of asbestos demand remained 2 percent of the
asbestos consumed in all asbestos roofi.ng products (29,200 short tons or
26,500 metric tons), approximately 580 short tons (530 metric tons) of
asbestos was consumed in roof coatings in 1980.
     Net sales of the five producers of asbestos coatings and sealants are
given in Table 3-32, but values attributable to coatings and sealants have
not been disaggregated from total  sales for all  products other than coatings
sold.  However, of the 23 companies evaluated, the shipment value for
fibrated asphaltic roof coatings was $60.2 mil lion.39  RTI attributed this
increase from 1972 to the lack of suitable substitutes.37
3.8.2  Process Description
     Asbestos coatings and sealants usually use 10 to 12 percent asbestos.
One of the two types of coatings is made from asphalt cut back with kerosene
or mineral  spirits, and the other is made with an asphalt emulsion  and
water.48  Because of the variety of products and the number of producers,
these formulations are unlimited.   Major components are;48
                                   3-53

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        TABLE 3-32.  1978 NET SALES FOR PRODUCERS OF
               ASBESTOS COATINGS AND SEALANTS47
                   (Thousands of dollars)
     Producer                               Net sales
Flintkote Company                             730,175

GAF Corporation                             1,063,291

Johns-Manville Company                      1,648,599

Koppers Company                             1,581,876

Jim Walter (Celotex)                        1,672,344
                            3-54

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          Cutback products
               Cutback asphalt:   30 to 80%,
               Asbestos:   10 to  15%,
               Limestone  and slate  flour:   15 to 30%,  and
               Dispersant:  1%;  and
          Emulsion products
               Emulsion asphalt:  55 to 80%,
               Asbestos:   10 to  15%,
               Limestone:   5 to  15%,  and
               Dispersant:  1%.
The following is a detailed description of the process used  in  preparing
coatings and seal ants.35
     Asbestos pallets are  moved  to  a staging  area and  weighed.   The  bags are
slit manually and dumped  either  into a hopper or directly into  a fluffing
machine.  This machine breaks down  the compressed fibers  to  an  open, free
condition to enable dispersion and  encapsulation during asphalt mixing.
     Cutting the bags and  dumping the free asbestos result in fiber  release.
Fiber can also become airborne or can fall  to the floor,  causing
house-cleaning problems and contributing to overall background  level  of
asbestos exposure.
     Empty bags containing residual  asbestos  create a  disposal  problem  in
the operation.  Because several  bags  may be emptied at once, a  waste
receiver is often made available for direct disposal.  Where the bags are
laid on the floor or otherwise remain loose until  fiber introduction is
completed, free asbestos creates a  houskeeping problem in the work area.
Several  thousand emptied  asbestos bags are disposed of by a  single coating
manufacturer in a year's time.
     Typically, fluffed asbestos fiber is  transferred  to  hoppers or  directly
to a batch-mixing tank.  Fiber transfer may be pneumatic, mechanical
(conveyors), or manual. Pneumatic  transfer systems are enclosed and use
fabric  filters for exhaust air;  conveyors  generally are enclosed. Manual
transfer may be employed  for small  operations or for specialized, low-volume
requirements.
                                   3-55

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     Fluffed fiber and other dry materials are brought into contact with
asphalt (and solvents, as required)  in a batch tank and mixed until an even
dispersion is achieved.  The batch-mixing tanks normally are enclosed-to
prevent fiber dispersion.  After a short mixing time, the asbestos fiber is
bound in the asphalt.  Upon completion of mixing, the asbestos is considered
completely encapsulated in the asphalt with little chance for fiber dust
exposure.  When the batch is finished, the material  is pumped to the
packaging (containerizing) operation.
     The predominant packaging for coatings is 5 gallon pails with sealed
lids.  Special  orders are sometimes filled using drum containers.  Bulk
shipments as in tank cars are infrequent.
3.8.3  Emission Sources
     Asbestos emissions may occur during unloading and storage of
asbestos-containing bags; bag opening  and dumping fibers;  bag disposal;
fiber opening;  manual or mechanical  conveying  of fluffed fibers to either
hoppers or a batch-mixing tank;  and final  transfer of fibers into the
slurry.  Pneumatic conveyors or covered mechanical  conveyors eliminate
emission sources due to transfer of asbestos fibers.
     Based on observation and theoretical  calculations,  it is estimated that
asbestos released to the environment during manufacture  of coating and paint
compounds normally will be only that entrained with  air  emitted from bag
filters.14  it  was found that no significant scrap or water effluents are
produced and that asbestos released from bag filter  emission can  be
approximated at a maximum average of less than 1 ton  per year for the entire
coating and paint compound production  operations.14   Dust  from bag filters
is the only release in which fibers are in free-fiber form.   In other
effluents from  washing, floor spills,  and wastage of  the bitumastic product,
asbestos fibers are encapsulated in the binder.
3.8.4  Control  Techniques
     One study  revealed that hooded exhausts connected to  baghouses and
exhausted enclosed conveyors are employed in fiber introduction areas of  new
and large plants.35  some smaller plants did not have baghouses in 1976.^5
More recently,  emissions from the bag-emptying step  have been controlled  by
ventilation with dust collection in baghouses;!^ this still  appears to be
                                   3-56

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BAT.  Varying degrees of houskeeping are reported among different pi ants.•*$
Accordingly, inspection of some plants showed dust accumulations that may
contain fibers on all horizontal surfaces, while others regularly use vacuum
cleaning to control  accumulations.35
3.8.5  Waste Disposal
     Waste produced  by this operation includes empty bags that had contained
pure asbestos, waste that may have occurred because of bag breaking or
spilling, and collected dust from exhausted operations.  It was reported
that collected dust  is recycled to the feed and no scrap material  is
produced.  Therefore, the emptied bags constitute the only asbestos-
containing waste materials.   According to another report, several  thousand
emptied asbestos bags are disposed of each year by a single coating
manufacturer.35  Emissions from empty asbestos bags are controlled by
immediately placing  empty bags into containers.35
3.8.6  Costs
     The 1976 cost of implementing best occupational  exposure control
techniques, which also include use of baghouses, would be approximately
$1,610,000 without the cost  of the industrial  hygiene and medical
program.35

3.9  ASBESTOS GASKETS AND PACKINGS
3.9.1  Industry Statistics
     Gaskets and packing are used to prevent fluid leakage in applications
such as valves and pump tank sealing devices.   Asbestos is the most widely
used material for gaskets and packing because  of its resilience,  strength,
chemical inertness,  and heat resistance.35
     Primary manufacturers of compressed  asbestos gaskets and packing,
location, and product line are presented  in Table 3-33.   Manufacturers  of
beater-add gasketing paper use a paper-making process and are excluded  from
this table.  Beater-add gasketing is discussed in Subsection 3.3,  Asbestos
Paper Products.
     The Bureau of the Census includes asbestos gaskets and packing in  SIC
3293, Gaskets, Packing, and  Sealing Devices.  Bureau of Census Information
                                   3-57

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               TABLE 3-33.   PRIMARY MANUFACTURERS OF ASBESTOS
                           GASKETS AND PACKING49
Manufacturer and location
             Product 1ine
Anchor Packing3
     Manheim, Pennsylvania
Braiding and Packing Works
  of America
     Brooklyn, New York
A. W. Chesterton3
     Woburn, Massachusetts
     Winchester, Massachusetts
Cincinnati  Gasket, Packing, and
  Manufacturing Company
    'Cincinnati, Ohio
Crane Packing
     Morton Grove, Illinois
F. D. Farnum3
     Necedah, Wisconsin
Felt Products Manufacturing
  Company3
     Skokie, Illinois
Garlock, Incorporated (Colt
     Industries)
     Charlotte, North Carolina
Asbestos packing, fiberglass
packing, rubber packing, and
gaskets
Asbestos packing, flax, and substitute
packing (including metallic, teflon,
graphite, rubber, and vegetable fiber)
Asbestos gaskets; teflon, fiberglass,
and ceramic gaskets; asbestos packing;
teflon, fiberglass, ceramic, and
extruded plastic; and graphite
packing
Asbestos gaskets, rubber and metallic
gaskets, heat shields, and
distributors for Corning glass and
Garlock packing
Asbestos packing, graphite and teflon
yarns, mechanical seals, and die-
cutters of gasketing
Asbestos gaskets, synthetic rubber
gaskets, and beater-add gasketing
Asbestos gaskets, tefl.on and steel
gaskets, asbestos sheet packing,
fibrous sheet packing, cork packing,
and chemicals
Asbestos gaskets and plastic, rubber,
and metallic gaskets
3Phasing out asbetos manufacture.
               (Continued)
                                   3-58

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              TABLE 3-33.  PRIMARY MANUFACTURERS OF ASBESTOS
                     GASKETS AND PACKING^ (Continued)
Manufacturer and location
             Product 1ine
Greene, Tweed, and Company3
     North Wales, Pennsylvania
Jamak, Incorporated3
     Weatherford,  Texas

Johns-Manville
     Manville, New Jersey
     Waukegan, Illinois
Lament Metal  Gasket
  Company, Incorporated
     Houston, Texas
     New Orleans,  Louisiana

McCord Corporation
     Wyandotte,  Michigan

Nicolet
     Ambler,  Pennsylvania
Parker Seal
  (Parker-Hannefin  Corporation)
     North Brunswick,  New Jersey
Raybestos-Manhattan
Richardson Company
  (Hercules Division)
     Alden, New York
Asbestos gaskets; vegetable fiber
gaskets; and asbestos, teflon, and
nylon packing
Asbestos gaskets and rubber gaskets
Asbestos gaskets, rubber and
vegetable fiber gaskets, and asbestos
and nonasbestos packing
Asbestos gaskets and metallic gaskets
Asbestos gaskets and metallic gaskets
Asbestos gaskets, rubber gaskets,
millboard and roll board, and A/C
sheets
Asbestos gaskets and metallic and
semimetallic stainless steel  gaskets

Asbestos and nonasbestos gaskets and
packing, friction materials, rivets
and related products, and other
products
Asbestos packing and teflon,
graphite, and carbon packing
aPhasing  out  asbestos manufacture.
                                                     (Continued)
                                   3-59

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               TABLE 3-33.   PRIMARY  MANUFACTURERS OF ASBESTOS
                     GASKETS AND PACKING^  (Continued)
Manufacturer and location
             Product 1ine
Sepco
     Birmingham, Alabama
     Atlanta, Georgia

STANDCO Rubber and Sterling
  Gasket Company
     Houston, Texas
Tannetics, Incorporated
  Mel rath Gasket Company
     Philadelphia, Pennsylvania
Fitzgerald Gasket
     Torrington, Connecticut
Utex Industries
     Wiemar, Texas
Asbestos and nonasbestos gaskets and
packing
Asbestos gaskets, rubber and teflon
gaskets, and asbestos packing
Asbestos gaskets and metallic,
rubber, teflon, and stainless steel
gaskets
Asbestos gaskets and  steel, cork,
cork and rubber, rubber, and metallic
gaskets
Rubber compounds, asbestos gaskets,
rubber and fiber gaskets, and
asbestos packing
a Phasing out asbestos manufacture.
                                  3-60

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 is  not disaggregated sufficiently to determine employment  in  asbestos  gasket
 and packing manufacturers.  However, a 1976 study35 reported  6,100
 employees, while a 1978 study40 reported 1,100 workers exposed to asbestos
 in  the packing and gaskets industry.
      Value of shipments for compressed asbestos gaskets was $58.4
 million in 1977 and $24.5 million 1972.33  Asbestos gasketing cloth had  a
 shipment value of $7.5 million in 1977 and $2.4 million in 1972.33
 Information on asbestos packings was not disaggregated sufficiently to
 determine shipment values.
      Asbestos consumption for packing and gaskets declined from 1978 to
 1980, according to Bureau of Mines data.  Table 3-34 presents asbestos
 consumption figures for the period from 1978 to 1980.  Grades 3, 4, 5, and 7
 are used predominantly in manufacturing gaskets and packing.*
      For the year 2000, the Bureau of Mines shows a low forecast for
 asbestos gaskets and packing of zero metric tons, a high forecast of 30,000
•metric tons, and a probable forecast of 25,000 metric tons.2  Apparently,
 consumer tastes are shifting away from asbestos-containing gasket material
 and toward substitute gasketing products.49  Demand for asbestos gaskets and
 packing probably will decline as demand for substitutes increases.4^
 3.9.2  Process Description35
      Generally, production of asbestos gaskets begins with manual  opening
 and dumping of bags containing asbestos into a mixing tank or a conveyor
 leading to the mixer..  In some cases, compressed raw asbestos is dumped into
 a fluffer for fiber opening before the mixing step.  Fillers and bonding
 materials also are added to the mixer and blended.  Mixing may be in a dry
 or  wet state, according to product requirements, and multiple production
 lines may be employed.   The formulation from the mixer is calender-rolled
 into  sheeting, which may be packaged and sold to secondary manufacturers
 (such as gasket cutters) for further processing.  Sheeting also could be
 sold to distributors serving the maintenance market.
      Asbestos-based packing can be manufactured by a number of processes,
 the most common being to impregnate dry yarn with lubricants that coat the
 fibers.  These yarns are braided into a continuous length of packing and
 then are calendered to  specific sizes and cross-sectional  shapes.  The sized
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       TABLE 3-34.   ASBESTOS CONSUMED IN THE PRODUCTION OF
                     GASKETS AND PACKING1.36
                          (Metric tons)
           1978                                  31,100

           1979                                  19,200

           1980                                  12,300
TABLE 3-35.   ESTIMATES OF TOTAL ANNUAL ASBESTOS EMISSIONS FROM THE
 MANUFACTURE OF ASBESTOS GASKETS AND PACKING IN THE UNITED STATES
 Emissions                             Quantity
   to air              Year          (metric tons)          Reference
From process             1974              13                   19

From disposal             1974              13                   19

From baghouses           1976            <0.09                  14
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braid may be coiled, boxed, and sold to the maintenance trade, or it may be
cut and die-formed to the manufacturer's specifications.  A variation of
braided packing can be produced by first extruding  a mixture of asbestos
fiber, binder, and lubricants, and then braiding  lubricated asbestos yarns
over extrusion.
3.9.3  Emission Sources
     The primary potential  emission sources are from the bag opening and
dumping of asbestos and from the mixing step.   Receiving and warehousing of
raw fibers, disposal of emptied bags and product  scrap, and braiding and
twisting of treated asbestos yarn also can  be  considered potential  emissions
sources.
     The only available estimates of asbestos  emissions are engineering
calculations and cannot be considered precise.  Table 3-35 shows  such
estimates of annual release of asbestos from the  manufacture of gaskets and
packing.
3.9.4  Control Techniques
     Fiber release is controlled by use of  hoods  and LEV;34,35 dust is
typically collected by baghouses.^  Where  mixing is accomplished with a
wetted compound, fiber evolution is low.34
3.9.5  Uaste Disposal
     Since product scrap cannot be reused,  it  is  disposed of in landfills.
Based on 1974 asbestos consumption data, it has been estimated that 653
metric tons (718 short tons) of asbestos is disposed of to land from the
manufacture of gaskets and packing.19
3.9.6  Costs
     Information on control and operation costs was not compiled  in Phase I.

3.10  ASBESTOS TEXTILES
3.10.1  Industry Statistics
     Asbestos fibers may be worked into a textile form to provide an
incombustible material that retains its physical  properties at high
temperatures.  Asbestos textiles are manufactured in several different forms
and have various uses, including:
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          Lap:   used  as  insulation  for electrical  conductors;
          Roving:   used  as  insulation  for heater cords,  twisted  to  form yarn;
          Yarn:  woven  into textiles;
          Cord:  used for seals,  packings,  and  insulation;
          Woth:   used  for  curtains, blankets,  and safety clothing;
          Tubing:   used  for sleeving for electrical  conductors;
          Wick:  used as packing  and seal ings;
          Tape:  used for electrical insul ation.50
Four asbestos textile manufacturers are located in the United  States.   Their
location, employment, and product lines are presented in Table 3-36.
     Total  shipment value of asbestos  textiles  was $50.3 million in  1977  and
$37.2 million in 1972.33 Asbestos consumption  by  textiles  for 1978  through
1980 is given in Table 3-37.   Consumption by textiles for this period  has been
about 1 percent  or less  of  total  asbestos consumption.   From 1969 to 1974,
annual  asbestos  consumption for textiles ranged from 13,000 metric tons
(14,300 ,short tons) to 18,000 metric tons (19,800  short  tons).2  This
apparent decline in demand  for asbestos textiles is  due  in  part  to available
substitutes.51   Bureau of Mines forecasts for the  year 2000 a  U.S. asbestos
demand in textiles of from  0  to 10,000 metric tons (11,000  short tons),
with a probable  forecast of zero  tons  consumed.2
3.10.2  Process  Description
     Asbestos textiles are  manufactured from chrysotile  asbestos, primarily of
the long, Group  3  fibers.  The product is typically  comprised  of 75 to  100
percent asbestos,  and organic fibers comprise 0 to 25 percent  of the
product.^0  Textiles also^nay be  reinforced with wire or synthetic yarns,
depending upon end use.
     A majority  of asbestos textile production  is  by conventional process,
while 5 to 10 percent of U.S.  asbestos textile  production is by  wet
extrusion.*4 The  conventional process can  be subdivided into  dry-woven and
damp processes,  the difference being the application of  moisture to the yarn
by contact with  a  wet roller or a mist spray.   Unless noted otherwise,  the
following descriptions of conventional  and  wet  processes were  adapted  from
Daly.35
                                  3-64

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               TABLE 3-36.   MANUFACTURERS OF ASBESTOS TEXTILES^
    Manufacturer and
        location
Production      Total
 workers      employees
                 Product
                  line
Amatex Corporation'3
    Meredith, NH

    Norristown, PA
Johns-Manville
    Manville, NJ
Raybestos-Manhattan
    Marshville, NC
    North Charleston,  SC
Southern Textiles Company
    Charlotte, NC
   110

   N/A



 1,550
   160
   425
   265
  125

  100



2,000
  190
  725
  320
Abestos textiles and
substitute textiles
Asbestos textiles and
fiberglass textiles
Asbestos textiles,
mechanical packing,
and felt saturation
Asbestos textiles only,
asbestos textiles, and
pyroglass textiles
Asbestos textiles
fiberglass textiles
Information was taken from Reference 51  and  contacts  with.pi ant  and
 corporate personnel.
"Amatex Corporation is phasing out  asbestos textile production.
           TABLE 3-37.   ASBESTOS CONSUMED  IN TEXTILE  PRODUCTION IN  THE
                  UNITED STATES, 1978  to 1980  (Metric tons)1.2
                         1980

                         1979

                         1978
                      1,900

                      5,800

                      2,900
                                   3-65

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     In the conventional  process, raw asbestos and other ingredients are
weighed and dumped into several  blending machines, which operate continuously
to mix the formulation components gently.  Mixing takes place as the asbestos
slowly moves toward the rear of the machine, is drawn up an incline, and
tumbles to the bottom.  Part of the mix is carried over the incline and falls
into a hopper.  The rear of the blending machine is enclosed and hooded to
minimize fiber evolution.  As the hoppers are filled with the blended fibers,
the fibers are transferred to the carding machines or may be conveyed
pneumatically to the carding machines.
     The carding operation combs the fiber mix into a parallel  (oriented)
fiber mat, which is pressed mechanically and layered into a lap.  At the
finishing card, the lap is separated into thin, continuous strips of fiber
known as roving.  At this point, cotton, rayon, or other materials may be
added to the roving to impart strength and other characteristics.  The lap,
matting, or roving may be packaged and sold to secondary industries.
Otherwise, the roving proceeds to the spinning operations.
     The roving is spun and twisted a specified number of turns per inch to
give it strength.  In the damp process, the roving is moistened via wet
rollers before spinning.   This dampening process is employed to reduce fibrous
dust during subsequent processing.  In some cases, for better product quality.
the roving is not wetted.
     Spun roving, known as single yarn, can be twisted with other single yarn
or other material to produce plied yarns.  Plied yarns can be coated to
produce thread or treated yarns, or woven to produce tapes, cloth, or woven
tubing.  It also can be braided to produce cord, rope or braided.tubing.  Spun
yarn can be processed without twisting to produce woven, braided,  and
otherwise treated products.
     At the weaving operations, the yarn is first put on a beam or creel,
which handles a large number of strands to feed a loom.  A damp or dry loom
can be used to create cloths of different characteristics.
     The wet process differs from the conventional  processes in that raw
asbestos is dumped directly into a slurrying tank with water and chemicals.
The resulting slurry is extruded directly into strands.  These  strands proceed
to the spinning and subsequent operations similar to conventional  processing.
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The wet process thus avoids the blending, and carding operations, which
generate substantial amounts of asbestos dust in the conventional process.
Wet-processed textiles possess different characteristics than do
conventionally woven products; therefore, secondary manufacturers must adapt
production techniques to compensate for altered processability and
final-product characteristics.
3.10.3  Emission Sources
     Fiber release may occur during asbestos receiving and storage as a result
of damaged bags.  In the conventional  textile process, greatest potential  for
fiber release generally is associated with bag opening and dumping (commonly
done manually), blending, transporting blended fibers, and carding.   The
high-speed working of yarn in spinning, twisting,  and weaving also will
release asbestos fibers.  Inspection and shipping  areas also may be considered
potential  emission sources; however, potential  is  normally low at this stage
of the process.
     In the wet process, potential  for fiber release is greatly decreased
because blending and carding operations have been  eliminated.  However,  bag
opening and dumping may release asbestos fibers.  Spinning, twisting, weaving,
and braiding in the wet process release fewer fibers than the same operations
in the conventional  process do.35
     Emission data have been collected for one conventional asbestos textile
plant.11  Air was sampled as it went into the baghouse and as it was
exhausted, and samples were analyzed by optical  and electron microscopy.
Results are given in Table 3-38.  Engineering estimates of annual  emissions to
air from U.S. asbestos textile manufacturing range from less than 0.18 metric
ton (0.20 short ton)14 to 3 metric  tons (33 short  tons).19  One study using
1974 asbestos consumption figures estimates that 9 metric tons (9.9  short
tons) of asbestos is emitted annually into the atmosphere as a result of
asbestos textile waste disposal.19
3.10.4  Control Techniques
     Methods used for controlling fiber emissions  in receiving and storage
include repairing or enclosing in plastic all  damaged bags and prompt
vacuuming  of spills.  In fiber introduction, a semi enclosed manual
bag-opening station kept under negative pressure often is used.  Blending
                                   3-67

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CO
I

00
                             TABLE 3-38.  TOTAL FIBER COUNTS AND FIBER REMOVAL  EFFICIENCIES

                                          FOR AN ASBESTOS TEXTILE MANUFACTURER11
Optical microscope,
500X
Plant
location
Marshville,
North Carolina

Sample
location
Upstream
Downstream
Downstream
Total
fibers
8.07 x 108
1.42 x 104
•.•»••••
Efficiency
(%)
>99.99
— — — _
Electron microscope,
16.364X
Total
fibers
2.45 x 1011
3.28 x 109
- 5.04 x 109
Efficiency
(*)
98.69
97.94

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machines normally are partially enclosed and under negative pressure.  Blended
fiber may be loosely bagged by a bagging machine, placed in carts, and
manually pushed to the carding machines, where the bags are opened and dumped.
Another method pneumatically conveys the blended fibers from the blending
machine to a reserve hopper, which is under negative pressure, supplying the
carding machine.  Carding machines are enclosed and under negative pressure.
Spinning and twisting require constant worker attention and cannot be
contained easily.  Reducing spindle speeds and work practices is the major
means of controlling fiber release.  Emissions from winding operations are
effectively controlled, in one instance, by enclosing and exhausting the
operation and leaving the front open for worker access.52  Clear, heavy
plastic strips suspended vertically in the opening allow operator access and
visibility while a high air velocity, low air volume system is maintained.52
Yarn wetting also is used to control  emissions, and a resin may be applied to
"lock in" asbestos fibers in the woven fabric.  Packaging in stretch-wrapped
plastic, shrink-wrapped plastic, and plastic bags has helped eliminate fiber
release in the shipping area.52  Dust from all capture devices and enclosures
is exhausted to baghouses, which are open-pressure and closed-suction types.
Housekeeping commonly consists of using portable and central  vacuum systems.
Control methods currently in use in the textile industry appear to represent
BAT.
3.10.5  Waste Disposal
     Baghouse waste may be reused, collected,  and sold to other asbestos
industry segments, or bagged and placed in landfills.  Emptied bags and
vacuum-cleaning waste are bagged for disposal.   Waste disposal  either is
contracted out or landfilled on plant-owned property.
3.10.6  Costs
     Cost information was not collected during Phase I.
3.11  CHLORINE MANUFACTURING
3.11.1  Industry Statistics
     Of the chlorine produced in this country,  70 percent is produced by
diaphragm cells, and an approximate total  of 0.7 to 1.2 pounds of asbestos is
consumed per ton of chlorine produced.14,53  jn 1976, chlorine production was
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10 million  tons;54 therefore,  asbestos consumption during  electrolysis was
2,500 to  4,200  tons.
     Of 68  chlorine plants  in  the United States,  38 produce chlorine by the
diaphragm cell  process.   The manufacturer and  location  of  each plant are
listed in Table 3-39.
3.11.2  Process Description
     A special  grade  of  asbestos  is used as a  diaphragm in the percolating
diaphragm method of chlorine production via brine electrolysis.   In the
electrolytic  process,  cathode  surfaces generally  are lined with  a layer of
asbestos, either in the  form of paper or as vacuum-deposited fibers.  The
asbestos  diaphragm maintains the  caustic strength and minimizes  the
diffusional migration  of hydroxyl  ions.  All diaphragms gradually clog with
residual  impurities not  removed from the brine and  with graphite particles
that break  from the anode.   The diaphragms  therefore are renewed at regular
intervals,  on the order  of  100 days or slightly longer.  Depending on  the
number of cells per plant,  only a few cells are renewed  each week; 1 plant
with 86 operating cells  renewed an average  of  3 cells per  week.56  Asbestos
paper sheets  were used extensively in diaphragm cells through the 1930s and
1940s but have  been replaced,  by  almost all  commercial  diaphragm cells, with
an asbestos slurry.57
     The  slurry, made  by mixing approximately  130 pounds of  asbestos fibers
with water, is  vacuum  deposited through a perforated  plate onto  the cathode
pole.  HAPP (Hooker asbestos plus polymer)  diaphragms are  basically the same
but contain a fl uoropolymer resin to help diaphragm  bonding  while reducing
voltage load.  Use of  paper sheets as diaphragms  has diminished  because the
voltage load  is significantly  higher for paper, as opposed to  the
vacuum-deposited diaphragm. A long-fiber,  high-quality  paper is still  being
produced  and  is available to customers who  operate aged  electrolytic
equipment,  as well as  the newer processes.   It  has been  suggested that  the
asbestos  paper  can be  blended  with water to form  a slurry  and  vacuum deposited
onto the  cathode, thereby eliminating potential hazard  associated with
handling  bags of asbestos fibers.^7
                                   3-70

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            TABLE 3-39.   CHLORINE PRODUCERS WITH  DIAPHRAGM CELLS55
       Producer
      Location
BASF Wyandotte Corporation

Brunswick Chemical  Company
Champion International

Diamond Shamrock Corporation

Dow Chemical  USA
E. I.  duPont de Nemours and  Company,
  Incorporated
Fort Howard Paper Company
FMC Corporation
General  Electric Company
Georgia Pacific Corporation
Hercules, Incorporated
Hooker Chemicals and Plastics  Corporation
ICI Americas, Incorporated
Kaiser Aluminum and Chemical  Corporation
Linden Chemicals and Plastics Corporation
01 in Corporation
Penwalt Corporation

PPG Industries, Incorporated

Shell  Chemical  Company
Stauffer Chemical  Company of  Nevada
Vulcan Materials Company

Weyerhaeuser Company
Geismer. Louisiana
Wyandotte, Michigan
Brunswick, Georgia
Canton, North Carolina
Houston, Texas
Deer Park, Texas
La Porte, Texas
:reeport City. Texas
Mttsburg, California
'laquemine, Louisiana
Midland, Michigan
Corpus Christi, Texas

Green Bay, Wisconsin
South Charleston, West Virginia
Mt. Vernon, Indiana
Plaquemine, Louisiana
Hopewell, Virginia
Niagara Falls, New York
Tacoma, Washington
Taft, Louisiana
Montague, Michigan
Baton Rouge, Louisiana
Gramercy, Louisiana
Syracuse, New York
Mclntosh, Al abama
Portland. Oregon
Tacoma, Washington
Wyandotte, Michigan
Barberton, Ohio
New Martinsville, West Virginia
Lake Charles, Louisiana
Deer Park, Texas
Henderdon, Nevada
Denver City, Texas
Wichita, Kansas
Geismer, Louisiana
Longview, Washington
                                     3-71

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3.11.3  Emission Sources
     Potential  for asbestos emissions is greatest for receiving and storage,
bag opening,  dumping into the mixer, cell  removal, and waste disposal.
Emission data for these operations are not available.
3.11.4  Control  Techniques
     Emission control  equipment for receiving,  storage, bag opening, and
dumping is the same as in other asbestos manufacturing processes.   Therefore,
work practice control  for receiving and storage with procedures, such as wet
sweeping or vacuuming  for spills,  is the most common.  For bag  opening, the
control method is use  of LEV and immediate containment of empty bags.  One
particular plant uses  a clean room kept under negative pressure in which bags
are opened.56  jne exhaust is vented through a  high-efficiency  particulate air
(HEPA) filter that is  replaced annually.  Fiber emissions from  the filter were
found to be less than  0.01 fiber per field" or less than 669.5 fibers per
membrane filter.  Optical microscopy was used and since volume  was not
specified, a  concentration could not be calculated.
     Other work practices included immediate disposal  of empty  bags into a
metal drum and wet removal of the  asbestos diaphragm.  Old  HEPA filters also
are placed in drums prior to disposal.
     Another  control measure currently available to  chlorine producers is to
change from an asbestos diaphragm  to a new ion-selective membrane  filter.
These new membranes permit production of a higher concentrate of caustic with
lower energy  consumption and are likely to be used increasingly in the
future.58
3.11.5  Waste Disposal
     Disposal of empty asbestos-containing bags, fines collected by dust
collectors, and worn-out diaphragms is in  accordance with EPA and  Occupational
Safety and Health Administration (OSHA) regulations.   One of the chlorine
producers seals metal  drums containing emptied  bags  and filters and contracts
for solid waste disposal.56  Wash  water containing spent asbestos  from the
diaphragms is mixed with the wastewater of a nearby  company, which treats and
disposes of the waste.
                                     3-72

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3.12  ASBESTOS INSULATION
     Asbestos may be an ingredient in materials used for thermal insulation,
acoustical insulation, and fireproofing.  Asbestos-containing products used as
insulation include asbestos millboard and rollboard, asbestos commercial
papers, asbestos cements, asbestos blankets, asbestos coatings and sealants,
and sprayed asbestos insulation.  Asbestos products that perform the function
of thermal insulation include asbestos millboard and rollboard, asbestos
commercial papers, asbestos cements, and asbestos blankets.59  Asbestos
millboard, rollboard, and commercial papers, which are paper products, are
discussed in Subsection 3.3 and will not be discussed further here.
Insulating cements were used where insulation that could be troweled was
required.  Similar to asbestos-containing joint cements and patching
compounds, these products have been replaced on the market with asbestos-free
products, such as calcium silicate or diatomite.59  Asbestos blankets are
manufactured by the asbestos textiles industry, which is discussed in
Subsection 3.10, and are not considered further here.  Asphalt and tar-based
coatings and sealants to which asbestos is added may be considered to have
insulating properties.  For example, asbestos-containing automobile
undercoatings have acoustical  insulating properties and insulate against
corrosion.  Asbestos coatings and sealants also may be applied to structural
steel  for fire-proofing.37  Asbestos coatings and sealants are discussed  in
Subsection 3.8.

3.13  SHOTGUN SHELLS
3.13.1  Industry Statistics
     Asbestos may be used to manufacture base wads for shotgun shells.
Currently, only one plant, Remington Arms Company in Bridgeport, Connecticut,
manufactures asbestos-containing shotgun shell  wads and only about 5 percent
of its shells contain asbestos.  This small  amount was to be eliminated during
1981.60  Remington Arms Company in Lonoke, Arkansas, also fabricates shotgun
shells using the asbestos-containing wad made in Connecticut.  In 1974,
Remington used approximately 454 metric tons (500 short tons) of asbestos  to
manufacture shotgun shells.6*   Given the availability of substitutes for
asbestos wads, disappearance of this market is imminent.60
                                     3-73

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3.13.2  Process Description
     Asbestos is mixed with wood flour and wax and  pressed  into base wads.2
The mixture's formulation, by weight,  is:61
          Asbestos:     36 percent,
          Wood flour:  54 percent, and
          Wax:         10 percent.
3.13.3  Emission Sources
     Emission sources likely in the manufacture of  asbestos-containing shotgun
shells include receiving and warehousing  of asbestos,  opening and dumping of
asbestos, mixing, wad pressing, and subsequent handling  and  processing.
Baghouse operations, including exhausts,  are sources of  fiber release
into the environment.62  Based on high baghouse efficiency,  emissions from
baghouse exhausts are very small.62
3.13.4  Control  Techniques
     Dust from emission points is exhausted to particulate control  devices.
In 1974, these included mechanical  collectors and spray  scrubbers.61  In  a
1978 report,  the authors, in estimating emissions,  indicate  that Remington has
employed a baghouse  to control emissions.62  The switch  to substitutes
ultimately will  eliminate asbestos emissions from its  facility.
3.13.5  Waste Disposal
     Asbestos-containing waste from shotgun shell manufacturing is  minor.
Baghouse collections are recyclable and product scrap  wastes are minor.3
3.13.6  Costs
     Cost information was not collected during Phase I.

3.14  ASPHALT CONCRETE
3.14.1  Industry Statistics
     Asbestos is added to asphalt to give it greater strength and longer  life
and is used as a thin topping layer on some airport roadways, bridges, and
street curbing.61 As of 1974, an estimated 5,000 asphalt concrete  plants were
located in the United States, about 50 of which used asbestos each  year,  and
4,100 metric  tons (4,500 short tons) of asbestos were  used.61  By 1978,
asbestos use  in asphalt concrete was less than 91 metric tons (100  short  tons)
per year as a result of environmental  restrictions  and concerns over health
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effects and Government regulations,64 most likely EPA and OSHA regulations.
Current asbestos use in asphalt concrete is negligible and its continued use
is unlikely.63  The National  Asphalt Pavement Association was not aware of any
asphalt concrete plant that uses asbestos.6^
3.14.2  Process Description
     In the manufacturing process, bags of asbestos are opened manually and
dumped into a conveyor system or are introduced opened into the mixer.   The
asbestos is mixed first with  dried aggregate, after which hot liquid asphalt
is added to the asbestos-containing aggregate and thoroughly mixed.6!
3.14.3  Emission Sources
     Emissions can occur during manual  bag opening, emptying of asbestos into
the conveyor hopper, and dry  mixing.  Empty bags, if not incorporated into the
mixture or properly contained, can be points of fiber release.  Considering
only negligible amounts of asbestos currently are used, emissions are probably
small.  Once bound into the asphalt concrete product, asbestos emissions are
not considered significant.61
3.14.4  Control Techniques
     The common method of introducing fiber into the process consists of
dumping the unopened plastic  bags of asbestos directly into the mixer.61  This
procedure alleviates emission problems  associated with manual  opening and
dumping and conveying loose fibers.  No information was found on current use
of collection devices by asbestos-asphalt plants.  In 1974, it was thought
that most of these plants would install small fabric filtering devices  and a
few would install venturi scrubbers to  control  asbestos emissions.61
3.14.5  Waste Disposal
     Considering the small quantities of asbestos probably used in asphalt
concrete, the amount of asbestos containing waste probably is also small.  In
product scraps asbestos fibers are encapsulated by the asphalt mixture  and
cannot become airborne.64
3.14.6  Costs
     During Phase I, no cost  information was collected for asphalt concrete
production.
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3.15  FABRICATING
3.15.1  Industry Statistics
     Fabricators, or secondary processors, refer to firms that purchase
products from primary manufacturers and either fabricate these materials
(e.g., cutting and drilling of cement sheets)  or process them together with
other materials for incorporation into an end  product (e.g.,  use of reinforced
plastics in electrical  generators).  Field fabrication is discussed in Chapter
4 as part of construction.  It is not always  possible to isolate a secondary
industry in a strict sense because primary producers often purchase from each
other.  For example, manufacturers of friction materials may  purchase from
asbestos textile manufacturers.  Furthermore,  primary producers often perform
operations to their own products that could be considered secondary processing
or fabricating.  For example,  a producer of asbestos flooring felt may also
apply the polyvinyl  chloride coating and print or emboss a pattern in the
coating.
     The secondary industries  can be defined by the primary segment of the
asbestos manufacturing industry that services  them, as follows:-^
          A/C products;
          Asbestos friction materials;
          V/A floor tile;
          Asbestos-reinforced  plastics;
          Asbestos paper products;
          Asbestos paints, coatings, and sealants;
          Asbestos gaskets, seals, and packing materials;  and
          Asbestos textiles.
     Each of these secondary industry segments will  be described  here briefly.
Unless noted otherwise, information on secondary industries is from a 1978
OSHA study.66
     3.15.1.1  A/C Products.  The secondary market  for A/C pipe is limited.
Most of the product is manufactured and finished for direct end use in the
construction industry.   A/C sheets have both construction and industrial
application.  Cement shingles  are used in residential  construction areas,
while corrugated sheets are usually precut and fabricated  at  the  primary
plants for various construction activities.  The cooling tower industry is a
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major end user of flat A/C sheets usually fabricated at the primary industries
on a special-order basis.  Industrial applications for A/C sheets include
table tops for schools and laboratories, hoods and vents for corrosive
chemicals, small appliance components, electrical switchboard components, and
other uses where the strength and heat-chemical-resistant nature of asbestos
cement is required.  Most of these applications are serviced by small  cement
board fabricators located throughout the country who do job shop work for
specific orders.  Approximately 50 such firms are located throughout the
country, typically employing 20 to 25 persons per plant.  Additional  users of
A/C sheets, such as furniture manufacturers and large electrical  firms,
fabricate sheets for their own use.
     Based on sales data from primary industries, it is estimated that
approximately 25 percent of the A/C sheets go through the secondary
fabricators.
     3.15.1.2  Asbestos Friction Materials.  Secondary fabricators of friction
material products are primarily in the automotive aftermarket with additional
markets in some industrial  applications.
     The automotive aftermarket consists of three sectors:
          Firms that rebuild or reface friction components  for brakes,
          clutches, and transmissions;
          Firms that repackage friction materials; and
          General  service and brake  repair.
Approximately 1,150 firms are associated with refacing and  rebuilding  friction
materials.  For the most part, these are small, one-plant operations;  however,
some larger corporations also have such plants (i.e.,  Bendix).   The major
distinction between these operations and similar operations in  the primary
segments manufacturing friction materials is that because these  plants do not
handle raw asbestos fiber,  their asbestos control  problems  are  somewhat
different.
     Compared to the other  sectors,  the repacking sector is small  with an
estimated 100 small  operations throughout the United  States.
     The general  service and  brake repair sector of the automotive after-
market is very large and involves a  number of subsectors.   Estimated
establishments involved are as follows:
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          Repair shops                        110,000
          Dealerships                          32,900
          Tire/battery/accessories             29,200
          Department store repair shops          5,800
          Service stations                    190,000
            Total                             367,900
     3.15.1.3  V/A Tile.  V/A floor tile is manufactured by the primary
industries and is cut and shipped directly to  either the construction industry
or the end user.  There is no secondary  fabricator for this product.
     3.15.1.4  Asbestos-Reinforced Plastics.  Primary industry segments
manufacture molding compounds, mainly phenolic molding compounds,  and sell
this granulated material to a myriad of  secondary  molding fabricators.   Major
segments of this secondary industry include appliances such as household
appliances, utensils, and tools;  various automobile applications in the
ignition, transmission, and wiring system;  the wiring device industry;
electrical  switch gear manufacturers; makers of closures such as bottle and
jar caps; and the communications  and electronics industry.   It is  extremely
difficult to determine the entire scope  of the secondary market for asbestos-
reinforced plastics.  Industry estimates some  3,000 secondary fabricators of
reinforced plastics and perhaps 5,000 separate product end  users.  However,
the percentage of these plastic fabricators that use  asbestos-reinforced
plastics or other materials cannot be determined.   Some of  the primary
industries fabricate their own plastic products, but, for the most part,
asbestos-reinforced plastics go through  secondary  processes.
     Based on the sales percentage of the primary  industry  to secondary
fabricators, it is estimated that approximately 70  percent  of asbestos-
reinforced plastics go through secondary fabricators.  An estimated 5,700
people are employed in the secondary processing of asbestos-reinforced
plastics.67
     3.15.1.5  Asbestos Paper Products.   Asbestos  paper is  used in areas such
as roofing, gaskets (commonly called beater-add gaskets), thermal  and
electrical  insulation material, and underlaying for sheet flooring.   Many
primary manufacturers of asbestos paper  also fabricate and  finish  the product
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for sale to the end user.  Specifically, manufacturers of asbestos roofing
felt have their own saturating plants, which in turn sell  the roofing product
directly to the construction industry.  Individual  establishments acting as
secondary fabricators of asbestos roofing products  are minimal.   A significant
portion of asbestos paper goes directly into the secondary fabricators for
gasketing material.  Other paper is sold to manufacturers  of cooling towers
where the paper is saturated,  cut,  and .fabricated as a sandwich  filler for
some applications.
     Based on sales data from  primary manufacturers, an estimated 60 percent
of asbestos paper goes through some form of secondary fabrication before
reaching the construction industry  or other end users.  An estimated 6,300
people are employed in secondary fabrication of asbestos paper products.67
     3.15.1.6  Asbestos Paints, Coatings, and Sealants.  These products
manufactured by the primary industries have no secondary fabricator market.
Their end-use applications involve  the construction industry,  home remodeling
markets, and automotive undercoatings.
     3.15.1.7  Asbestos Gaskets, Seals, and Packing Materials.  During these
secondary fabricating steps, packing of gasket materials may be  impregnated
with polymers, latex, or other chemicals to impart  certain properties to the
material.  These secondary fabricators cut, slit, or punch the material  to
specific shapes for end users.  Where strength and  pressure sensitivity  is not
critical, gasket cutters use asbestos paper from the paper segment of the
primary asbestos industry.  Finally, asbestos yarns made by primary asbestos
textile mills are sold to secondary fabricators to  be used as  packing material
for pumps and other applications that require this  high-strength material.  In
some instances, primary textile operations will  manufacture their own packing
material  and sell  it directly  to end-user industries.
     Based on sales data from  primary industries, approximately  95 percent of
packing and gasket material  are estimated to go through secondary fabricating
firms.   An estimated 6,300 people are employed in this segment.67
     3.15.1.8  Asbestos Textiles.  The wide range of asbestos  textiles has a
correspondingly wide range of  secondary markets. Asbestos cloth is used in
welding curtains and screens,  safety garments, protective  clothing, and
reinforced plastic laminates.   Asbestos yarn is used as filler in the wire
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and cable industry, as the main ingredient in braided packings, and is woven
in the process of making certain types of felts.
     With some large textile companies, fabricating certain products may occur
within the primary textile industries.  However, for the most part, asbestos
textiles go through secondary fabricating steps prior to end use.  For this
reason and based on sales data, it is  estimated that approximately 90 percent
of the asbestos textiles manufactured  by the primary segment go through
secondary processing.  An estimated 3,200 people are employed by secondary
processors of textiles.6?
3.15.2  Process Description
     In general, operations involved in secondary fabrication are similar to
finishing operations of the primary manufacturing segments.  They may use such
operations as grinding, sawing, sanding, punching,  pressing, or slitting,
depending on the fabricated product desired.
3.15.3  Emission Sources
     Secondary fabricators receive their asbestos products  from the primary
industry in a bound form and do not have the problem of  handling raw asbestos
fibers.40  Some asbestos-containing dust may be released during the receiving
of these products due to residual  dust on the product or through breakage or
abrasion during transport.40  Because  occupational  exposures from these
sources are probably not serious,  emissions  to  the  atmosphere are probably
insignificant.  The important emission sources  include actual  fabrication
operations, such as grinding, drilling, sanding,  sawing, routing, cutting,
slitting, and others that destroy  the  integrity of  the product.40
3.15.4  Control Techniques
     Basically, secondary industry segments  use the same type of control
equipment and work practices as the primary  industry segments to reduce
employee exposure to asbestos dust. Control  equipment and  work practices used
include central vacuum systems for floor and equipment cleaning; down-draft
tables, local exhausts on hand tools,  and area  hoods on  large machines
connected to a central  ventilation system with  air  filtering through a
baghouse,40 which represents BAT for dust collection; wet grinding and sawing
where product integrity is not affected adversely;  cleaning of raw materials
and products to minimize dust exposure in handling  and packaging; proper
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handling of scrap materials; and routine equipment and floor cleaning.™  In
addition,, some primary manufacturers try to minimize fiber emissions in
secondary industries by coating or waxing their products.
3.15.5  Waste Disposal
     Waste from secondary processors will resemble that from finishing
operations among primary manufacturers.  Secondary processors, however, do not
have the capabilities to recyle product scrap or vacuum system and baghouse
waste.  It is likely that they use landfills for waste disposal.
3.15.6  Costs
     No attempts were made to obtain current cost information on  fabricating
operations and control systems.

3.16 REFERENCES
1.   Bureau of Mines, U.S. Department of the Interior.  Asbestos  in 1980,
     Annual Advance Summary.  In:   Mineral  Industry Surveys.  Washington, D.C.
     May 15, 1981.   7 p.

2.   Clifton, R. A.  Asbestos Mineral  Facts and Problems, 1980 Edition.
     Bureau of Mines, U.S. Department of the Interior.  Washington, D.C.
     Bulletin 671.   1980.  17 p.

3.   Kendall, D. L., et al.  Economic Impact Analysis  of Controls on Certain
     Use and Exposure Categories of Asbestos (draft).   Research Triangle
     Institute.  (Prepared for Office of Toxic Substances,  U.S.  Environmental
     Protection Agency.  Research  Triangle  Park, North Carolina.)   November
     1980.
4.   1980 Review:   The Asbestos Mining Industry—United States.  Asbestos.
     62(7):11-12.   January 1981.
5.   International  Industry Review—1979.  Part II:  The Asbestos Mining
     Industry—United States.  Asbestos. 6l_(6):l7-lB.   December  1979.

6.   W. E.  Davis and Associates.  National  Inventory of Sources and Emissions,
     Cadmium, Nickel, and Asbestos, 1968.  (Prepared for National  Air
     Pollution Control  Administration.  Washington,  D.C.)   February 1970.
                                     3-81

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7.   Harwood, C. T.  Asbestos Air Pollution Control.   Illinois  Institute  of
     Technology Research Institute.  IIEQ Document No.  71-8.   (Prepared for
     the Illinois  Institute for Environmental Quality.   Chicago,  Illinois.)
     November 1971.

8.   Fowler, D. P.  Derivation of Emissions Estimates  shown in  Figure	
     (Unpublished).  SRI Internationil.  Menlo Park, California.  28 p.

9.   Harwood, C. F., and T. P. Blaszak.  Characterization and Control of
     Asbestos Emissions from Open Sources.  Illinois Institue of Technology
     Research Institute.  (Prepared for National Environmental Research
     Center, U.S. Environmental Protection Agency.  Research Triangle Park,
     North Carolina.)  EPA-650/2-74-090.  September 1974.  203 p.

10.  Office of Air Quality Planning and Standards, U.S. Environmental
     Protection Agency.  Control Techniques for Asbestos Air Pollutants.
     Research Triangle Park, North Carolina.  Publication AP-117.  February
     1973.  p. 3-4.

11.  Harwood, C. F., P. Siebert, and T. P- Blaszak.  Assessment of Particle
     Control Technology for Enclosed Asbestos Sources.  Illinois Institute of
     Technology Research Institute.  EPA-650/2-74-088 (Prepared for Office of
     Research and Development, U.S. Environmental Protection Agency.  Research
     Triangle Park, North Carolina.)  October 1974.  126 p.
12. Office of Air Quality Planning and Standards, U.S. Environmental
     Protection Agency.  Background Information on National  Emission Standards
     for Hazardous Air Pollutants, Proposed Amendments to Standards for
     Asbestos and Mercury.  Research Triangle Park, North Carolina.
     EPA-450/2-74-009.  October 1974.   p. 59-72.

13.  Little, A. D.  Characterization of the U.S. Asbestos Papers Markets.
     (Prepared for Sores, Inc.)  May 1976.  p. 42.
                                     3-82

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14.  Meylan, William M., et al.  Chemical Market Input/Output Analysis of
     Selected Chemical Substances to Assess Sources of Environmental
     Contamination:  Task III.  Asbestos.  Syracuse Research Corporation.
     (Prepared for the Office of Toxic Substances, U.S. Environmental
     Protection Agency.  Washington, D.C.).  August 1978.  323 p.

15.  Bureau of the Census, U.S. Department of Commerce.  1977 Census of
     Manufactures.  Preliminary Report.  Asbestos Products.  Standard
     -Industrial  Classification 3292.  Washington, D.C.  May 1979.  p. 8.

16.  Johns-Manville.  Friction Materials.  Chrysotile Asbestos Fiber Technical
     Bulletin.  Denver, Colorado.  AF-112A.  Undated.  1 p.

17.  Gregg, R. T.   Development Document for Effluent Limitation Guidelines and
     New Source Performance Standards for the Textile, Friction Materials, and
     Sealing Devices Segment of the Asbestos Manufacturing Point Source
     Category.  Effluent Guidelines Division, U.S.  Environmental  Protection
     Agency.  Washington, D.C.  EPA-440/-174/035-a.  December 1974.  91 p.
18.  Margolin, S.  V., and B. U.  N.  Igwe.  Economic Analysis of Effluent
     Guidelines:   The Textiles, Friction, and Sealing Materials Segment of the
     Asbestos Manufacturing Industry.  Arthur D.  Little, Inc.
     EPA-230/2-74/030.  (Prepared for Office of Planning and Evaluation, U.S.
     Environmental  Protection Agency.  Washington,  D.C.)   July 1975.   61 p.

19.  SRI International.  Asbestos:   An Information  Resource.  R.  J. Levine
     (ed.)   (NIH)  79-168.  (Prepared for the National  Cancer Institute,
     National  Institute of Health.   Bethesda, Maryland.)   May 1978.

20.  Laney, M.  Trip Report—Initial  Plant Visit, Bendix Corporation, May 14,
     1981.   Research Triangle Institute.  Research  Triangle Park, North
     Carolina.  May 21, 1981  5 p.

21.  Reference 3,  p. 135-152.
22.  RTI contacts  with personnel  for the Johns-Manville Corporation.   1981.
                                     3-83

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23.  Reference 3, p. 287-305.
24.  Clifton, R. A.  Asbestos.  Mineral Commodity  Profiles.   Bureau  of Mines,
     U.S. Department of the Interior.  Washington, D.C.   September 1977.
     17 p.

25.  Carton, R. J.  Development Document for Effluent Limitations Guidelines
     and New Source Performance Standards for the  Building, Construction, and
     Paper Segment of the Asbestos Manufacturing Point Source Category.
     Washington, D.C.  Office of Air and Water Programs,  U.S. Environmental
     Protection Agency.  EPA-440/l-74-017-a.  February 1974.  143 p.
26.  Harwood, C. F., and P- K. Ase.  Field Testing of Emission Controls for
     Asbestos Manufacturing Wast Piles.  EPA 600/2-77-098.  IIT Research
     Institute.  (Prepared for Office of Research and Development, U.S.
     Environmental Protection Agency.  Cincinnati, Ohio.)  May 1977.   135 p.
27.  Reference 14, p. 107-143.
28.  Boltin, J., J. Helsen, and A. Deruytteri.  Nature, Structure, and
     Properties of Asbestos Cement Dust.  British Journal of Industrial
     Medicine. -_27_: 33-41.  1980.
29.  Rajhans, Gason S., and Gordon M. Bragg.  Engineering Aspects of Asbestos
     Dust Control.  Ann Arbor Science, 1978.  p. 32-35.
30.  Ontario Ministry of the Environment.  Asbestos as a Hazardous Contaiminat
     II.  January 1975.
31.  Siebert, P. C., T. C. Ripley, and C. F. Harwood.  Assessment of Particle
     Control Technology for Enclosed Asbestos Sources—Phase II.   Illinois
     Institute of Technology Research Institute.  (Prepared for Office of
     Research and Development, U.S. Environmental  Protection Agency.  Research
     Triangle Park, North Carolina.)  EPA-600/2-76-065.  March 1976.  134 p.
32.  Johns-Manville Corporation.  Vinyl  Asbestos Floor Tile.  Chrysotile
     Asbestos Fiber Technical  Bulletin.  AF-114A.   Denver, Colardo.  Undated.
     1 p.
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33.  Bureau of the Census, U.S. Department of Commerce.  Abrasive, Asbestos,
     and Miscellaneous Nonmetallic Mineral Products.  Industry Services.   1977
     Census of Manufacturers.  MC77-1-32E.  July 1980.  p. 32E-24.

34.  Wright, M. D., et al.  Asbestos Dust.  Technological Feasibility and
     Economic Impact Analysis of the Proposed Federal Occupational Standard.
     Part I.  Research Triangle Institute.  (Prepared for the Occupational
     Safety and Health Administration, U.S. Department of Labor.  Washington,
     D.C.)  September 1978.
35.  Daly, A. R.  Technological Feasibility and Economic Impact of OSHA
     Proposed Revision to the Asbestos Standard.  Roy F. Weston Environmental
     Consultants-Designers.  (Prepared for Asbestos Information
     Association/North America.  Washington, D.C.)   March 29, 1976.  189 p.

36.  Clifton, R. A.  Asbestos.  1978-1979 Bureau of Mines Minerals Yearbook.
     Washington, D.C.  Bureau of Mines, U.S. Department of the Interior.
     1980.  14 p.

37.  Reference 3, p. 171-180.
38.  Reference 3, p. 316.

39.  Bureau of the Census, U.S. Department of Commerce.   Industry Series,
     Petroleum and Coal  Product.   1977 Census of Manufacturers.   Publication
     No. MC77-1-29A.  July 1980.
40.  Research Triangle Institute.   Asbestos Dust.  Technological  Feasibility
     Assessment and Economic Impact Anlaysis of the Proposed  Federal
     Occupational Standard.  Part  III.  (Prepared for the Occupational  Safety
     and Health Administration, U.S.  Department of  Labor.   Washington,  D.C.).
     September 1978.
41.  Clifton, R. A.   Asbestos.  Mineral  Commodity Profiles.   Bureau of Mines,
     U.S.  Department of the Interior.   Washington,  D.C.   July 1979.  19 p.
42.  Clifton, R. A.   Asbestos.  1974  Bureau of Mines Minerals Yearbook.
     Bureau of Mines, U.S.  Department  of the Interior.   Washington, D.C.
     11  p.
                                     3-85

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43.  Clifton, R. A.  Asbestos.  1975 Bureau of Mines  Minerals  Yearbook.
     Bureau of Mines, U.S. Department of the  Interior.   Washington,  D.C.
     12 p.

44..  Clifton, R. A.  Asbestos.  1976 Bureau of Mines  Minerals  Yearbook.
     Bureau of Mines, U.S. Department of the  Interior.   Washington,  D.C.
     11 p.

45.  Clifton, R. A.  Commodity Data Summaries, 1977-  Bureau of Mines, U.S.
     Department of the Interior.  Washington, D.C.  January 1977.  p. 12.

46.  Clifton, R. A.  Mineral Commodity Summaries, 1978.  Bureau of Mines, U.S.
     Department of the Interior.  Washington, D.C.  January 1978.  p. 12.

47.  Moody1s Investors Service, Inc.  Moody1s Industrial Manual, New York.
     1979.

48.  Johns-Manville Corporation.  Asphalt Coatings.   Chrysotile Asbestos Fiber
     Technical Bulletin. Denver, Colorado.  Undated.  1  p.

49.  Reference 3, p. 180-192.

50.  Johns-Manville Corporation.  Asbestos Textiles.  Chrysotile Asbestos
     Fiber Technical Bulletin.  AF-111A.  Denver, Colorado.  Undated.  1 p.

51.  Reference 3, p. 192-202.

52.  Lewinsohn, H. C., C. A. Kennedy, J. E. Day, and  P.  H. Cooper.   Dust
     Control in a Conventional Asbestos Textile Factor.  Annals of the New
     York Academy of Sciences.  I. J. Selikoff and E. C. Hammond (eds.).
     330:225-241.  1979.

53.  Reference 3, p. 97.

54.  Bureau of the Census, U.S. Department of Commerce.  Inorganic Chemicals.
     In:  Current Industrial Reports.  Washington, D.C.  Publication No.
     M28A(77)-4.  April 1977.

55.  Chlorine Institute, Inc.  North American Chior-Alkali Industry  Plants and
     Production Data Book.  Pamphlet 10.  January 1980.  17 p.
                                     3-86

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56.  Conrad, L.   Trip Report—Intital Plant Visit, LCP Chemicals-New  York,
     Inc.  Research Triangle Institute.  Research Triangle Park, North
     Carolina.   March 5, 1981.

57.  Meyland, W.  M.,  et al.  U.S. Asbestos Paper Industry and Substitutes for
     Asbestos Paper and Asbestos Brake Linings.  Syracuse Research
     Corporation.  (Prepared for the Office of Toxic Substances, U.S.
     Environmental  Protection Agency, Washington, D.C.)  September 1979.

58.  Cell Developers  Work to Cut Electric Bills.  Chemical Week.  June 10,
     1981.  p.  51.

59.  Reference  3.  p. 329-33.

60.  Reference  3, p.  345.

61.  Reference  12,  140 p.

62.  Reference  14,  p. 276-178.

63.  Reference  13,  p. 346-351.

64.  Reference  14,  p. 275-276.

65.  Telecon.   Laney, M.,  Research  Triangle Institute,  with  Garker, B.,
     National Asphalt Pavement  Association.  August  13,  1981.   Use  of asbestos
      /
     in  asphalt concrete.

66.  Reference 35,  p. 11-21  to  11-25.

67.  Lee, B.  S.,  et al.  Asbestos Dust.   Technological  Feasibility  Assessment
     and Economic Impact Analysis of the  Proposed Federal  Occupational
     Standard.  Part  II:   Economic  Appendix,  Asbestos Dust in  Construction.
     Research Triangle Institute.   (Prepared  for the U.S.  Department of  Labor,
     Occupational Safety and Health Administation, Washington, D.C.)
     September 1978.
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     4.   INDUSTRY DESCRIPTION:   DEMOLITION,  RENOVATION, AND CONSTRUCTION

4.1 INDUSTRY DESCRIPTION:   CONSTRUCTION
     Approximately 75 to 80 percent of all  asbestos manufactures are used by
the construction industry.   The industry's  complexity and flexibility make it
difficult to follow consumption of asbestos  products although the literature
describes installation and  application processes.   The industry consumes
asbestos/cement (A/C) products, flooring  products,  roofing materials, paper
products, insulation, and coatings and sealant materials.  Asbestos products
have'specific uses and markets  but may be shared by several  construction
industry factions, such as  single-family  dwelling  contractors, multiunit
residential  dwelling contractors,  or nonresidential  building contractors.
Because  asbestos products are widely used in a variety of construction jobs, a
construction industry profile will  provide the necessary basic information to
review accurately the scope of  the asbestos  emission standard.  Of particular
interest are portions of the industry involved in  demolition and renovation
operations as covered by the standard. Therefore,  this section addresses
construction separately from renovation and  demolition.
4.1.1.  Industry Statistics
     In  1977, 1.2 million establishments  were operating as general building
contractors  and operative builders (SIC 15), heavy  construction contractors
(SIC 16), special trade contractors (SIC  17), and  subdividers and developers
(SIC 6552).!  Of the 1.2 million establishments, 70 percent were special trade
contractors, 24 percent were general  builders, 5 percent were involved in
heavy construction, and 1 percent  was subdividers  and developers.
     Business receipts for  construction projects totaled $244.8 million, a
49-percent increase over receipts  collected  and reported in 1972.1  The 1977
employment figures showed a total  of over 4  million construction workers in
the United States, similar  to the  number  reported  in 1972.
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     Assuming little change in 1977 statistics,  the largest industry segment
is made up of nonpayroll  establishments.   However,  the 720,000 establishments
in this category only accounted for 8 percent of business receipts.  These
businesses are controlled by 735,000 self-employed  proprietors and working
partners who contract their own services.  Seventy-seven percent of these
establishments are primarily special trade contractors.
     Establishments with  payroll  employees numbered 450,000 in 1977, employing
approximately 4.3 million persons and retaining  279,000 proprietors and
working partners.  This smaller industry  segment accounted for 92 percent of
total business receipts.   Only 18 percent of payroll  establishments employed
more than 10 workers but  accounted for 76 percent of all  business receipts
received in the industry.  Table  4-1 summarizes  1977  and  1972  statistics for
construction establishments with  and without payroll.
     Business receipts were over  $10 billion for payroll  establishments
located in New York, Illinois, Texas, and California.   The largest dollar
income for construction was in California with $25  billion in  receipts, and
the lowest was in Vermont with $380 million in receipts.   On the average, 86
percent of business receipts were paid for construction work by home State
establishments.
     General building contractors and operative  builders  are involved  in
residential and nonresident!"al construction that includes dwellings, stores,
farm buildings, and office buildings.  General contractors perform services
either under contract with the project owner or  under  the operative builder
who undertakes projects to be sold.  Heavy construction general  contractors
are involved in highway and street construction; bridge,  tunnel, and elevated
highway construction; water, sewer, and utility  projects; dams and water
projects; air fields; heavy industrial  facilities;  and other heavy
construction that involves either earth moving or erecting constructions and
appurtenances other than  buildings.
     Special trade contractors are involved in specialized activities  such as
plumbing, heating, and air conditioning;  painting,  paper  hanging,  and
decorating; electrical work; masonry and  other stonework; plastering,  drywall,
and insulation; terrazzo, tile, marble, and mosaic  work;  carpentry; roofing
and sheet metal work; concrete work; water well  drilling; structural  steel
                                     4-2

-------
TABLE 4-1.  SUMMARY STATISTICS  FOR ESTABLISHMENTS WITH AND WITHOUT PAYROLL:   1977 AND 19721
All establishments

Industry
Construction industries and
subdividers and developers
' Construction industries
co
General building contractors
and operative builders
Heavy construction general
contractors
Special trade contractors
Plumbing, heating, and air
conditioning
Electrical work
Subdividers and developers.
not elsewhere classified

Number
1,200,407

1,183.221
286,320

55,210

841.691
106,603

75,958
17,186

Proprie-
tors and
working
partners
1.013,961

996,942
219,077

37,449

740,416
79,806

58,230
17,019

All
employees
4,272,659

4,233,658
1,180,747

917,083

2,135,828
458,687

356,591
39,001

All
business
receipts
x 1,000
244,815,905

239.426.850
98,116.714

51,674.514

89,635,622
22,650,620

15,213,602
5,389.058

Establ isliuents without payroll

Number
720.393

708,285
130,349

23.915

554,021
50,168

39.194
12.108

Proprie-
tors and
working
partners
734,652

719,381
130,596

24,366

564 419
51,108

39,656
15.271

All
business
receipts
x 1,000
20,150,970

17,804.427
8,330.156

946,739

8,527,532
1,219,435

731,760
2.346,543


Number
480,014

474,936
155,971

31.295

287,670
56,435

36,764
5,078

Establishments with payroll
Proprie-
tors and
working
partners
279,309

277.561
88,481

13,083

175.997
28,698

18,574
1,748

All
employees
4,2/2,659

4,233,658
1,180.747

917,083

2,135,828
458,687

356,591
39,001

Al 1
bus inuss
receipts
x 1,000
224.664,938

221.622.423
89,786.558

50,727. 7/5

81.108,090
21.431.185

14,481,842
3,042,515

                                                                                       (Continued)

-------
   TABLE  4-1.   SUMMARY STATISTICS  FOR ESTABLISHMENTS WITH  AND WITHOUT PAYROLL:   1977 AND 1972  (Continued)
All establishments
Industry
1972
Construction industries and
subdividers and developers
_p» Construction industries
General building contractors
and operative builders
Heavy construction general
contractors
Special trade contractors
Plumbing, heating, and air
conditioning
Electrical work
Subdividers and developers.
Number

920,806
906,134
208.383
42.717
653.325
88.371
57.816
14,672
Proprie-
tors and
working
partners

748,253
743,855
149,579
27,823
564,737
65.528
42.952
4.398
All
employees

4,145.779
4,083,465
1,149.520
827.346
2.106.599
456,100
323,748
62,314
All
business
receipts
x 1,000

164.457,691
161,091,002
67.374.118
31,921,251
61,774,631
16,394,924
10,126.111
3.366.689
Establishments without payroll
Number

482.865
476,107
75,329
14,726
384,343
25,070
25.361
6.758
Proprie-
tors and
working
partners

473,819
471,354
M.663
14,383
383,592
34.782
25.224
2.465
All
business
receipts
> 1.000

8,607,039
8,369,423
3,024,195
460,355
4,863.871
779,456
518,076
238,616
Number

437.941
430.027
133.054
27.991
268.982
53,301
32.455
7,914
Establishments with payroll
Proprie-
tors and
work 1 ng
partners

274.43''
272.501
77.916
13,440
181,145
30.746
17,728
1.933
Al 1
enipl oyees

4, 14 '.1.7/9
4.083,465
1.149.520
827,346
2.106,599
456,100
323,748
62,314
Al 1
bus mess
receipts
t 1,000

155,849,652
152,721,579
64,459,923
31,460,896
56,910,760
15,615,468
9,608,035
3,128,073
not elsewhere classified

-------
erection; glass and glazing work;  excavating and foundation work; and wrecking
and demolition.  Special  trade contractors may work for general  contractors
under subcontract or directly for  the project owner.  Subdividers and
developers are primarily  engaged in subdividing real property into lots and in
developing it for resale  for their own account or for others.
     General  statistics for payroll  establishments by various construction
industries are provided in Table 4-2.  Regardless of types of construction
work and business, certain fundamental  characteristics are shared among
various industry classes.  Some of these characteristics can be  summarized to
define the industry further:
          Construction work is performed at temporary locations  that vary in
          size, physical  boundaries,  and working surfaces;
          Construction work is usually performed in open air, subject to
          weather variability;
          Construction work varies as the project progresses from initiation
          to completion,  demanding a  variety of materials, equipment, and
          skills;
          Type and duration of emissions are variable due to the significant
          influence wind  and atmospheric conditions can have on  dust
          dispersal;
          Portable tools  and equipment are preferred on temporary locations
          and for field work, making  local  exhaust ventilation (LEV) and dust
          collection a major engineering problem; and
          Employment is transient  in  construction, permitting tradesmen and
          laborers to work for several  different contractors at  several
          different sites per year.
4.1.2.  Renovation
     Under Section 61.21  of the asbestos emission standard,  renovation has
been defined as "the removing or stripping of friable asbestos materials used
on any pipe, duct, boiler, tank, reactor, turbine, furnace,  or structural
member."  Wrecking or removal  of load-supporting structural  members  is
excluded.  Therefore, removal  of insulation materials containing asbestos and
removal of sprayed-on asbestos-containing materials for remodeling,  repair, or
renovation (operations as described by the construction industry)  could come
under the standard's purview.   However, as the standard stipulates,  only
removal or stripping of friable asbestos materials amounting to  that covering
more than 80 meters of pipe or that covering more than 15 square meters of a
duct, boiler, tank, reactor, turbine, furnace, or structural  member  is
regulated.  The Administrator excluded from the scope and application of the
standard all  residential  buildings except private multiunit  dwellings with
more than four units.
                                     4-5

-------
                  TABLE 4-2.   GENERAL STATISTICS  FOR  ESTABLISHMENTS WITH PAYROLL  BY INDUSTRY:  1977
CTl
SIC
Code

15,16
17
15

1521
1522
1531
154
1541
1542
16
1611
162
1622
1623
1629

Employees Payroll
Total
Number of Construction All Construction construction
Industry establishments All workers employees workers receipts
Construction Industries and
subdlviders and developers
Construction Industries:
General building contractors
and operative builders:
General contractors,
residential buildings:
Single- family houses
Other residential buildings
Operative builders
General contractors,
nonresidential buildings:
Industrial buildings and
warehouses
Nonresidential buildings, not
elsewhere classified
Heavy construction general contractors:
Highway and street construction
Heavy construction, except highway:
Bridge, tunnel, and elevated
highway construction
Water, sewer, and utility lines
Heavy construction, not elsewhere
classified
480,014 4,272.659 3,565,469 54,960,063 43,112,399 214,844,319


100,993 437,681 382,806 3,736,421 3,066,031 21.292,675
4,775 55,589 45,707 646,375 484,890 4,442,110
23,477 173,819 109,702 2,026,118 1,053,389 19,812,272

8,259 202,070 170,787 2.852,817 2,247,193 12,855,514
18,467 311,588 254,360 4,274,933 3,189,805 27.137,768

11,748 ' 267,917 232,810 3,595,809 2.927.185 15.021,207

979 38,093 33,187 535,877 438,750 2.247,284
10,227 198,354 173,093 2,837,270 2,347,495 9.361,092
8,342 412,719 318,375 7,298,267 5,274,120 21.624,035
                                                                                             (Continued)

-------
TABLE 4-2.   GENERAL STATISTICS  FOR ESTABLISHMENTS WITH PAYROLL BY  INDUSTRY:   1977  (Continued)
Employees
SIC
Code
17
1711
1721
1731
174
1741
1742
1743
175
1751
1752
1761
1771
1781
179
1791
1793
1794
1795
1796
1799
Number of Construction
Industry establishments All workers
Special trade contractors:
Plumbing, heating, and air
conditioning
Painting, paper handling, and
decorating
Electrical work
Masonry, plastering, and tile
setting:
Masonry, stone setting, and other
stonework
Plastering, drywall, and insulation
work
Terrazzo, tile, marble, and mosaic
work
Carpentering and flooring:
Carpentering
Floor laying and other floorwork
Roofing and sheet metal work
Concrete work
Water well drilling
Miscellaneous special trade
contractors:
Structural steel erection
Glass and glazing work
Excavating and foundation work
Wrecking and demolition work
Installing building equipment,
not elsewhere classified
Special trade contractors, not
elsewhere classified
56,435
27.369
36,764

24,815
16.745
3,891

24,388
8,969
20,577
16,974
4,305

2,592
3.283
16,521
978
2,442
20.626
458,687
133,106
356,591

152,167
180,326
22,324

124,646
40,990
171,931
118,116
22.352

47,166
26,125
104.092
8.295
40,474
128.440
368,993
121.288
296,946

142,797
158,479
19,084

114,673
33,724
146,307
107,085
18,720

40,911
19.335
91,552
6,998
32,630
107,632
Payroll
All
employees
6,413,961
1,361,463
5,482,519

1.493,214
2.261,906
255,475

1,202,203
453,107
1.967,824
1,209,879
237,036

673,768
316,974
1,207,669
89,020
752,439
1,383,720
Construction
workers
5.024,679
1,191,130
4,496,695

1,350,307
1,900,704
207,643

1,060,685
352,246
1.555,286
1,042.622
188,307

556.462
228,741
1,020,923
70.233
601,593
1,085,630
Total
construction
receipts
21.072,098
3.171,129
14,221,277

3,775,368
6,057,467
766,114

3,597,222
1,616,932
6,200,390
4,097,293
1,090,418

1,803,310
1,006,566
4,215,722
240,630
1899,047
4,407,208
6552
Subdividers and developers, not
  elsewhere classified
5.078
39,001
17.518
414,002
414,002
1,053,473

-------
     Portions of the construction industry that would engage in "renovating
operation"  are general  contractors of residential  but not single-family
buildings;  general  contractors of nonresidential  buildings that include
industrial  buildings and warehouses;  and general  contractors who engage in new
construction, addition, alteration,  remodeling, and repair of commercial,
institutional, religious, amusement,  and recreational buildings.  In addition,
the following special  trade contractors would most likely engage in
renovation:
          Plumbing, heating (except  electric), and air conditioning;
          Electrical work;
          Plastering,  drywall, acoustical, and insulation work;
          Roofing and  sheet metal  work;
          Wrecking and demolition;
          Installation or erection of building'equipment, not elsewhere
          classified (includes contractors who dismantle industrial
          equipment);  and
          Special trades, not  elsewhere classified (includes insulation of
          pipes and boilers and dismantling of forms  of poured concrete).
     Table 4-2 provides general statistics on establishments, employment, and
business receipts for those construction types.   Information taken from the
Census of Construction Industries also includes business receipts  for
maintenance and repair-  Assuming all  renovation  would be classified as such,
this information may provide a dollar volume guide relative to all
construction receipts  per construction type.  Table 4-3 provides maintenance
and repair receipt data for all building contractors  other than single-family
dwellings reported in  the 1977 Census of Construction Industries.
     Table 4-4 provides maintenance  and repair receipt data for industrial
structures, facilities, and installations reported under "nonbuilding
construction."  Nonbuilding construction is the Census classification that
includes power plants; sewage  treatment and water  treatment plants;  and blast
furnaces, petroleum refineries, and  chemical complexes.   Although  the standard
does not specifically  cite plants and complexes,  they may be construed as
industrial  facilities  and installations for this  review.   Assuming maintenance
and repair of nonbuilding construction would be solely by special  trade
contractors, receipts  reported for general  contractors and operative builders
are not included in the table.  Also,  receipts attributed to repair and

                                     4-8

-------
      TABLE 4-3.   MAINTENANCE AND REPAIR RECEIPT DATA FOR  BUILDINGS  OTHER
                         THAN SINGLE-FAMILY DWELLINGS
       Industry series
Maintenance and
repair receipts
  ($l,OOOs)
Percent of
all receipts
General  contractors

  Residential  buildings other
    than single-family3

  Industrial  buildings and
    warehouses3

  Nonresidentialj  other than
    industrial  buildings and
    warehouses3

Operative builders

  All  buildings other than
    single-family

Special  trades

  Plumbing,  heating,  and air
    conditioning
     219,692


   1,255,011


   1,237,968
      90,358
   2,810,744
    5.0


   10.0


    4.6
    0.5
   13.3
Electrical work
Plastering, drywall ,
acoustical , and
insulation
Roofing and sheet metal work
2,112,087
534,807
1,413,893
14.9
8.8
22.8
aDoes not  include  receipts from outside the particular SIC.
                                   4-9

-------
TABLE 4-4.  MAINTENANCE AND REPAIR RECEIPT DATA FOR NONBUILDING CONSTRUCTION
      Industry series
   acoustical, and
   insulation

 Roofing and sheet metal  work
Maintenance and
repair receipts
  ($l,OOOs)
    41,601
Percent of
all  receipts
Plumbing, heating, and air
conditioning
Electrical work
PI astering, drywall ,
375,207
439,976
115,341
1.8
3.1
2.0
    0.7
                                4-10

-------
maintenance of streets, highways, or other heavy construction have been
subtracted from totals reported in the Census.
     Standard Industrial  Classification (SIC) codes of "Installation or
Erection Building Equipment,"  not elsewhere classified, include dismantling of
machinery and other industrial  equipment contractors and installation
contractors that may be involved in renovating operations as defined by the
standard.  The 1977 Census reports 2,442 payroll establishments, an employment
of 40.5 thousand workers, and  business receipts of $1.95 billion.  Total
construction receipts were $1.9 billion.  New construction, which may also
include renovation under this  SIC code, and maintenance and repair receipts
were over $900 million.
     The special trade contractors, not elsewhere classified, includes
contractors engaged in waterproofing, damproofing, and fireproofing that  may
require renovating as defined  by the standard.  However, because several
special trade types are included in this particular classification and because
the Census does not provide specific information, it is impossible to
determine the percentage of the $4.4 billion in receipts that can be
attributed to renovating operations.
4.1.3  Demolition
     In 1979 under a "New Directions Grant" from the Occupational Safety  and
Health Administration (OSHA),  a demolition industry profile was prepared.2
The profile showed that 2,300  companies in the United States are involved in
demolition as opposed to the 836 reported in 1972 and the 978 reported in the
1977 Census of Construction Industries.  The researchers used a variety of
sources but found over 1,600 firms advertising demolition services in
telephone directories of 157 cities.  Extrapolation revealed approximately
2,300 firms capable of demolition work.
     Primary data showed that  most of the demolition firms—approximately 68
percent—provide a full range  of industrial, commercial, and residential
structure demolition.  The remainder are involved in specialized jobs, such as
chemical plants, port facilities, or utilities equipment.  The report
characterized demolition work  by the short-term jobs and substantial
subcontracting.2
     The survey showed that the average firm employs 12 permanent and 10
temporary workers and that the average duration of demolition projects is 3.87
                                     4-11

-------
32
J£
30
28
26
24
22
20
18
i 16
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                                                      eN  I   tf"*  I  3*-  I       I      I*



                                                      °  I   °  I  °  I       I        ,
10    15     20     25    30     35     40     45


   NUMBER OF AVERAGE TEMPORARY EMPLOYEES




 Figure 4-3. Average temporary employee distribution.
                                                                            50
                                                                                  < I-
                                                                                     70
                                      4-14

-------
    380



    360



    340



    320
£  300
1  280
Ul
t-

\  260


i
e
£  240

u.
o

*  220

CO


£2  200
Ul

O
    180
Ul
5   160
IT
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Ul
tr
LU
C9

-------
days for a residence, 9.56 for a commercial  structure, and 14.7 for an
industrial facility-  However, it did not report specifically the duration of
demolitions involving asbestos removal.  Figures 4-1, 4-2, 4-3, and 4-4 were
taken from the report that shows distribution of demolition work, distribution
of permanent and temporary employees as a function of the frequency of
contracting work, and comparison of the two  types of employees.
     According to previous EPA estimates, fewer than 3,000 demolitions per
year are covered by the standard.3  For verification, EPA regional National
Emissions Standards for Hazardous Air Pollutants (NESHAPs) officers indicated
that an estimated 2,618 demolition projects  covered by the standard are
completed in a year.4  Further investigation revealed that contracts were
awarded for demolition of 2,596 buildings in 1978.4  These figures, however,
were not qualified because the number of demolition contracts involved
asbestos.  In addition, it was found that EPA's Region V received notices of
79 demolition and renovation projects in 1978 and that 731.4 demolition
contracts were awarded Region V contractors.  This  could mean that of the 731
contracts, only 79 were covered by the standard; that all  731 involved
asbestos but only 79 were done within Region V; or  that the remaining
contracts were neither initiated nor reported.
     Table 4-5 summarizes the data TRC reported on  1978 demolition projects.

4.2  PROCESS DESCRIPTIONS
4.2.1.   Introduction
     The construction industry consumes approximately 75 to 80 percent of all
asbestos products.  Except for A/C sheet, flooring  felts,  and textiles shared
by secondary industries, these products, designated in Table 4-6,  are sold
directly to construction contractors either  by  the  manufacturers  or through
distributors.  Products are used in the following construction types:
          Private single-unit residences,
          Private multiunit residences and nonhousekeeping units,
          Residential additions and alterations,
          Private nonresidential  buildings,
          Educational and religious facilities,
          Hospitals and institutions,
          Farm nonresidential buildings,
          Telephone and telegraph facilities,
                                    4-16

-------
TABLE 4-5.  SUMMARY OF DEMOLITION DATA^
Number of
contractors
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II
New Jersey
New York
Region III
Del aware
District of Columbia
Mary! and
Pennsylvania
Virginia
West Virginia
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
148
36
13
70
10
17
2
316
107
209
249
8
11
38
130
41
21
251
16
95
28
26
4
45
17
20
524
185
75
83
24
87
70
Number of
contracts
674
144
16
457
8
39
10
150
78
72
577
47
72
10
445
3
0
119
15
16
56
12
3
13
3
1
731
12
58
209
9
125
318
Percent of Percent of
total total
contracts contractors
26.0 6.5






5.8 13.8


22.2 10.8






4.6 10.9








28.2 22.8






                                          (Continued)
                   4-17

-------
TABLE 4-5.  SUMMARY OF DEMOLITION DATA (Continued)4

Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region IX
Arizona
California
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Washington
Number of
contractors
181
13
27
10
35
96
130
54
22
36
18
106
50
7
10
4
25
10
304
27
245
12
20
92
2
11
31
48
Number of
contracts
121
27
36
0
28
30
141
29
0
44
68
16
0
4
2
6
1
3
22
2
19
0
1
45
12
7
6
20
Percent of Percent of
total total
contracts contractors
4.7 7.9





5.4 5.7




0.6 4.6






0.9 13.2




1.7 4.0




                     4-18

-------
     TABLE 4-6.   ASBESTOS PRODUCTS CONSUMED BY THE CONSTRUCTION INDUSTRY5
          Products
   Secondary
    market
     Final
     product
   consumption
A/C pipe

A/C sheet



A/C siding/shingles

Vinyl/asbestos (V/A)  floor
  tile

Flooring felts


Roofing felts


Pipe insulation


Electrical  insulation


Mi 11 board
Coatings/seal ants
  25% to
fabricators
60% flooring
manufacturers
Textiles (thermal/electrical
  insulation)
90% wire and
cable industries;
braided rocking
and felt manu-
facturers; elec-
trical and
thermal
insulation users
Heavy construction

Building construction
  manufacturing and
  furniture

Building construction

Building and special
  trade construction

Building and special
  trade construction

Building and special
  trade construction

Building and special
  trade construction

Building and special
  trade construction

Building and special
  trade construction;
  steel  and glass
  industries

Building; heavy and
  special trade
  construction; auto-
  motive and home
  repair
10% directly to
  building; heavy
  special trade
  construction
and
                                     4-19

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          Water facil Hies,
          Sewer works,
          Electric and other public utilities,
          Public housing, and
          Miscellaneous public construction including military facilities.
Usage of asbestos products involves the activities shown in Table 4-7.
     In addition to erection and installation activities, maintenance and
repair activities may require removal  of asbestos products.  Demolition
activities may also involve removal or destruction of asbestos-containing
materials.
     Construction contractors recently have been called upon to encapsulate
sprayed-on asbestos materials in lieu of removing friable asbestos materials
from public buildings.  Although this activity neither uses nor removes
asbestos materials, it involves potential  asbestos emissions.  The number and
types of contractors called on to perform  this activity are not known,
partially because measures to correct asbes.tos fiber fallout in public
buildings are just being addressed by Federal  and State Governments.
     The process or operational  descriptions for each of the above activities
are presented in one of the following  sections: . construction,  renovation,
and demol Hi on.
4.2.2  Construction
     4.2.2.1  A/C Pipe Installation.   Although pipes are manufactured in
standard sizes and in half and quarter lengths with  proper  couplings, pipes
occasionally must be cut to length and machined  to fit couplings.   Pipes that
are machined all  over by the manufacturer  do not  require additional  machining.
Either special tools designed for cutting  and  machining pipe or a  standard
power saw equipped with an abrasive or diamond wheel  is used.
     An economic analysis of the occupational  standard revealed that 1976
production was 90 million linear feet  of pipe, that  the installation
production rate was 223 feet per day  for a typical crew of  three or four
people, and that one 15-minute cutting machining  operation  is required for
approximately 1,300 feet of pipe.   It  was  estimated  that 9,230  cuts per year
would be made in the field on A/C pipe.^
     4.2.2.2  A/C Sheet Installation.   Field cutting  of A/C sheets  may be
required at corners and around wall  apertures.   Holes must  be drilled on A/C

                                    4-20

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  TABLE 4-7-   DISTRIBUTION OF ACTIVITIES AMONG DIFFERENT CONSTRUCTION TYPES&
           Type
                                                Activities
1.

2.
Private single-unit residences

Private multiunit residences
  and nonhousekeeping units
3.
Residential  additions and
  alterations
4.
Private nonresidential
  buildings; industrial  and
  commercial offices; and
  miscellaneous construction
5.
Educational  and religious
  facilities
Drywal1 removal

A/C sheet installation
A/C architectural panel
  installation
Installation of built-up roofing
  and replacement roofing
Roof removal
Drywal1 removal
Thermal, acoustical, and
                                               decorative material
                                               and  removal
                                                              maintenance
A/C sheet installation
A/C architectural panel
  installation
Installation of built-up roofing
  and replacement roofing
Roof removal
Drywal1  removal
Thermal, acoustical. "and
                                               decorative  material
                                               and  removal
                                                              maintenance
A/C sheet installation
A/C architectural panel
  installation
Installation of built-up roofing
  and replacement roofing
Roof removal
Drywal1 removal
Thermal, acoustical, and
  decorative material maintenance
  and removal

A/C sheet installation
A/C architectural panel
  installation
Installation of built-up roofing
  and replacement roofing
Roof removal
Drywal 1 removal
Thermal, acoustical, and
  decorative material maintenance
  and removal
                                                                    (Continued)
                                     4-21

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            TABLE 4-7-  DISTRIBUTION OF ACTIVITIES AMONG DIFFERENT
                        CONSTRUCTION TYPES (Continued)6
           Type
        Activities
6.   Hospitals and institutions
7.   Farm, nonresidential
8.   Telephone and telegraph
       facilities
9.   Water facilities
10.  Sewer works
11.  Electric and other public
       utilities

12.  Public housing
A/C sheet installation
A/C architectural panel
  installation
Installation of built-up roofing
  and replacement roofing
Roof removal
Drywall removal
Thermal, acoustical, and
  decorative material maintenance
  and removal

Drywall removal
Thermal, acoustical, and
  decorative material maintenance
  and removal
Thermal, acoustical, and
                                               decorative material
                                               and removal
                      maintenance
A/C pipe installation
Thermal, and acoustical insulation
  maintenance and removal

A/C pipe installation
Thermal and acoustical insulation
  maintenance and removal

Electric insulation installation
  maintenance and removal

A/C sheet installation
A/C architectural panel
  installation
Drywall removal
Installation of built-up roofing
  and replacement roofing
Roof removal

                      (Continued)
                                     4-22

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            TABLE  4-7-   DISTRIBUTION  OF  ACTIVITIES AMONG  DIFFERENT
                        CONSTRUCTION  TYPES  (Continued)6
           Type
        Activities
13.   Miscellaneous  public
       construction including
       military  facilities
14.   Demolition
A/C sheet installation
A/C architectural panel
  installation
Drywall  removal
Installation of built-up roofing
  and replacement roofing
Roof removal

Removal  of thermal, acoustical,
  and decorative material
                                     4-23

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sheets for attachment purposes.  Circular saws equipped with either an
abrasive wheel or a diamond- or carbide-tipped blade are used for cutting, and
standard portable drills are used for the holes.  The same economic analysis
showed that of the 96 million square feet of A/C sheet produced in 1976, 75
percent is consumed by the construction industries.  It was estimated that
field fabrication is required on 5 to 30 percent of the installed sheet and
that each sheet averages 32 square feet.  Therefore, of approximately 2
million sheets consumed by construction, only 100,000 to 600,000 sheets
require field cutting per year.
     The average amount of A/C sheet used per project was reported as 24,750
square feet.  The 1976 production figure for A/C sheet was used to determine
that 2,909 projects using A/C sheet were undertaken that year.   If,  for each
site, field fabrication is required on 5 to 30 percent of the sheets,
approximately 38 to 230 sheets need field finishing.
     4.2.2.3  A/C Architectural Panel  Installation.   Most A/C panels  are
ordered to specifications from the manufacturer, minimizing the need  for field
fabrication.  However, since the panels are attached to frames  with  screws,
drilling is necessary.  Standard electric drills are used for this purpose.
Occasionally, cutting is required, which is performed by using  a portable
circular saw equipped with an abrasive or diamond cutting wheel.
     The 1976 figures showed that 3 million square feet of A/C  panel  was
produced and that the daily installation rate is approximately  495 square feet
for an average crew of four people.^  Economic analysis of the  occupational
standard showed that approximately 8,365 square feet of panel is needed  per
project and that 350 projects used A/C panels in 1976.   Analysis also  showed
that for every 12,000 square feet, approximately 32  cuts  taking  15 minutes
each were required and that approximately 6,500 holes had to  be  drilled.
Therefore, for each site 22 cuts and 4,500 holes are necessary  (assuming a
constant market demand).
     4.2.2.4  Installation of Asbestos Roofing Felts.   The  economic analysis
of the occupational  standard indicated that asbestos felts  coated  with asphalt
are cut with a knife or shears at the  installation site.   Then,  the felts  are
placed over the roof deck in layers  and roofing tar  is  mopped on between the
layers.8  in another economic analysis, it was reported  that  three plies are
                                    4-24

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layered for built-up roofing.9  Two types of roofing installations have been
described.10  One type of built-up roofing is applied by layering uncoated
asbestos roofing felts, and the second involves layering previously coated
felts and using cold adhesives to cement the plies together.  In addition to
built-up roofing, asbestos felts are often used as an underlayment for other
roofing materials such as asphalt shingles.
     Approximately 200 square miles of commercial  built-up roofing is
installed annually and the daily installation rate of a crew size of seven is
about 2,400 square feet.8  The number of cuts and  the timing required for each
depend upon the size of the roof and the desired size of each ply.
     The quantity of annually installed roofing reported in 1976 by the
National  Roofing Contractors Association may have  changed radically,  as
indicated by current production numbers.5  The 1979 production of roofing
felts was 138,500 short tons.9  Since roofing felts usually are manufactured
in weights of 9 1/2 to 15 pounds per 100 square feet,10 based on an average,
the felt installed in built-up roofs could not have exceeded 66 square miles.
Since roofing felts are not used solely for built-up roofing, the amount  may
still be less.
     4.2.2.5  Roof Removal.. Approximately 100 square miles of commercial  and
industrial  roofing is repaired or renovated annually requiring removal  of
roofing felts containing  asbestos..   With a crew of 5 people, the average  daily
removal  rate is 16 squares or 1,600 square feet of old  roofing.8  Ninety-nine
percent of removal  is manual, in which roofing is  pulled from the deck.   When
insulation is attached, the roofing is usually cut into 2-  by 2-foot
squares,  which are thrown manually  to the ground.11
     4.2.2.6  Drywall  Removal.  Asbestos associated with drywall  removal  is
contained in spackling, taping, and joint compounds. Although use of
asbestos-containing patching and joint compounds was banned in 1977,  prior
construction used such compounds.
     Therefore, it is likely that  of 1.65 billion  square feet of drywall
removed each year,  some—the footage installed prior to 1977—may produce
free-form asbestos fiber  emissions  when removed.7   Drywall  usually is pulled
from the  frame manually;  however, tools such as axes or hammers may be
required  initially to break into the wall  in some  circumstances.12 The wall
                                     4^25

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joints are cut and, if the drywall had been nail-applied to wood studs, the
nails are punched through in order to salvage the material.  If the drywall
had been screw-applied onto metal, the screws are removed and the joint tape
is cut.
     4.2.2.7  Sanding Asbestos Floor Tile.   A common practice among floor tile
installers was sanding old floor tile with  conventional  belt sanders before
resurfacing.  However, in their instruction manuals, manufacturers warn
against sanding old tile, a practice most contractors have discontinued.   The
number of installations where sanding is continued is not known.
     4.2.2.8  Installation of Asbestos Cloth and Rope Lagging Electrical
jnsulation.  Applying asbestos textile insulation materials such as cloth and
rope lagging usually is used for electrical  insulation and requires pulling
the cloth or rope from rolls or coils and cutting to desired lengths.   The
cloth and rope are usually cut with mechanical  cutters,  knives,  clickers,
dies, or scissors.  Cloth can be torn from  the roll, but this is not
recommended.  Materials are fitted, hammered and nailed, glued,  and sewn
during application.
     4.2.2.9  Installation of Thermal  Insulation.   Thermal  insulation  usually
consists of paper and millboard, but cloth  or woven tape may be  used.
Installing paper and millboard sheets for thermal  insulation requires  field
fabrication to fit the materials onto equipment and structures.   Paper and
millboard sheets must be cut to shape and length.   For piping, flues,  and
circular stacks, paper, millboard, cloth, or tape is wrapped around the
objects in layers and can be fixed to the surface with wire, bands, or
sheathing.  Fabric covering can also be applied with or  without  coating or
paints.  For furnaces, boilers, turbines, reactors, kettles, or  other  heated
vessels, the asbestos millboard is attached  to the surfaces  by studs,  bolts,
bands, expanded mesh, or sheet metal.?
     4.2.2.10  Removal of Nonfriable Insulation Materials.   Like drywall,
asbestos blanket (cloth), rope, and asbestos paper and millboard insulation on
turbines, boilers, pipes and ducts is manually  torn off  surfaces or from
cavities.  Approximately every 3 to 5  years  large  amounts of insulation are
removed as a result of inspections and repairs  required  on  turbines in
electric power-generating plants.7
                                    4-26

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 4.2.3   Renovation
     4.2.3.1  Removal of Friable  Insulation and Fireproofing Materials.
 Removal  of A/C insulation spray-applied prior to 1973; removal of friable,
 molded  thermal and acoustical  insulation containing asbestos and of powdered
 A/C  insulation manually wet-applied prior to 1975; and removal of any other
 sprayed-on materials containing more than 1 percent asbestos applied before
 1977 are regulated by the EPA emission standard for asbestos.  Therefore, in
 addition to dislodging material from ceilings, walls, pipes, ducts, or other
 surfaces with scrapers, picks, drills, saws, or other hand-held or powered
 tools,  removal will include containment of the area, sufficiently wetting the
 asbestos material prior to stripping, or capturing emissions at the source by
 LEV.
     Sprayed-on asbestos materials were commonly used by the construction
 industry from 1946 to 1973.13  In 1950 more than half of all multistory
 buildings constructed in the United States used some form of sprayed-on
 fireproofing, and in 1968 40,000 tons of fireproofing was sprayed on in U.S.
 buildings.^  in 1970 40,000 tons of fireproof ing was used again  for the same
 purpose.15  A 1971 product bulletin stated that by 1971,  more than  50,000,000
 square feet of structural  steel had been fireproofed with a particular brand
 of thermal  insulation.^  These sprayed-on materials containing asbestos were
 used for fireproofing, thermal  and acoustical  insulation, decoration,  and
 condensation control.   Fireproofing accounted  for the largest amounts  on
 structural  steel  components  of multistory  buildings.   Thermal  insulation was
 applied on turbines and in reaction vessels in chemical  plants  and  refineries,
 boiler breechings, and stacks.   Sprayed-on materials  containing asbestos were
 applied for decorative ceilings and for noise  absorption  in large public
 buildings and restaurants.   Walls and  ceilings of indoor  swimming pools,
 laundries,  textile plants, and  other industrial  buildings where condensation
might have caused corrosive  damage were sprayed  with  asbestos-containing
materials.15  EPA has  estimated that approximately  8,600  public schools
contain friable  asbestos materials.
     4.2.3.2   Encapsulating  With Sealants.   Encapsulating with  sealants  has
replaced removal  of sprayed  asbestos materials from buildings.  Nearly  any
sealant or  encapsulation method will  reduce  asbestos  fallout contamination.
Sealing of  sprayed  asbestos  surfaces involves  applying material that will

                                     4-27

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envelop or coat the fiber matrix and eliminate fallout and protect against
contact damage.  Sealants are applied over the surface of the material  using
airless spray equipment at low-pressure settings.
4.2.4  Demolition
     To demolish buildings specified under EPA's emission standard,
contractors must proceed as directed by the standard.  The process includes
removing friable asbestos materials prior to wrecking, wetting materials prior
to removal, removing members coated with friable asbestos, and subsequent
wetting when friable materials are stripped from these units.  Fixtures such
as lights, partitions, and other mounted objects must be removed before
removal of friable materials containing asbestos:  insulation, fireproofing,
acoustical insulation, and decorative coatings containing asbestos.  Actual
removal of material requires spraying area with water or amended water,
scraping, drilling or cutting, placing the material  into drums or doubly
lined plastic bags, and disposal.  Demolition proceeds with cleanup of  debris
by placing it, too, in drums or doubly lined bags for disposal.   Once these
procedures are completed wrecking can commence.
     According to the Background Information Document (BID)  for the 1973
asbestos emission standard, 4,000 apartment buildings and 22,000 commercial  or
industrial buildings are demolished annually.16  However, based  upon reports
to the Agency, EPA estimated that, in 1 year, less than 3,000 demolitions are
covered by the standard.  In a study of demolitions it was found that in 1978,
2,596 demolition projects subject to the standard were initiated, which agreed
with the EPA estimate.4

4.3  EMISSION SOURCES AND EMISSIONS
     In the construction industry emission sources are as variable as are
asbestos products.  Asbestos products are basic building materials that, when
combined with other materials to form a complete support system, have a finite
service life.  They have specific applications within the support system.
Therefore, emission sources are identified by the operations  employed for
certain activities such as product installation, maintenance  and repair,
renovations, and demolition of support systems built with these  materials.
     Process descriptions contained in the previous section  identified
emission sources.  For installation of building materials, emission sources
                                    4-28

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are generally prefabrication; installation or application; cleanup of waste
materials; and disposal of waste materials and dust collected from local
exhaust systems.  For removal of emission source operations, include removal
of any objects attached to asbestos-containing building materials, initial
break or cut into materials, ripping of material from its frame, waste
cleanup, and disposal of waste materials and dust from local exhaust and
vacuum systems.  Table 4-8, taken from the economic analysis of the proposed
occupational standard, lists some operations and available, related emission
data for various products.?  Most published emission data describe the
occupational environment and were obtained with sampling and analysis
procedures that may or may not be appropriate for determining ambient asbestos
fiber concentrations.  However, data are presented only to demonstrate sources
of asbestos emissions.

4.4  CONTROL TECHNIQUES
     The temporary nature of construction projects, sporadic use of asbestos
materials, extensive use of portable tools, and effect of weather on  outdoor
projects make it difficult to control asbestos emissions from construction
activities.^  Published literature and reports have described the various
techniques that, when applied, lower occupational  exposures and  simultaneously
control  environmental emissions.  However, control  of occupational  exposures
in construction relies heavily on work practices;  e.g.,  using slow-running
tools, vacuuming fallen waste from machining, using dust suppressants  for
cleanup, and cutting one piece at a time.
     Most operations involving asbestos products in construction are
fabricating, except for removal  and demolition.   The Asbestos Information
Association (AIA) has recommended that for controlling emissions from
fabrication operations, low-volume, high-velocity  controls for cutting  A/C
sheets should be used, high-efficiency vacuum cleaners should be used  if
available, and good work practices should be followed at all  times.
Installation, removal, demolition, and renovation  control  techniques  are
addressed separately in the following paragraphs.
4.4.1   A/C Pipe Installation
       Although little field fabrication of pipe is necessary due to  the type
of product available, LEV systems for portable tools have been developed by
Johns-Manville;^ however, the extent to which they are being used is  unknown.
                                      4-29

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           TABLE  4-8.   EMISSION SOURCES AND OCCUPATIONAL EXPOSURES7
Operation
                          Activity
      Occupational exposures
             (f/cm3)
Machining  A/C pipe


Machining  A/C sheet

  Sawing


  Drilling



Machining  A/C panels

Laying roofing felts

Tearing off roofing
  felts

Drywal1 removal

Sanding floor tiles

Tearing out electrical
  turbine  insulation
  (blankets)
                        Installation
                        Installation
                        Installation

                        Installation

                        Repair


                        Repair

                        Installation

                        Maintenance
Tearing old insulation  Renovation


                        Renovation
Removal  of ceil ing
  sprayed  with
  A/C mix
  Dry removal

  Wet (water)

  Wet (amended  water)
0.0-0.5—controlled
Greater than 25 (C)a--uncontrolled

2 to greater than 24(C)a

Less than 5—uncontrolled
Greater than 20—uncontrolled

Less than 2—controlled
Less than 2 except for overhead
  drilling--uncontrol 1 ed

2 to greater than 25(C)a

0.1-0.2 (8-h TWA)

0.0-1.7 (8-h TWA)


15 (8-h TWA)

1.2

0.1-5.9 (8-h TWA)
                                          •  0.2-26.3
                                            82.2

                                            23.1

                                            8.1
a(C)  represents  a ceiling concentration.
                                                            (Continued)
                                    4-30

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     TABLE 4-8.  EMISSION SOURCES AND OCCUPATIONAL EXPOSURES (Continued):
Operation
Activity
Occupational exposures
        (f/cm3)
Cleanup debris          Renovation
  containing asbestos

  Wetted (water)

  Wetted (amended
    water)

Cleanup scrap           Renovation
  insulation
  containing asbestos

Removal of insulation   Demolition
                  0.3-4.0

                  0.2-0.3


                  Less than 0.1 to 3.7



                  Greater than 80(C)a
a(C) represents a ceiling concentration.
                                    4-31

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Work practices have been recommended that include, cutting with carbide blade
equipment; using snap cutters; using .manual and powered lathes designed for
pipe; cutting holes with specially designed hole cutters; drilling holes with
a drill and rasp or a chisel and rasp; and using specially designed equipment
for tapping.7  in addition, recommendations have been made against blowing
out dust and cuttings with compressed air or using power-driven saws for dry
cutting or leveling pipe.l?  A second control  method is a change in the
process in which field machining would be eliminated by special orders of
prefabricated pipe.  A third control .method is elimination of A/C pipe usage.
PVC (polyvinyl chloride) pipe is already a commonly used alternative.5  Work
practices emphasizing cleanup of debris and catching of chips produced by
cutting and machining would prevent reentrainment into the air by other
activities.  AIA recommends that equipment surfaces be free of dust
accumulations.1?  These work practice guides are a result of field studies to
establish the best available techology (BAT) in controlling asbestos emissions
from field fabrication operations.
4.4.2  A/C Sheet Installation
       Portable powered drills and saws (circular and sabre)  equipped with
dust collection hoods have been developed and  tested.  AIA recommends hand
saws equipped with carbide blades for infrequent cutting to limit generation
of airborne fibers.18  Clippers designed with  slow cutting speeds also
generate coarse particles and few airborne fibers.  These tools are
commercially available, but the extent of their use is unknown.  Other
practices include placing a vacuum box behind  the sheet to collect particles
falling from behind cutting and drilling actions and a piece of plywood behind
the sheet during drilling to prevent emissions from underneath.19  Wet cutting
is another possible control technique that has been used to control
occupational exposures to asbestos in A/C product manufacturing plants.
Whether or not such a technique has been field tested or used at  all  by
construction contractors is unknown.19
     To a large extent, sheets and panels are  prefabricated,  minimizing the
need to cut and drill holes.  Manufacturers often receive orders  with
specifications for precutting.  Special  fabricating shops that work with A/C
                                     4-32

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product distributors provide prefabrication services,^ but prefabrication
may not be possible in all installations, especially when allowances must be
made for ducts, conduits, and other protrusions.
     As with A/C pipe, use of nonasbestos-containing substitutes is another
control method.  Market demand for A/C sheet has been affected directly by
substitutes, and sales volume has decreased approximately 5 percent annually
since 1977.20
     Work practices—such as wet sweeping, vacuuming, collecting debris from
machining, and keeping equipment dust free—help minimize airborne asbestos
fibers.  These control methods provide field fabricators with the best means
of controlling asbestos emissions under special conditions of field work.18
4.4.3  Drywall Removal
       Occupational exposure to asbestos has been described for the removal  of
drywall for either repair or demolition activities.21  However, engineering
controls for occupational  exposures have not been described for pulling
drywall from building frames.  Work practices that involve wetting may reduce
emissions, but current studies on asbestos emission controls have not
indicated that spraying drywall joints with water or amended water is
applicable as it is for insulation removal.  However, containment as described
for removal  of sprayed-on asbestos materials may be possible for areas where
drywall is to be repaired or removed.^  Good housekeeping practices,  such as
wet sweeping, vacuuming, and keeping equipment dust free are recognized
controls for occupational  exposure that minimize airborne asbestos fibers.
4.4.4  Installation and Removal of Roofing Felts
       Engineering controls for occupational exposures to asbestos from
cutting and applying plies or pulling  off roofing felts are not known.
Prefabrication or precutting of felts  for installation by the manufacturer may
minimize field cutting but may not be  feasible or necessary, considering the
possibly increased product cost and the low occupational exposures at
concentrations of 0.1 f/cm^.  Containment of installation and removal
operations would be economically infeasible due to cost of building
containment structures and of controlling the inevitable increase in
occupational  exposures.  Wetting with  amended water has been mentioned as a
probable control; however, actual  studies have not been reported.21
                                    4-33

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4.4.5  Removal  of Nonfriable Insulation
       Again, wetting with amended water is mentioned as a probable control
method of occupational exposures resulting from removal of textile and paper
insulation products.21  Containment procedures may also be possible as
described for removal of friable asbestos insulation.14  cleanup work
practices that include wetting scrap, wet sweeping, and vacuuming also provide
for emission control.
4.4.6  Encapsulation with Sealants
       Application of a sealant to friable asbestos materials by spraying will
disseminate small fibers by contact.  A sealant should be applied with as much
caution and at as low a nozzle pressure as possible to reduce contact
disturbance.  The potentially high concentration of small asbestos fibers
could cause significant worker exposure, so workers require protection with
respiratory devices and decontamination.  Such asbestos fiber contamination
from application of sealants is usually not detectable by the National
Institute for Occupational Safety and Health (NIOSH) method of optical
microscopy and may require electron microscopic examination for definition.14
4.4.7  Renovation and Demolition
       Asbestos emissions resulting from renovations and removal  of friable
materials containing asbestos are controlled by use of amended water prior to
scraping, picking, and drilling and by containing emissions within areas where
removal is undertaken.  Demolition control procedures include removal  of
friable materials containing asbestos, removal  of nonsupport installations
covered with friable asbestos materials such as boilers, and spraying of the
building with water prior to wrecking.
4.5  WASTE DISPOSAL
     The processes involved with asbestos-containing materials in construction
are fabrication, renovation, or demolition operations.  However,  fabrication
of asbestos products for installation is not covered by the current EPA
standard.  In its definition of fabrication, EPA has exempted fabrication
of products "at temporary sites for the construction or restoration of
buildings, structures, facilities, or installations."  However, 61.22 (j) of
the current NESHAP for asbestos applies to the friable materials  removed in
renovation and demolition operations.  Therefore, asbestos-containing waste
                                     4-34

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from these operations either is treated with water, sealed with leak-tight
containers, and buried or is formed into nonfriable pellets or shapes.
     At construction sites, waste includes A/C pipe, sheet and panel scrap,
and dust collected by local exhaust systems or any other means from cutting
and drilling operations.  Waste includes ripped out roofing and drywall,
roofing felt pieces left from installation, and dust collected by vacuum
systems or wet-sweeping during cleanup.  Nonfriable insulation such as paper
and textile scrap used in electric generating plants, on pipe and ducts, also
will be construction waste.  Waste also will include pieces of floor tile and
flooring felts left after installation and empty and near-empty cans, barrels,
or drums of asbestos-containing coatings and sealants.  However, only the
friable materials containing asbestos removed from buildings are covered under
waste disposal  provisions of the standard.

4.6  COSTS
     Some cost data are available from economic analysis of the occupational
standard.  Equipment designed to control emissions from drilling or cutting
A/C products may cost from $400 to $3,000.5  Industry's total  annualized cost
for engineering controls"for a 2.0-f/cm^ occupational  exposure limit is
between $1 and $9 million.
     Surfactants for making amended water might cost between $15 and $18 per
gallon, and 1 ounce of surfactant to 5 gallons of water is  the recommended
usage.^  Therefore, the cost of amended water in renovation and demolition
will depend upon the size of the job and the amount of friable asbestos to  be
removed.  According to Sawyer,  the cost of removing and disposing  of a  ceiling
containing a sprayed-on asbestos cement covering costs $42,962 or $1.23 per
square  foot.*4
     The cost of removing sprayed-on asbestos materials in  27  Massachusetts
public  schools ranged from $0.91 to $14.00 per square foot.13  •

4.7  STATUS OF OCCUPATIONAL HEALTH STANDARD
     The Occupational  Safety and Health Administration (OSHA)  standard  for
asbestos [29 CFR 1910.  1001] is applicable to the construction industry and is
currently under review by the Agency.   The review has been  projected to take
at least 2 years.   The current  permissible exposure level  is 2 f/cm^.
                                    4-35

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4.8  REFERENCES
1.   Bureau of the Census, U.S. Department of Commerce.  1977 Census  of
     Construction Industries, Summary.

2.   JACA and National Association of Demolition Contractors (NADC) Project
     Summary and Report of First Year Grant Activities.  (Prepared  for the
     Occupational Safety and Health Administration, U.S. Department of Labor,
     Washington, D.C.)  June 1979.

3.   Office of Air Quality Planning and Standards, U.S. Environmental
     Protection Agency.  Background Information on National Emission  Standards
     for Hazardous Air Pollutants, Proposed Amendments to standards for
     Asbestos and Mercury.  Research Triangle Park, North Carolina.
     EPA-450/2-74-009.  October 1974.  p. 140.

4.   The Research Corporation of New England.  Demolition and Renovation.
     Cost of Complying with EPA Asbestos Regulations.  Wethersfield,
     Connecticut.  (Prepared for the U.S. Environmental Protection Agency.)
     August 1979.  92 p.

5.   Kendall, D. L., et al.  Economic Impact Analysis of Controls on  Certain
     Use and Exposure Categories of Asbestos (draft).  Research Triangle
     Institute.  (Prepared for the Office of Toxic Substances, U.S.
     Environmental Portection Agency.  Research Triangle Park, North
     Carolina.)  November 1980.
6.   Lee, B. S., et al.  Asbestos Dust.  Technological Feasbility Assessment
     and Economic Impact Analysis of the Proposed Federal  Occupational
     Standard.  Part II:  Economic Appendix, Asbestos Dust in Construction.
     Research Triangle Institute.  (Prepared for the U.S.  Department  of Labor,
     Occupational Safety and Health Administration, Washington, D.C.)
     September 1978.

7.   Wright, M. D., et al.  Asbestos'Dust.  Technological  Feasbility  and
     Economic Impact Analysis of the Proposed Federal Occupational Standard.
     Part I:  Research Triangle Institute.  (Prepared for the U.S. Department
     of Labor, Occupational Safety and Health Administration, Washington,
     D.C.)  September 1978.  p. 111-13 to 111-54.

                                     4-36

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8.   Reference 7,  p. 11-13.

9.   Reference 5,  p. 78-86.
10.  Meylan,  William M.,  et  al.   Chemical  Market Input/Output Analysis of
     Selected Chemical  Substances to Assess Sources of Environmental
     Contaimination.  Task III:   Asbestos.  Syracuse Research Corporation.
     (Prepared for the Office of Toxic Substances, U.S. Environmental
     Protection Agency,  Washington,  D.C.)   August 1978.

11.  Conrad,  L.  Personal  communications with Quality Roofing Company.  Randy
     Bolton.   Durham, North  Carolina.  July 29, 1981.

12.  Conrad L.  Personal  communications-with the Association of Wall and
     Ceiling  Industries.   Gene  Irwin.  Washington, D.C.  July 29, 1981.

13.  Irving,  Karen, et al.   Asbestos Exposure in Massachusetts Public Schools.
     American Industrial  Hygiene Association Journal.  4Jj270-276.  April
     1980.
14.  Sawyer,  Robert N;   Asbestos-Containing Materials in School  Buildings:  A
     Guidance Document.   Part II.   (Prepared for the Office of Air and Waste
     Management and the  Office of Air Quality Planning and Standards, U.S.
     Environmental  Protection Agency, Research Triangle Park, North Carolina).
     EPA-450/2-78-014.   March 1978.

15.  Reitz, William.  Application  of Sprayed Inorganic Fiber Containing
     Asbestos.  Occupational  Health  Hazard.  American Industrial  Hygiene
     Association Journal.  ^3_:178-191.   March 1972.

16.  Office of Air Quality Planning  and Standards, U.S. Environmental
     Protection Agency.   Background  Information on Development of National
     Emission Standards  for  Hazardous Air  Pollutants:  Asbestos,  Berylluim,
     and Mercury.   APTD-1503.  Research Triangle Park, North Carolina.   March
     1973.  p. 97.

17.  A/C Pipe Producers  Association.   Recommended Work Practices  for A/C Pipe.
     Arlington, Virginia.  1977.   p.20.
                                     4-37

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18.   Asbestos Information Association.   Recommended Work Practices for Field
     Fabrication of Asbestos-Cement Sheet.  Arlington, Virginia.  January
     1980.   p.  27.

19.   Reference  7, p. IV-65 to IV-69.

20.   Reference  5, p. 150.

21.   Reference  7, p. VI-24.
                                     4-38

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                             5.   CONTROL METHODS

     Methods potentially applicable for control  of asbestos emissions are
discussed in this chapter.  Technological  advances in fabric filtration,
scrubbing, and electrostatic precipitation as they apply to controlling
particulates and developments in emission control  methods for the demolition,
renovation, and construction industry are reviewed.   Finally, substitutes for
asbestos and asbestos products are examined as another method for preventing
asbestos emissions.  Detailed information on controls already in widespread
use in the asbestos industry are not presented (see  Chapters 3 and 4  for
discussions of controls currently used in the asbestos industry).  However,
principles of operation and current use of fabric  filters (the predominant
control  method) scrubbers, and electrostatic precipitators (ESP) are
sunmarized for background information.

5.1  FABRIC FILTERS
     Housed in a structure known as a baghouse,  fabric filters are one of the
most effective methods for removing solid  particles  from gas streams.   During
filtration, a dust-laden gas stream is passed through a woven or felted
material in the shape of a cylindrical  or flat supported bag, depositing dust
on the dirty side of the filter.  Dust is  deposited  on the filter by  direct
interception, inertial impaction, diffusion, electrostatic attraction,
gravitational settling, and sieving.   A mat or cake  of dust forms on  the
filter surface, improving its collection efficiency.   Eventually, the combined
resistance to air flow of the filter and filter  cake  increases to the point
that air velocity across the filter and in the entire exhaust system
decreases.  At some predetermined resistance level  (determined by pressure
drop across the filter), the filters are cleaned by  one of a variety  of
cleaning mechanisms.  These cleaning mechanisms  are  a distinguishing  feature
among baghouse designs.
     Filters may be cleaned by fabric flexing or reverse air flow.  Fabric
flexing  can be accomplished by manual, mechanical, or air shaking.  Air
                                     5-1

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shaking is further separated into air bubbling, jet pulsing, reverse air
flexing, and sonic vibration.   Reverse air flow consists of three methods:
repressuring cleaning, atmospheric cleaning, and reverse-jet cleaning.   For
each of these methods, advantages and disadvantages exist that must be
considered in the overall  design of a fabric filtration system for each
industrial application.
     A variety of filter material  is available; actual  selection is determined
by factors such as gas stream  temperature and moisture, available space,
cleaning method, and costs.   Fabric filter cloth is either woven or felted.
Woven fabrics generally operate at lower air-to-cloth ratios than do felted
fabrics, therefore requiring more cloth area for the same amount of exhaust
gas.  Felted bags are used in  reverse-jet and pulse-jet baghouses.
     A survey of plants that used asbestos revealed that 80 percent of  the
respondents used baghouses and 90.1 percent of all  control  devices used were
baghouses.1  In addition,  another 4.4 percent of the plants used baghouses
preceded by cyclones, a combination representing 3.2 percent of total control
devices used.  Table 5-1 summarizes the information on  control  device use,
including baghouse use.
     The same survey showed  that cotton was the fabric  used in  the majority of
baghouses (see Table 5-2)  and  mechanical  shaking the cleaning method used most
often (see Table 5-3).  Air-to-cloth ratios ranged  from 1  foot  per minute to
over 10 feet per minute (see Table 5-4).   Ratios for mechanically shaken
baghouses were generally less  than 3 to 1, while reverse-jet baghouses  had
air-to-cloth ratios of 4 to  1  and greater.  Pressure drops  for  a majority of
the baghouses surveyed operated were under 3 inches of  water (see Table 5-5).
     During 1981, information  on emission controls  was  collected during visits
to 13 milling, manufacturing,  and fabricating sites that used over 120
separate control devices (see  Table 5-6).  Detailed information was not
available in all instances,  but baghouses were overwhelmingly used to control
asbestos emissions, as shown in Table 5-7.  The cyclone used in conjunction
with a baghouse acted to return scrap material  to the process and to reduce
the load on the baghouse.   The wet scrubber, with a pressure drop of 1.5
inches, was used to control  emissions from a high-moisture, exhaust gas
stream.  Table 5-8 summarizes  the information collected on  baghouse cleaning
                                     5-2

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                      TABLE 5-1.  DUST CONTROL DEVICES1
Plants
using device
Control device
Baghouse
Scrubber
Cyclone-baghouse combination
Cyclone
Filter systems
Scrubber-baghouse combination
No.
72
6
4
4
3
1
Percent
80.0
6.8
4.4
4.4
3.3
1.1
Total
devices used
No.
335
8
12
7
6
4
Percent
90.1
2.1
3.2
1.9
1.6
1.1
Total
90
100.0
372
100.0
                                    5-3

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                                             TABLE  5-2.   BAG  FABRIC1
01
I
Plant Baghouses using Bag-cleaning mechanism used with
using fabric fabric type of fabric, no. (%) of baghouses
Fabric
Cotton
Dacron
Polyester
Canvas
Wool
Nylon
Orion
Polyprolene felt
Polyphrone felt
Burlap
Total
No.
36
8
5
2
2
1
1
1
1
1
58
Percent No.
62.3 164
13.8 31
8.6 15
3.4 4
3.4 2
1.7 4
1.7 3
1.7 3
1.7 1
1.7
100.0 227
Hand Automatic Reverse Pulse
Percent shaker shaker jet jet
72.2 27 125 10 2
(16.4) (76.8) (6.7) (1.2)
13.7 23 3 5
(74.2) (9.7) (16.1)
6.6 -- 5 10
(33.3) (66.7)
1.8 4
(100.0)
0.9 2
(100.0)
1.8 4
(100.0)
1.3 3
(100.0)
1.3 -- -- 3
(100.0)
0.4 -- 1
(100.0)
--
100.0

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                     TABLE 5-3.  BAG-CLEANING MECHANISM1
Cleaning mechanism
Automatic shaker
Pulse jet
Reverse jet
Hand shaker
Total
TABLE 5-4.
Air-to-cloth ratio
m/mi n ft/mi n
£0.62:1 £2.0:1
0.63-0.75:1 2.1- 2.5:1
0.76-0.91:1 2.6- 3.0:1
0.92-1.24:1 3.1- 4.0:1
1.25-3.10:1 4.1-10.0:1
PI
using
No.
39
10
9
8
66
AIR-TO-CLOTH
ants
mechanism
Percent
59.0
15.2
13.6
12.2
100.0
RATIO1
Plants having
ratio
No.
3
3
6
2
7
Percent
14.3
14.3
28.6
9.5
33.3
Baghouses using
mechanism
No.
160
28
33
32
253

Percent
63.3
11.0
13.1
12.6
100.0

Baghouses
having ratio
No.
22
22
23
9
34
Percent
20.0
20.0
20.9
8.2
30.9
Total
21
100.0
110
100.0
                                     5-5

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                                     TABLE 5-5.  PRESSURE DROP ACROSS BAG1
Bag-cleaning mechanism used
Plants Baghouses no. (%)
having Ap3 with Ap

Pressure drop Hand Automatic
(cm [in.] H20) No. Percent No. Percent shaker shaker
Ap < 2.54 (1) 2 10.0 2 2.0 -- 2
(100.0)
2.54 (1) < Ap < 5.08 (2) 3 15.0 40 39.2 7 16
01 (17.5) (40.0)
cr>
5.08 (1) < Ap < 7.62 (3) 5 25.0 17 16.6 -- 11
(64.7)
7.62 (3) < Ap < 10.2 (4) 10 50.0 43 42.2 7 26
(16.3) (60.4)
Reverse
jet
__

10
(25.0)

4
(23.5)
4
(9.3)
Pulse
jet
._

7
(17.5)

2
(11.8)
6
(14.0)
Total 20 100.0 102 100.0
aAp = pressure drop.

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              TABLE 5-6.   PROCESSES  AND NUMBER OF SITES VISITED
               Process
Number of sites visited
Mill ing
Asbestos/cement (A/C)  products
Textile products
Plastic materials
Friction products
Paper and felt
Chlorine
         3
         2
         2
         1
         2
         2
         1
Total
        13
                        TABLE  5-7.   CONTROL DEVICE USE3
Control device
Baghouse
Cyclone-baghouse combination
Scrubber
Otherb
Number of pi ants
using device
11
1
1
2
Total
devices used
120
1
1
1
Information was collected  during  1981  plant visits.
bOne plant using a small  amount  of asbestos uses high-efficiency particulate
 air (HEPA)  filters.   Because  of the  nature of its product and its
 manufacturing process,  another  plant virtually has eliminated emission
 sources from within  the  plant,  thus  eliminating the  need for air pollution
 control equipment for asbestos  emissions.
                                     5-7

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                  TABLE 5-8.   BAGHOUSE-CLEANING  MECHANISMS3
                                                      Baghouses
Cleaning mechanism                         Number                   Percent





Pulse jet                                   83                       68



Reverse air                                 10                       8



Shaker                                      29                       24





Total                                      122                     100





Information was collected  during 1981 plant visits.
                                    5-8

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mechanisms.   Reverse-jet cleaning was used in 68 percent and shaker mechanisms
were used in 24 percent of the baghouses.
     Advances in fabric filtration technology during recent years have been
limited to introduction of fabrics capable of withstanding high temperatures
and use of pneumatic cleaning  devices.2 Attempts are being made to augment
the already  high collection efficiency  of  baghouses through application of
electrostatics and optimization of baghouse operations.
     High exhaust temperature  is not  a  serious problem for the  asbestos
industry.  High temperatures are associated with drying  of asbestos ore during
milling.  Nomex fabric  filters typically are used for cleaning  dryer exhausts
in the mills visited.
     The only other major advance or  change that has occurred is the apparent
increase in  use of reverse-jet filters  in  the asbestos industry.   Generally,
lower overall  costs have made  reverse-jet  fabric filters  increasingly popular
wherever dust is collected from industrial  processes.3  Pulse-jet cleaning
requires use of felted  fabrics and allows  higher air-to-cloth ratios,  thus
necessitating fewer bags for the same air  flow.   Reverse-jet filters typically
have longer  bag lives than do  mechanically shaken filters.   In  addition, extra
bags are often installed in shaker-cleaned baghouses to  permit  the .closing  off
of a part of the baghouse for  cleaning  without interrupting  production.*
     Potentially available technology applicable to  fabric  filtration  was
explored. Use of electrostatic augmentation to  improve  filter  performance
currently is being investigated.   An  electrostatic  charge  applied to exhaust
particles or to filters or the imposition  of an  electric  field  across  the
fabric reportedly increases collection  efficiency and  reduces pressure
drop.2>4,5  Reduced pressure drop is  apparently  due  to deposition on the
filter of a  more porous filter cake.2  Currently, an electrostatic
augmentation device is  being marketed under the  trade  name  "Apitron."   In the
Apitron, incoming dust  is charged as  it passes through a corona  in charging
tubes just before entering the open end of the filter  bags.  The  filters and
charging tubes are cleaned by  a pulse of compressed  air.
 However,  in  some  asbestos  plants, the  need  for extra bags in mechanically
 shaken  baghouses  is avoided by  scheduling fabric cleaning during  normal
 production interruptions,  sucn  as meal  breaks and  shift changes.
                                     5-9

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      In another EPA-sponsored  study, a  pilot-scale  baghouse  is  being  used  to
investigate electrostatic  augmentation  of  fabric  filtration.6   A reverse-jet
baghouse, electrostatically augmented,  is  being operated  in  parallel  with  a
conventional baghouse  (control) to eliminate dust from  an  industrial  boiler
slipstream.  The electric  field is maintained  parallel  to  the fabric  surface;
corona particle charging is not used.   Performance  of the  electrostatically
augmented baghouse has  been superior to the conventional baghouse in  several
ways, including:
          Reduced rate  of  pressure drop increase during a  filtration  cycle,
          Lower residual pressure drop,
          Stable operation at  higher face  velocities, and
          Improved particle removal efficiency.
Reported, low power consumption and modest expenditures for electrical
hardware combined with  the ability to operate  at increased face  velocities
offer a favorable economic projection.
      For some asbestos  manufacturing operations an  intermediate  product  is
produced, which will be processed further to create a finished  product.  This
process is often referred to as fabricating or secondary processing.
Fabrication of the intermediate products can liberate asbestos fibers as in
the cutting, grinding,  or drilling of millboard, A/C sheet, or brake  products.
These operations are similar to the finishing  steps in manufacturing  and
emissions are controlled in the same way, typically by fabric filtration.
Other fabricating operations are not likely to emit asbestos; e.g., in the
asphalt saturation of asbestos felt for built-up roofing or pipeline wrap, or
in the vinyl coating of asbestos felt for vinyl sheet flooring.    Air-cleaning
devices associated with these  operations; e.g., high-energy air  filters
(HEAFs) used for controlling emissions from asphalt impregnating  materials,
are not intended for asbestos  control.  Use of HEAFs has been investigated for
.controlling emissions from asphalt saturation  processes and phenol formaldehyde
baking ovens where emissions are submicron, liquid,  tacky particulates.7»8
Applicability of HEAFs  to asbestos emission control  is unknown.
     Although baghouses have a high mass efficiency, they may still release
large numbers of small  fibers.1  Thus, research has been performed to optimize
baghouse efficiency by  controlling various operating parameters,  such as
                                     5-10

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relative humidity, air flow,  dust  loading,  bag  type,  shake  cycle,  and series
operations.9>!0  In a pilot-scale  study,9  the  following  qualitative
conclusions  were drawn:
          Relative humidity may affect  the  longer  fibers' filterability,  and
          nigh relative  humidity adversely  affects many  bag fabrics;
          Total  dust loading  is less  significant than  dust  type;
          Cotton fabrics seem equal  in  control  capability and  superior in
          resistance to  relative humidity;
          Increasing air-to-cloth  ratios (ranges selected in study)  promote
          fiber removal;
          Higher shake amplitudes  produce  lower outlet concentrations;
          Shorter shake  durations  produce  lower outlet fiber concentrations;
          Longer time periods between shake cycles (low  frequency)  produce
          Tower outlet fiber  concentrations;
          Exhaust recycle during bag  stabilization may dramatically reduce
          outlet fiber concentration during stabilization of new bags
          (approximately 24 hours  of operation); and
          TWO  baghouses  in  series  are not  significantly  more efficient than  a
          single, stabilized  baghouse.
Atypical  baghouse was selected, automated, and modified for stack  sampling  in
a subsequent field study to assess the  impacts  on  baghouse  efficiency of  shake
amplitude, shake duration,  and  interval between shaking.^   The conclusion was
that long  intervals between shaking, small  shake amplitude, and short shake
duration are apparently  related  to lower emission  concentrations.   Low
emissions  were thus related to  the least frequent  bag  disturbances.10

5.2  WET COLLECTORS
     Water and other liquids  are employed  in conventional,  wet collectors to
entrap and remove particulates  from gas streams.   This action  is accomplished
by bringing  droplets of  scrubbing  liquid into contact  with  the undesired
entrained  particles primarily through inertia!  impaction, diffusive
deposition,  and  direct interception to  render particle sizes large  enough to
permit high-efficiency collection.  The mixture of collected material  and
scrubbing  liquor is removed from the cleaning device to  minimize reentrainment
of the original  contaminating material.  Spray  chambers, centrifugal  spray
scrubbers, impingement plate  scrubbers, venturi scrubbers,  packed-bed
scrubbers, and centrifugal-fan  wet scrubbers are among the  many types of  wet
collectors used  commercial ly.H> 12
                                    5-11

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     A primary disadvantage of using wet collectors as final-stage gas-
cleaning devices to control asbestos emissions is the apparent low collection
efficiency for submicron particulates.  Some wet collectors; e.g., the venturi
type, can be designed for improved efficiency in collection of submicron
particle sizes, but operating costs become excessive due to the resultant
higher pressure drops across the scrubbers.  Wet collectors also produce a
wastewater discharge.  By 1983,  asbestos-processing plants must have zero
discharge of asbestos-contaminated wastewater.
     Table 5-1 indicates the limited use of wet collectors (scrubbers)  by the
asbestos industry as of 1974.  Table 5-7 shows the number of scrubbers in use
at 13 sites visited during 1981.
     Because of the high energy  requirements of conventional  scrubbers,
especially in collecting submicron particles, alternate  collection forces have
been investigated and applied to augment conventional  scrubbers.  Presently,
two alternatives are available:   electrostatic augmentation and use of
phoretic forces.  Electrostatic  augmentation includes  charged  particle,
oppositely charged droplet; charged particle with image  charge on  droplet;
and charged droplet with image charge on particle.12  phoretic forces  are
active in wet scrubbers when temperature or water vapor  concentration
gradients exist between the particle and droplet environments.^

5.3  ELECTROSTATIC PRECIPITATORS
     In an ESP, a corona is established  between an  electrode maintained at
high voltage and a grounded collecting surface.  Particulate matter passing
through the corona is subjected  to intense bombardment of negative ions that
flow from the high-voltage electrode to  the grounded collecting surface.   The
particles thereby become highly  charged  within a fraction of a second  and
migrate toward the grounded collecting surfaces.13
     ESPs are not used by the asbestos industry to  control  emissions.   High
installation cost and lower collection efficiencies (relative  to those  of
fabric filters) do not make ESPs  attractive for control  of asbestos
emissions.
                                     5-12

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5.4  DEMOLITION, RENOVATION, AND CONSTRUCTION
5.4.1  Demolition and Renovation
     The asbestos national  emission standard requires that all  asbestos
materials be wetted before being stripped or removed during demolition or
renovation.   When temperatures are below 0° C,  the wetting requirement is
suspended because of hazardous conditions that  would result from freezing
water.  Removal  techniques currently available  and in use to an undetermined
extent include:
          Use of wetting agents (amended water),
          Use of barriers,
          Use of HEPA filtered vacuum cleaners, and
          Use of negative air pressure.
Wetting agents added to water enhance its penetration,  reduce the amount
needed, and  generally increase control  effectiveness.14  With the use of
amended water, little water runoff occurs and much is absorbed  by fallen
debris, visible dusting is  rare, and work time  is  halved  because less time is
necessary for airborne asbestos levels  to return to background  levels.15
     Table 5-9 compares asbestos fiber  counts for  three removal  methods.
Concentrations ?n the tables were obtained through the  U.S.  Public Health
Service membrane filter method and represent worker exposure levels.   Fiber
release is substantially reduced with use of amended water over fiber release
encountered  with either dry or wet (and  untreated  water)  methods.  A  wetting
agent of 50  percent polyethylene ester  and 50 percent polyoxyethyl ene ether in
a concentration of 30 milliliters (1 ounce)  in  19  liters  (5  gallons)  of water
was used to  obtain results  shown in Table 5-9.
     Barriers, consisting of polyethylene sheets,  can be  used to avoid
contamination of adjacent rooms and the  surrounding community.*5  Polyethylene
sheets are placed over all  openings surrounding the work  area,  which  can be a
single room  or an entire building.  Barriers can be used  to  reduce
contamination in both dry and wet removal  of asbestos.  Table 5-10 presents
the results  of using two parallel  polyethylene  sheets taped  to  door jambs to
prevent movement of asbestos fibers from the work  area  to an adjoining room
and to an outer room.
                                     5-13

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    TABLE 5-9.   COMPARISON OF METHODS IN REMOVAL OF AN 8- x 12-FOOT CEILING
                                  SECTION^

Dry:
Wet:
Wet:
Method
no preparation
untreated water
amended water

Number of
sampl es
11
6
10
Asbestos fiber counts
Mean
82. 2a
23.1
8.1
(f/cm3)
Standard
deviation
24.7
4.9
4.6
aMembrane filters contained numerous fiber clumps in addition to counted
 fibers.
   TABLE 5-10.   INHIBITION OF ASBESTOS- MOVEMENT BY POLYETHYLENE BARRIERS15
                                  Mean fiber counts (f/cm^)
                  Inner room
Removal method   (demolition)
                   Middle room
                     (entry)
                 Outer room
                  (staging)
Dry

Amended water
74.4

 8.2
6.4

2.0
2.0

0.0
                                     5-14

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     Dry vacuum methods can be used  for rapid  removal  of fallen debris and
decontamination of work areas after  the bulk of asbestos material  is removed.
Passing the vacuum exhaust through a HEPA filter is recommended.14  A HEPA
filtered vacuum will  fail  if used  on wet material,16 preventing its use for
removing wetted debris.  Commercial  vacuum systems  are available for dry and
wet asbestos removal.  Typically,  such  a system is  mounted  on a truck with a
heavy-duty, reinforced vacuum receiving chamber.  The  vacuum  is equipped with
three major filtration devices,  and  the storage section is  equipped with a
sprayer to treat collected dust.  The system uses  exhaust filtration
(including a HEPA filter)  and a  vacuum  blower.
     The negative air pressure method requires  that the work  area  first be
isolated with a system of barriers,  as  previously mentioned.   Fans are
positioned to draw air from the  work area through HEPA filters before the air
is exhausted to outside air.  One  such  system currently available  is
"Micratrap," which is designed specifically  for asbestos removal.   Filter
replacements are $100 each and have  approximately a 1,000-hour operating
life.
     The United States Navy currently is supporting the design,  development,
and construction of asbestos control  chemicals  and  prototype  equipment for
removal  of asbestos thermal  insulation  from  ships.   The technique  involves the
injection of an impregnating fluid into the  insulation; determination of
saturation of the insulation using electrical conductivity; and  application of
a foam or gel  as the  insulation  is cut  for removal.  Trials of the system will
be conducted in actual  shipboard situations.  The method is designed to reduce
fiber levels well below the current  Occupational Safety and Health
Administration (OSHA) limits.
     In certain situations, use  of encapsulants or  sealants offers an
alternative to asbestos removal.   Because encapsulation is  not a control
method to be used during demolition  or  renovation,  it  is discussed only
briefly here.   Encapsulation might be used where a  building is not being
renovated or demolished but where  asbestos insulation  is discovered in the
building and removal  would be extremely difficult.   It would  not apply to
demolition jobs or where asbestos-covered surfaces  are being  removed as part
of renovation.
                                    5-15

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     Sealing sprayed asbestos surfaces involves applying material  that will
envelop or coat the asbestos fiber matrix, eliminate fallout, and  protect
against contact damage.   Sealants  usually are applied to asbestos  surfaces by
spraying and consist of  polymers with an agent added to enhance penetration
into the fiber matrix.   Currently  available sealants include water-based latex
polymers, water-soluble  epoxy resins, and organic-sol vent-based polymers of
various types.14
     Application of a sealant to friable asbestos by spraying will  disseminate
small fibers by contact.   A sealant should be applied with caution  and at the
lowest nozzle pressure possible to reduce contact disturbance.^
     EPA's Chemical  Control  Division, Office of Pesticides and Toxic
Substances, currently is  sponsoring work to study and  evaluate new  or
innovative asbestos removal  methods.   In the first study phase, which is not
complete yet, the availability of  alternative removal  methods is being
investigated.  During the second phase,  various removal  methods will  be
monitored to determine which produce  lower emission levels.
5.4.2  Construction
     In construction, operations that would be expected  to release  fibers into
the atmosphere (e.g., cutting A/C  pipe or sheet,  removal  of  built-up roofing,
and others) generally do  not occur 8  hours a day, 5 days  a week.17   Potential
emission sources include  installation of A/C pipe, A/C sheet,  A/C
architectural  panels, and built-up roofing.
     Local  exhaust ventilation (LEV)  systems connected to  a  vacuum  source are
available for power grinding, sanding, cutting, and drilling  tools.   However,
because these tools cannot endure  field  conditions, they  are  not used in
significant numbers by the construction  industry.1? Furthermore, the
effectiveness of the LEV  systems is closely associated with operator
techniques and the geometry of the LEV's hood.   LEV's  effectiveness  may
decline drastically if the hood  is damaged,  which is likely  in  field  use of
such equipment.17  The cost associated with a LEV system  and  vacuum  unit for  a
circular saw ranged from  $1,400  to $3,000,  according to  a  technological
feasibility study.17 The efficiency  of  the vacuum unit  associated  with LEV
depends on the vacuum filtering  system.   Vacuum systems  are  available with
HEPA filters and would be expected to have high dust control  efficiencies.
                                     5-16

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Vacuum filters have been developed  that  are capable of collecting 99.97
percent of all dust down to the 0.3-  to  0.5-micrometer particle size range.18
     Alternatives to power tools exist  for field  cutting  and machining A/C
pipe.  Field cutting tools especially designed  for A/C pipe  are available,
which may be hand operated or driven  by  electric,  gasoline,  or pneumatic
motors.  A study of worker exposure to  asbestos using  manual  machining lathes,
snap .cutting equipment, a hack saw, and  a  tapering tool  showed that worker
exposure levels were below 0.5 f/cm^  (>5 micronmeters  long,  National  Institute
of Occupational  Safety and Health [NIOSH]  method).19   These  tools are already
used by some contractors installing A/C  pipe and  result  in little lost
productivity compared to losses generated  by a  shrouded circular saw, which
requires additional  time and skill  on the  part  of  the  employee to, perform.!7
In 1978, the cost of machining tools  ranged  from $350  to $1,500 (depending on
size range)  and the cost of cutters ranged  from $900 to $1,300.
     Wet cutting is a control  technique  that injects water onto the contact
point between the saw blade and the product  being  cut; however, there is no
indication that this method has been  used  under field  conditions.17

5.5  SUBSTITUTES
     Detailed assessments of the economic  and technical potential  have been
performed recently for many nonasbestos  substitute materials.l7»20,21   such an
assessment will  not be repeated here; rather, the  status of  substitutes will
be summarized.
     Substitutes for asbestos products have  been operating in  the  market place
for several  years and substitute materials are  available for many
applications.  However, no substitute material  currently is  able to replace
asbestos in  all  of its applications.  Where  substitutes are  available, they
may be more  costly and le.ss desirable than asbestos.   Factors  that have
encouraged the search for suitable  substitutes  include:
          Significant price increases for  asbestos;
          Significant worldwide shortage of  asbestos fiber,
          Concerns regarding health effects  of  exposure to asbestos,
          Health concerns regarding use  of certain asbestos-containing
          products (e.g., drywall spackling  compounds),
                                    5-17

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          Administrative burdens imposed by OSHA's current standard for
          occupational  exposure to asbestos,
          Increased workers'  compensation costs,
          Increased incidence of common law product liability suits,
          Increased difficulty in obtaining product liability insurance
          coverage, and
          Increased adverse publicity regarding health effects of asbestos.17
Added to this list should be increasing regulations by several Federal
agencies.  It should be mentioned that concern exists that any substitute will
pose its own  health hazards to the producing industries and to the product
users.
     Listed below are the asbestos-containing products judged, in one study,
to face competition from nonasbestos  substitutes:
          Vinyl/asbestos (V/A) resilient flooring
          Roofing felt
          Transmission  paper
          Filter paper
          Electrical wire wrapping tape
          Industrial laminates
          Decorative laminates
          Millboard and roll board
          Commercial paper
          Disc brakes for automobiles  and light trucks
          A/C pipe
          A/C sheet
          Reinforced plastics
          Coatings, paints, and sealants
          Gaskets and packings not for high-temperature  applications
          Thermal  insulation
          Drilling fluid additives
          Asphalt paving cement
          Shotgun shell  wadding
          Joint  cements and patching  compounds.20
Five asbestos-containing products judged to  face no market  competitors  in  an
economic sense included:
          Pipe!ine wrap,

                                     5-18

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          Electrolytic cell  diaphragms,
          Electrical  paper,
          Drum brake shoes for automobiles and light trucks, and
          Gaskets and packing for high-temperature applications.20
Some qualifications are needed here.   For example, some automobiles and light
trucks are equipped with four-wheel  disc braking systems that are asbestos
free.20
     The competitiveness of  substitutes for two asbestos-product categories,
metal  lining paper and textiles,  could not be determined clearly based on
available data.20

5.6  REFERENCES
1.    Harwood, C. F.,  P. Siebert,  and  T. P. Blaszak.  Assessment of Particle
     Control Technology for  Enclosed  Asbestos Sources.   Office of Research and
     Development, U.S. Environmental  Protection Agency.   Research Triangle
     Park, North Carolina.  EPA-650/2-74-088.  October  1974.   126 p.
2.    Ariman, T., and  D. J. Helfritch.  Pressure Drop in  Electrostatic Fabric
     Filtration.  In:  Second Symposium on the Transfer  and Utilization of
     Particulate Control  Technology.   Volume III.   Particulate Control
     Devices, Venditti, F. P, J.  A.  Armstrong, and M. Durham  (ed).  Research
     Triangle Park, Industrial  Environmental  Research Laboratory, Environmental
     Protection Agency, EPA-600/9-80-039c.  September 1980.  p. 222-236.
3.    Rymarz, T. M.  How to Specify Pulse-Jet Filters.   In:   Industrial  Air
     Pollution Engineering,  Cavaseno, V.  (ed).  New York,  McGraw-Hill
     Publications Company.  1980.   p. 197-200.
4.    Frederick, E. R.  Fibers,  Electrostatics, and Filtration:  A Review of
     New Technology.   Journal of  the  Air Pollution Control  Association.
     30:426-431.  April  1980.
5.    Lamb, G.  E. R.,  and  P.  A Costanza.  A Low-Energy Electrified Filter
     System.  Filtration and Separation.   July/August 1980.  p. 319-322.
6.    Van Osdell, D. W., G. P. Greiner, G.  E.  R. Lamb, and  L.  S. Hovis.
     Electrostatic Augmentation of Fabric  Filtration.   In:   Third Symposium on
     the Transfer and Utilization of  Particulate Control  Technology.
     Research Triangle Park, Environmental  Protection Agency.  March 9-12,
     1981.   10 pp.

                                     5-19

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7.   Goldfield, J., V.  Greco, and K. Gandhi.  Glass Fiber Mats to Reduce
     Effluents from Inudstrial  Processes.  Journal of the Air Pollution
     Control  Association.  2^:466-469.  July 1970.
8.   Goldfield, J., and K.  Gandhi.  Influence of Fiber Diameter on Pressure
     Drop and Filtration Efficiency of Glass  Fiber Mats.  Journal of the Air
     Pollution Control  Association. J33J95-97.  January 1981.
9.   Siebert, P- C., T. C.  Ripley, and C. F- Harwood.  Assessment of Particle
     Control  Technology for Enclosed Asbestos Sources—Phase II.  Office of
     Research and Development,  U.S. Environmental  Protection Agency.  Research
     Triangle Park, North Carolina.  EPA-600/2-76-065.   March 1976.  125 p.
10.  Jones, D. R.  Optimizing Baghouse Performance to Control Asbestos
     Manufacturing Source Emissions (draft).  ITT Research Institute.
     (Prepared for Industrial Environmental  Research Laboratory, U.S.
     Environmental Protection Agency.   Cincinnati, Ohio.)   EPA Contract Number
     68-03-2558.  1980.  64 p.
11.  Office of Air Quality  Planning and Standards, U.S.  Environmental
     Protection Agency.  Control  Techniques for Asbestos Air Pollutants.
     Research Triangle Park, North Carolina.  EPA Publication Number AP-117.
     February 1973.
12.  Genoble, A. L., R. L.  King,  and J. L.  Pearson.   Scrubber Emissions
     Correlations.  Engineering-Science.  (Prepared  for Stationary Source
     Enforcement, U.S.  Environmental Protection Agency.   Washington,  D.C..)
     EPA Contract Number 68-02-4146, Task Order 49.   December 1979.
13.  National Air Pollution Control Administration.   Control  Techniques for
     Particulate Air Pollutants.   Publication No.  AP-51.   Washington, D.C.
     January 1969.  215 p.
14.  Sawyer,  R. N., and C.  M. Spooner.  Sprayed Asbestos-Containing Materials
     in Buildings:  A Guidance  Document.  Yale University and GCA Corporation.
     Office of Air Quality  Planning and Standards, U.S.  Environmental
     Protection Agency.  Research Triangle Park, North  Carolina.
     EPA-450/2-78-014.   March 1978.  133 p.
15.  Sawyer,  R. N.  Asbestos Exposure  in a Yale Building.   Environmental
     Research.  13:146-169.  1977.
                                     5-20

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16.  Office of Toxic Substances, U.S. Environmental Protection Agency.
     Asbestos-Containing Materials in School Buildings:  A Guidance Document.
     Part 1.  Washington, D.C.  March 1979.  64 p.
17.  Wright, M. D., et al.  Asbestos Dust Technological Feasbility Assessement
     and Economic Impact Analysis of the Proposed Federal Occupational
     Standard.  Part I:  Technological  Feasbility and Economic Impact
     Analysis.  Research Triangle Institute.  (Prepared for Occupational
     Safety and Health Administration,  U.S. Department of Labor.  Washington,
     D.C.)   NTIS No. RTI/1370/02-01-F.   September 1978.
18.  The Nilfisk GA73 Vacuum Cleaner.  Asbestos.  April 1976.
19.  Equitable Environmental Health, Inc.  Dust Exposure During the Cutting
     and Machining of Asbestos/Cement Pipe.  Additional Studies.  (Prepared
     for the A/C Pipe Producers Association.  Arlington, Virginia.)  December
     15, 1977.
20.  Kendall, D.  L,  et al.  Economic Impact Analysis of Controls on Certain
     Use and Exposure Categories of Asbestos (draft).   Reserach Triangle
     Institute.  (Prepared for Office of Toxic Substances,  U.S. Environmental
     Protection Agency.  Washington, D.C.)   November 1980.
21.  Cogley, D.,  et al.  Asbestos Substitute Performance Analysis (draft).
     GCA Corporation.  (Prepared for Office of Toxic Substances, U.S.
     Environmental  Protection Agency.  Washington, D.C.)  March 1980.
                                     5-21

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                          6.   SAMPLING AND ANALYSIS

6.1  SAMPLING  CRITERIA
     Battelle-Columbus Laboratories  studied the feasibility  of developing
asbestos source  sampling  methods and established criteria  (summarized in
Tables 6-1  and 6-2)  necessary for an asbestos  source sampling  method.  The
first two criteria listed in  Table 6-1 place the following constraints  upon
the sampling method':   the overall  collection efficiency  must be known over the
fiber diameter range and  sufficient  numbers of fibrils and fibers  must  be
collected simultaneously  by the  same mechanism to eliminate  the need  for fiber
size separation.^
     The production  process and  applied control  technology will  affect  the
ability to  collect a time-integrated sample.  Battelle indicated that the
number, concentrations, and size of  the fibers may vary  throughout the
production  processes.   This characteristic and the fact  that baghouses  often
mix the various  process emissions (depending upon the design of the control
equipment)  and emit  particles having a smaller mean size than  most process
emissions affect sample concentrations and the ultimate  determination of the
sampl ing method.
     To obtain a sample from  the local  environment, the  sampling method must
be flexible enough to  adapt to several  variable occurrences:
          Stack  environments  in  which air flow is controlled,  uncontrolled
          emission environments  (i.e.,  ventilation air leaving plants;  indoor
          plant  air  escaping  from doors or windows; or outdoor emissions from
          mining,  transport,  and disposal  operations);
          Temperature,
          Relative humidity,
          Air  flow velocity,
          Temporal  variations of environmental characteristics, and
          Physical  accessibility.
                                     6-1

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    TABLE 6-1.  CRITERIA FOR A SOURCE SAMPLING METHOD FOR ASBESTOS
            FOR THE ACQUISITION OF A REPRESENTATIVE SAMPLE


Ability to collect asbestos over the diameter range 0.03 < Df < 10 um
  covering fibrils and fibers for determining number and mass
  concentration by counting techniques

Ability to collect asbestos fiber bundles over the diameter size range
  0.2 um to several tens of micrometers for determining number
  concentration by counting

Ability to collect a time-integrated sample

Ability to extract a sample from the local  environment
                                 6-2

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             TABLE 6-2.  CRITERIA FOR A SOURCE SAMPLING METHOD FOR ASBESTOS TO BE COMPATIBLE WITH THE
                                  ANALYTICAL METHOD FOR ASBESTOS DETERMINATIONS
                 Compatible with the provisional method
            Stricily compatible                        Compatib1e
            with recommendations                    with alternatives
                                                                                   Compatible  with
                                                                                 electron microscopy
en

CO
Sample must be collected
  uniformly over a  0.4-Mm
  pore size polycarbonate filter

Collection filter must  have
  an asbestos loading in  the
  proper range for  counting

Collection method is air
  filtration

Collection medium is 0.4  pin
  pore size polycarbonate
  filter material
    Collection of nonasbestos
      matter must be minimized

    Special care in the handling
      of polycarbonate filters
      must be exercised

    Fiber bundles must be collected
      for counting
                                               Capability to take the collected sample, alter it
                                                 (e.g., by"ashing), and obtain a uniform dispersion
                                                 on a polycarbonate filter is required

                                               Capability of obtaining an asbestos loading on a
                                                 polycarbonate filter in the proper range for counting
                                                 is required
Collection method is air
  filtration

Collection medium is 0.4 MID
  polycarbonate or cellulose
  acetate filter material
                                  Collection method is not
                                    limited to air filtration

                                  Collection medium is not
                                    specified; however, it must
                                    be compatible with a
                                    procedure to transfer the
                                    collected asbestos to an
                                    em grid

Capability to reduce the collected nonasbestos material (e.g.,
  by ashing)  must be available

Polycarbonate filters are not necessarily required for field
  use
                                                                             Counting  of fiber bundles is
                                                                               not  necessarily required

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6.2  CURRENT SAMPLING METHODS

     Battelle reviewed sampling methods that have been used to obtain asbestos

emission samples and methods that have been based upon EPA's Method 17;2 e.g.,

the Canadian standard reference method-^ and the EPA-recommended method that

was used for emission testing of an iron ore beneficiation plant.4  Methods

based on EPA sampling methods for new stationary sources were also

reviewed.455,6,7  Battelle described the method used by Harwood, Oestreich,

Siebert, and Blaszak to sample asbestos emissions from baghouse-controlled

sources including two asbestos/cement (A/C) plants, two mills, and one

asbestos textile pi ant.8  The following comments concern each of the methods

reviewed by Battelle and are excerpted from that report.

          The Canadian standard reference method specifies an in-stack filter
          in a sampling train that is essentially equivalent to Method 17.
          The filter holder and filter must be capable of withstanding
          temperatures up to 200° F.  A cellulose membrane filter with 0.8
          micrometer pore size is required.  The probe must have a heating
          system capable of maintaining the temperature of the gas at the exit
          end of the probe high enough to prevent condensation.

          EPA has recommended a method for sampling asbestos emissions,  which
          is also based on Method 17.  Inasmuch as asbestos emissions are not
          affected by temperatures below 300° F, the collection  temperature of
          250° F for total particulate sampling need not be maintained.
          Particulate matter may contain condensible material  such as
          asbestos.   Relaxation of this constraint eliminates the necessity of
          employing a glass probe and heating system; therefore, the distance
          travelled by the fibers going from the stack environment to the
          filter is reduced.  Because heating is eliminated, this method is no
          longer suitable for environments containing saturated  water vapor or
          liquid drops.

          Sampling conducted at iron ore beneficiation plants for fiber
          emissions has used both in situ and extractive sampling.   Extractive
          sampling was used at a dock pellet storage silo ventilator stack
          because saturated conditions existed in the stack.  The sampling
          train was heated from the inlet through the 47-millimeter
          polycarbonate filter.  Sampling of the baghouse exhausts from  the
          ore car dump, fine crusher, and fine crusher conveyor-to-
          concentrator storage silos was accomplished by in situ filtration.
          Except for one test using a cellulose-acetate filter,  all  tests were
          conducted using a 47-millimeter polycarbonate filter.   Sampling
          duration ranged from 15 seconds to 7 minutes, depending upon
          expected loading.

     Fugitive emission sampling methods also have been the subject of two EPA

reports reviewed by Battelle.9,10  Battelle summarized the commonly used

strategies in the following comments:

          Fiber emission measurements also have been made for pelletizinq
          operations.  Temperatures at the four locations encountered in
          Reference 8 ranged from 100° to 225° F.  Deviations from Method 1 to
          5 include (1) use of a 115-millimeter cellulose acetate filter
          instead of a glass fiber filter, (2) maintenance of 180° F for the
          sampling probe and heated filter, and (3)  installation of a glass
          cyclone in the heated filter box ahead of the filter to remove some
                                     6-4

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          particulate material.   A temperature  of 180°.i-  was  chosen, after
          deterioration of the cellulose acetate  material  was detected ai
          200s F.

          Measurements of asbestos emissions  from baghouse-controlled sources
          have been taken by extractive sampling  systems  placed  upstream of
          the baghouses.  Samples were drawn  through  a  cyclone prior to
          filtration by a 10-centimeter, 0.8-micrometer pore  membrane filter.
          The cvclone was not used on the downstream  side.   In some instances,
          sampling locations for extractive isokinetic  sampling  were
          inaccessible.  High-volume samples  with a membrane  filter were used
          within the baghouse for downstream  measurements.  A recent study
          suggests sampling simultaneously using  three  filters at  different
          flow rates in an attempt to ensure  proper loading.

          The quasi-stack method that involves  capturing  the  entire emission
          stream with an enclosure or hood and  sampling  these confined
          emissions with standard stack sampling  techniques.

          The roof-monitor method that involves measuring the emissions by
          traverses across well-defined openings  such as  ventilators, windows,
          and access doors.

          The upwind-downwind method that involves measuring  upwind and
          downwind concentrations using ground-based  sampling.   Source
          strength is calculated using a diffusion model measured  by
          meteorological parameters.

          The exposure-profiling method that  involves direct  measurement of
          particle flux downwind of a source  by simultaneous  multipoint
          sampling over an effective cross section of the fugitive emission
          plume.  The sampling condition must be  isokinetic.

     The most common methods for monitoring asbestos  emissions use high-volume

filtration with membrane filters.  This type  of filtration  is  consistent with

EPA's recommended  sampling procedure for its  published  provisional  method.H

     In reviewing  the literature, Battelle found  that passive samplers have

been used to collect particulate matter for particle  flux measurements.

However, they reported that although such samplers meet  environmental

constraints, an additional constraint on the  amount of  sample collected is

imposed upon the sampler by virtue of its design.  That  is, sampling volume is

limited by the product of the effective cross section of the  sampler and the

prevailing air velocity.  A separate, continuous  record  of  local air velocity

must be maintained to measure airborne concentration, as  opposed to particle

flux.


6.3  ANALYTICAL METHODS

     Three acceptable approaches are available  for analyzing  airborne asbestos

fibers.  Optical methods, which  are limited by  fiber  lengths  of  5  micrometers,

depend upon morphological recognition and optical crystallographical

techniques.12  Electron microscopy methods are  capable  of examining fibers in
                                     6-5

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sizes less than 0.1 micrometer in diameter.  The third approach involves
physical  analytical methods; these methods are limited to mass measurements.
6.3.1  Optical  Methods
     The National Institute for Occupational  Safety and Health (NIOSH), the
Province of Ontario, and the Asbestos International Association have endorsed
the optical phase contrast microscopy method.  Slight variations appear in
each procedure, although each method requires that the cellulose ester filter
used in the sampling train be treated with solutions having proper refractive
indices to render the membrane filter transparent.  The procedure continues
with counting and sizing fibers according to morphological  characteristics.
This method's major disadvantage is that it is nonspecific to asbestos and can
be used only to count fibers greater than 5 micrometers in length.
     Polarizing microscopy also can be used,  although it is used more often by
geologists and mineralogists to identify asbestos in bulk samples.^  Stephen
Becket summarized that this method uses the asbestos molecule polarizability,
which varies along different rotational axes.
6.3.2  Electron Microscopy
     Environmental asbestos emissions commonly are fibers less than 1
micrometer in diameter; therefore, optical methods of analysis have limited
usefulness.  Scanning electron microscopy (SEN)  and transmission electron
microscopy (TEM) provide greater magnification and resolution than do optical
methods for fiber identification, counting, and  sizing and  are used
extensively to examine asbestos fibers.
     SEM methods are comparable to reflected  light microscopy but  form images
electrooptically.14  Although sampling strategies generally are not
constrained by this analysis, Beckett recommends use of Nuclepore  filters
(polycarbonate filters).15  Cellulose ester membrane filters  may be used  and
are recommended if analysis by both optical and  electron microscopy is
required.  However, these fibers must be ashed,  dispersed,  and remounted  for
the electron microscope analysis.  In addition,  some workers  have  expressed
concern over fiber degradation, fracturing, or other alterations that might
occur during ashing.15  Although other workers have argued  that the smooth
collection surface of Nuclepore filters does  not adhere to  particulate
material  during handling and transferring, EPA's provisional  method specifies
the use of this filter.
                                     6-6

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     After sampling, the filters are mounted onto stubs and shadowed with gold
or carbon to give the fibers a conducting surface.  Once mounted, electrons
scan the specimen from which secondary electrons are emitted.  These secondary
electrons are amplified and displayed as intensity modulation on a cathode ray
tube.  The resulting image appears almost three dimensional.  When the
scanning electron microscope is equipped with X-ray analytical instruments,
X-rays emitted from particles can be analyzed either by corresponding energies
or wavelengths.  Therefore, pictures of fibers can be produced with the X-ray
spectrum, enabling identification of differing asbestos types.^
     Rajhans and Sullivan outlined the advantages of the SEM method:   actual
fiber size distribution is preserved, analysis is rapid, and large segments of
a filter can be examined.  They found that disadvantages outweighed advantages
in that underlying fibers are not detected,  fibers are lost through Nuclepore
membranes, stray X-rays may provide confusing results, analysis  of fibrils is
difficult, and the X-ray spectrum may not discriminate between some
asbestiforms.16
     TEM methods are capable of examining fibers 0.1 micrometer  in diameter.
TEM's imaging capabilities are superior to those of SEM.  Sampling techniques
are not constrained; however, TEM is similar to SEM because filter selection
may change preparation and mounting procedures slightly.
     Small pore size filters frequently are  preferred; however,  sizes  of 0.8
micrometer have been used successfully.^  $o0n after sampling,  Nuclepore
filters are coated with carbon.  Collected dust-containing fibers  is  then
transferred to the TEM grid either by the modified Jaffe-wick  technique
recommended by EPA^- or by condensation washing.  Transmission electron
microscopes can be equipped with energy-dispersive spectrometers,  which
provide resolution morphology, crystal  structure, and elemental  composition of
fibers.
     TEM can be used to provide selected area electron diffraction (SAED)
patterns in which scattered electrons at specific angles are focused  at a
single point in the image plane.  The image  produced on a fluorescent  screen
is relative to the crystal  structure of the  asbestos molecule, and the  pattern
obtained from an isolated particle is theoretically that of a  single
crystal.17  SAED patterns are similar for each fiber type; therefore,  TEM/SAED
                                     6-7

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methods are capable of characterizing crystal structures of amphibole and
chrysotile asbestos and other crystalline mineral particles.  However,
chemical analyses may be required in addition to TEM/SAED analysis of some
amphibole structures because some patterns are not readily distinguishable.
TEM/SAED analysis also may present problems with identifying fibers as small
as 20 nanometers and with fibers that are too long.l?
     Patterns resulting from chrysotile are unique because they exhibit
prominent layer line spacings.  However, only 20 to 50 percent of the sampled
chrysotile fibers provided the correct layer line spacing and less than 15
percent demonstrated the unique chrysotile SAED pattern.8
     A scanning transmission electron microscope that combines the advantages
of TEN and SEM19 -js available.  This instrument is used in laboratories
specifically for asbestos fiber counting and identification.  This
transmission electron microscope allows the electron beam to scan the sample
and to focus on a particular point.   The technique generally is applied to
obtain a shadow image like that obtained with TEM and either a diffraction
pattern or X-ray spectrum as needed.
6.3.3  Physical and Chemical Analysis
     Several methods have been developed to obtain mass measurements  of
airborne dust-containing asbestos.  However, mass measurements do not
distinguish between masses of asbestos and other dust, nor do they define size
characteristics directly related to  the reported health effects.   X-ray
diffraction and infrared spectroscopy have been used to analyze airborne
asbestos-containing dust.21
     6.3.3.1  X-ray Diffraction Analysis.   Rajhans and Sullivan reported  that
various investigations have performed quantitative analysis  of asbestos  in
filter samples by X-ray diffraction.  In 1969,  Goodhead and  Martindale
developed methods to determine milligram quantities  of amosite and chrysotile
in airborne dusts by X-ray analysis.  In 1971,  Richards and  Badomi
demonstrated X-ray  methods to determine chrysotile with detection limits  as
low as 10 micrometers.  Lange and Haartz have developed X-ray analytical
methods for microgram quantities of  chrysotile  asbestos deposited silver
membrane filters with detection limits of  2 micrometers.21
     Rajhans and Sullivan summarized the general  steps to be taken for
analysis of environmental  samples:

                                     6-8

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          The sample filter is ashed and placed in a lithium-glass capillary
          tube.   The tube is placed in  the oath of a collimated X-ray oeam,
          rotated to increase the probability that each plane in the .  .
          crystalline material is at some time in the diffracting position,
          and photographed.

          The filter can be placed directly in the path of the X-rays by
          cutting a section from the sample filter and fastening it to  a  piece
          of glass cut from a microscope slide coated with a thin film  of
          adhesive (lacquer).  The layer of lacquer may cause some scattering
          and a  small loss in X-ray intensity.  After mounting, the glass
          slide  is attached to the sample holder in the diffractometer  with  a
          spring clip.  Alternatively,  an unadulterated sample filter can be
          held flat on the sample stage by suction applied through an array  of
          shallow grooves communicating with a central  vacuum port.

          The filter is ashed and the fibers are electrostatically aligned
          parallel to one another and embedded in a thin plastic film.

     6.3.3.2  Infrared Spectrophotometric Analysis.  In 1975, Becket,

Middleton, and ~r>dgson found that infrared (IR) spectrophotometry can be  used

to estimate small  quantities of single  varieties of asbestos.^0  Therefore,

substances other than chrysotile on prepared sample disks may interfere with

mass determinations of asbestos.  However, in 1979, Heidermanns reported  an  IR

method for determining mass of chrysotile asbestos collected on a vinyl

chloride membrane filter.  Raj nans and  Sullivan summarized the procedure,

which eliminates errors associated with ashing filters:22

          The required amount of sample (about 4 milligrams)  for IR analysis
          is obtained by punching circular filter sections of known diameter.

          The required number of filter sections is transferred to a
          centrifuge tube, and acetone  is added to dissolve the filter  matrix.
          The result is a fine dust suspension in acetone.

          The suspension is centrifuged for 10 minutes  with an oscillating
          rotor  at 13,000 cycles per minute.  The fine  dust is deposited  on
          the bottom of the centrifuge  tube.

          Excess solvent is siphoned off by using a suction tube, fitted  with
          a frit.

          The residue on the bottom of  the tube is dispersed in the remaining
          acetone and quantitatively transferred onto a glass filter by
          rinsing with pure acetone. After the solvent evaporates, the glass
          fiber  filter, containing the  fine asbestos dust, is dried for
          subsequent pellet preparation.

          The B=KBr pellet is prepared  by drying the glass fiber filter and
          transferring it with 600 milligrams dry KBr to a steel  cylinder for
          subsequent grinding to yield  a homogeneous KBr asbestos mixture.

          IR absorption bands are measured for quantitative determination.
          The characteristic double bond at 3.660 or 3,700 cm"1 has been  used.
          A linear correlation has been reported between extinction and
          asbestos concentration in the range of 1 to 3 milligrams chrysotile
          asbestos per 150 milligrams KBr.

          Heidermans reports a detection sensitivity of 20 micrometers.
                                     6-9

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6.4  OTHER SAMPLING AND ANALYSIS METHODS

     Direct reading instruments are readily available on the market for

instantaneous measurement of airborne dust.  The instruments usually employ

light-scattering principles and they normally record all airborne dust,

regardless of its composition.

     One such instrument is the Fibrous Aerosol Monitor, Model  FAM-1,

developed by GCA Corporation under contract to NIOSH with partial funding from

the U.S. Bureau of Mines and EPA.  The following excerpt from Rajhans

and Sullivan's book on asbestos sampling describes the instrument.

     The instrument draws air from the environment into a sensing tube at a
     rate of 2 liters/min.  A laser beam from 2mW He-Ne laser shines down the
     tube.  The beam volume intersects a region observed by a photomultiplier
     detector.  Particles that enter the detection volume can scatter light
     into the detector.  A high voltage electric field is applied to the
     detection volume and this field aligns elongated particles  such as fibers
     perpendicular to the axis of the laser beam.  Light is then scattered
     from the fibers preferentially in a direction normal to the fiber s long
     axis.  The electric field is rotated or rocked so that the  fiber produces
     a series of scattered light pulses as it passes through the detection
     volume.  These pulses are converted to electrical  signals  and are
     amplified and analyzed by the electronic detection system.   Two variables
     relating to pulse shape are measured in order to determine  whether a
     signal is due to a fiber.  These two variables are the ratio and the
     amplitude and reflect the pulse sharpness and its height.   Ratio and
     amplitude threshold settings are determined by dial settings on the panel
     of the instrument.  Once these settings have been established,  all
     signals meeting the threshold requirements will be counted  as fibers-.
     The higher the threshold settings', the lower the count rate and the
     higher the noise discrimination of the instrument.

     Total fiber concentration range is from 0.0001 to 30 fibers per cubic

centimeter for fibers greater than 0.2 micrometer in diameter and 2

micrometers or greater in length.

     This instrument has been evaluated by comparison with the  NIOSH sampling

and analysis method for work place exposures; its use for emission sampling

has not been tested or evaluated.  However, review data reported by  the

Illinois Institute of Technology Research Institute (IITRI) on baghouse

emissions (see Subsection 3.5) indicated this instrument would not have

counted 10^ fibers having lengths less than 1.5 micrometers emitted  from the

baghouses.

     The Royco photoelectric particle counter and the Rathero Mitchell  P3

count particulates by using light-scattering principles.  The Royco  counter

tested in a chrysotile asbestos plant for particles with lengths of  5

micrometers showed counts 25 percent lower than those determined by  membrane

filter methods.  A 15-percent increase over the counts obtained  by membrane
                                     6-10

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fiber methods was found when the Royco counter was set at 4 micrometers.23
The Rathero Mitchell P3 was found unsuitable for monitoring low dust
concentrations.23
     Other methods have been developed whereby fibers are counted by first
collecting fibers on membrane filters, aligning the fibers either parallel or
normal to a magnetic field, and measuring scattered light.  However, there
are no indications that these instruments have been used to test for asbestos
emissions.

6.5  BULK SAMPLE ANALYSIS
     EPA describes three reliable methods whereby asbestos fibers can be
identified from bulk samples:  petrographic microscopy.  X-ray diffraction, and
electron microscopy.24
6.5.1  Petrographic Microscopy
     The petrographic microscope is the same as a polarized light microscope,
which is widely used in the geological and chemical  sciences to identify and
characterize crystalline substances based upon their optical  and
crystallographic properties.  Techniques are well  established  and equipment  is
relatively low in cost.  The method is effective for identifying the
particular mineral species present.  A possible drawback in the use  of
petrographic microscopy is the high level of skill  and experience required of
the microscopist.  Bulk sample optical microscopy involves the ability to
adequately search a sample and successfully recognize and identify the suspect
material.  However, an experienced microscopist should be able to locate and
identify even small amounts of asbestos in bulk samples.
     EPA is in the process of publishing its method  of analysis for  asbestos
in bulk samples using polarizing light microscopy.   The  method sets  down six
criteria to positively identify chrysotile asbestos.   This method is limited
to samples containing 1 percent or more of asbestos.   The identification is
limited to resolution of the polarizing light microscope, which is capable
of resolving fibers having a length of 2 micrometers, and a diameter of
approximately 0.5 micrometer.  Classical  methods using refractive index oils
and dispersion staining methods can be applied.
                                     6-11

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6.5.2  X-Ray Diffraction
     In this technique, which is also described for emission sample analysis,
X-rays are diffracted by a small sample of the suspect material and a pattern
uniquely characteristic of any crystalline material present is produced.  With
some instruments, a permanent diffraction tracing is produced.  This method
requires significant investment in equipment, references, mineral  standards,
and technical expertise.  In routine examinations, X-ray diffraction of bulk
samples may fail to detect small concentrations of asbestos, and other
silicates or crystalline phases may significantly interfere with accurate
identification.  However, the technique usually yields information with a high
degree of diagnostic reliability and a printed record.  X-ray diffraction
usually is used as a confirmation of petrographic microscopy impressions and
not as a screening procedure.
6.5.3  Electron Microscopy
     Specific and accurate fiber identification can be achieved by examining
the structure of individual fibers or fibrils, especially if this  examination
is used in conjunction with electron diffraction or energy-dispersive X-ray
analysis.  However, extrapolation of precise electron microscope data to
significant bulk sample information is inefficient and costly.   Use of these
data in identification usually is confined to resolving ambiguities raised by
petrographic microscopy and X-ray diffraction.  Primary use of the
electron microscopy technique is in examination of air samples, which is
described in Subsection 6.3.
6.6  AVAILABILITY OF EMISSION DATA
     Few data that characterize asbestos emissions in terms of number, mass
concentration, or size distribution concentrations are available.   Some
engineering estimates for yearly asbestos emissions from industrial  sources
have been attempted to describe overall  environmental  exposure to  asbestos.
However, estimates have not been provided for all  sources,  nor have they been
evaluated by monitoring.  Emission data most often provided in the literature
are also provided in the earlier chapter of this report.
                                     6-12

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6.7  REFERENCES
1.   Battelle Columbus Laboratories.  Discussion of Technical Progress.
     January 1981.
2.   U.S.  Environmental Protection Agency.  Determination of Particulate
     Emissions from Stationary Sources (In-Stack Filtration), Standards of
     Performance of New Stationary Sources.  Federal Register.  43J37):
     7584-7596.  February 23, 1978.
3.   Fisheries and Enviroment Canada.  Standard Reference Methods for Source
     Testing.  Measurement of Emissions of Asbestos from Asbestos Mining and
     Milling Operations.  EPS 1-AP75-1.  December 1976.
4.   Clayton Environmental  Consultants.  Iron Ore Beneficiation—Emission
     Test Report, Reserve Mining Company, Silver Bay- Minnesota.  EMB Report
     78-10B-5.  (Prepared for U.S. Environmental Protection Agency.  Research
     Triangle Park, North Carolina).  1979.
5.   U.S. Environmental Protection Agency.  Standards of Performance for New
     Stationary Sources.  Federal Register.  _43(160):41776-41782.  August
     18, 1977.
6.   U.S. Environmental Protection Agency.  Standards of Performance for New
     Stationary Sources.  Federal Register.  _45_(160) :41755-41758.  August
     18, 1977-
7.   Reference 6, p.  41,758-41,768.
8.   Oestreick, D. K., C. F. Harwood, P.  Siebert, and T. P. Blaszak.
     Assessment of Particle Control Technology for Enclosed Asbestos Sources.
     EPA-650/2-74-088.  October 1974.
9.   Kalika, P. W., R. E. Kenson, and P.  T. Bartlett.  Development of
     Procedures for the Measurement of Fugitive Emissions.   U.S. Environmental
     Protection Agency.  EPA-600/2-76-284.  December 1976.
10.  Measurement of Fugitive Particulate.  In:   Second Symposium on Fugitive
     Emissions:  Measurement and Control.  Houston, U.S. Environmental
     Protection Agency.  May 1977.  EPA-600/7-77-148.  December 1977.
     p.  47-62.
11.  Electron Microscope Measurement of Airborne Asbestos Concentrations; A
     Provisional  Methodology Manual.  EPA-600/2-77-178.  Revised June 1978.
                                     6-13

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12.  Beckets, S. T.  Monitoring and Identification of Airborne Asbestos.   In:
     Asbestos, Michaels and Chissick (ed.).  John Wiley and Sons.   1979.
     p. 236.
13.  Reference 12, p. 238.
14.  National Bureau of Standards.  Proceedings of Workshop on Asbestos, July
     18-20,  1977-  November 1978.  p. 222.
15.  Reference 12, p. 239.
16.  Rajhan, Gyan S., and John L. Sullivan.  Asbestos Sampling and Analysis.
     Ann Arbor Science.  1981.
17.  Reference 16, p. 237.
18.  Reference 14, p. 249-268.
19.  Reference 14, p. 222.
20.  Reference 12, p. 240.
21.  Lange, B. A., and J. C. Haartz.   Determination of Microgram Quantities of
     Asbestos by X-Ray Diffraction:  Chrysotile in Thin Dust Layers of Matrix
     Material.  Analytical Chemistry.  _51_(4):520-525.  April 1979.
22.  Reference 17, p. 181.
23.  Reference 12, P. 231.
24.  Sawyer, Robert N.  Asbestos-Containing Materials in School  Buildings:   A
     Guidance Document.  EPA-450/2-78-014.  March 1978.
                                     6-14

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             7.  HUMAN HEALTH EFFECTS ASSOCIATED WITH INHALATION
                                 (Jr
7.1  INTRODUCTION
     Exposure to asbestos is associated with increased risk of many diseases,
including pulmonary fibrosis (asbestosis), respiratory cancer, and
mesothelioma of both pleura! and peritoneal  tissue.  These health effects have
been documented in over 90 studies conducted by many researchers using
different groups of occupational workers.i  For this document, the health
effects discussion will focus on studies of a quantitative dose-response
relationship for disease among workers exposed only to chrysotile asbestos,
asbestos-related health effects resulting from nonoccupational  exposure, and
the influence of cofactors such as smoking habits and age.

7.2  HEALTH HAZARDS OF CHRYSOTILE EXPOSURE
7.2.1  Asbestosis Mortality
     Asbestosis is a chronic, noncancerous,  irreversible disease characterized
by hardening and thickening of lung tissue.   A maj.or cause of death in groups
of workers exposed to high levels of airborne asbestos,  asbestosis is  a
progressive disease that can continue to develop long after a person has been
removed from the source of exposure.  Several occupational  studies have
demonstrated dose-response relationships between exposure to asbestos  and
severity of asbestosis.  The dose-response curve for asbestosis  mortality
among Canadian chrysotile miners and millers has been described  by McDonald
(1979)  as a linear relationship, although the author cautions against
extrapolation to very low exposure levels.2
7.2.2  Lung Cancer Mortality
     Many epidemic!ogical studies have demonstrated clearly that lung  cancer
risk increases with exposure to asbestos.  Few researchers, however, have
attempted to quantify the risk because of problems in estimating cumulative
exposure.  Three recent studies—McDonald (1980), Enterline and  Henderson
(1979), and Dement et a!. (1980)-- have investigated a quantitative dose-

                                     7-1

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response relationship for lung cancer among workers exposed only to
chrysotile.2.3,4  ^11 three studies suggest that the relationship between
cunulative dust exposure and lung cancer is linear; i.e., the risk of lung
cancer is directly proportional to cumulative exposure.  The authors disagree
on the magnitude of increased risk for a given cumulative exposure,
particularly for workers in the lowest exposure categories.  Differences in
study design and method of exposure estimation probably account for some
inconsistencies in findings of these three studies.
     McDonald (1980), who studied chrysotile miners and millers in Quebec, and
Enter!ine (1979), who investigated mortality of retired maintenance-service
employees of an asbestos manufacturing company, estimated past dust exposure
using work histories and total airborne particulate data collected by the
impinger method.*  McDonald included persons exposed to extremely high
airborne fiber levels; thus, competing risk (i.e., persons dying from other
causes) may be a problem.  Enterline's study group consisted only of retirees
older than 65 years of age and may represent a survivor population with  less
lung cancer risk than the general public.   Workers who died before their 65th
birthdays were not included in the study.   Both McDonald and Enter!ine found
that risk of respiratory malignancies increases directly with increasing
cumulative exposure but that an excess risk is difficult to detect in the
groups with least exposure.
     Dement (1980), who studied mortality  among chrysotile textile workers,
used asbestos fiber count data (determined by phase contrast microscopy)  to
estimate past exposure.  Conditions at the textile plant allowed Dement  to
evaluate health effects at exposure levels lower than levels measured by
McDonald or Enter!ine.  Dement1s data suggest a linear dose-response
relationship with no threshold for lung cancer and nonmalignant  respiratory
diseases.  Lung cancer demonstrated a statistically significant  excess in
even the lowest cumulative exposure category.  The risk of lung  cancer at a
given cumulative dose was also found to be greater than the risk reported by
McDonald and Enter!ine.
 The impinger method involves pulling a volume of air through  a  small  tube
 containing water or alcohol.  Particles that settle in the tube are examined
 by light microscopy.  The impinger method was- replaced by the membrane filter
 technique in 1971 for determining occupational  exposure to asbestos.
                                     7-2

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7.2.3  Pleural and Peritoneal Mesothelioma
     Researchers have shown that exposure to asbestos can produce mesothelioma
of the pleura (the membrane that surrounds the lungs and lines the thorax)
and/or the peritoneum (the membrane that surrounds the abdominal  organs and
lines the abdominal and pelvic cavity).  Estimated prevalence of mesothelioma
in the United States and Canada ranges from one to six cases per million
people and seems to be higher in cities where asbestos has been used in the
shipbuilding or ship repair industries.5  The disease often is not detected
for 30 to 40 years after initial exposure.
     The three studies that quantitatively estimated exposure and lung cancer
among chrysotile workers revealed low mortality due to mesothelioma; Dement
(1980) found 1 death, McDonald (1980) found 11 deaths, and Enter!ine (1979)
found 1 death.  In another study, Robinson et al.  (1979) observed 17
mesotheliomas amoung 1,040 deaths in a plant using predominantly  chrysotile
and some crocidolite and amosite.6
     Epidemiologists agree that mesothelioma is underdiagnosed, and proper
study of its incidence requires information beyond what ordinarily appears on
death certificates.3

7.3  NONOCCUPATIONAL EXPOSURE TO ASBESTOS
     Perhaps the most disconcerting aspect of the  relationship between
mesothelioma and asbestos exposure is the disease's documented association
with apparently low levels of exposure for relatively brief periods from
neighborhood or domestic sources.?  In 1960, Wagner documented mesothelioma
cases in residents of a South African asbestos mining area.   Many of these
individuals had never worked with asbestos; their  exposure was associated  with
living near the mines, mills, or roadways along which asbestos fiber was
transported.^  In 1964, Newhouse and Thompson reviewed 76 cases of
mesothelioma reported in London.  Roughly half were former employees of an
asbestos manufacturing facility, 11 lived within one-half of a mile of the
asbestos factory, and 9 lived with workmen employed at the factory.9
     More recently, Borow et al. (1973), using hospital records rather than
plant records, reported 72 cases of mesothelioma in the vicinity  of one of the
two plants Enterline studied.10  Further investigation revealed that 41 of
these cases worked at the plant at some time.  Many died before the age of 65
and thus  were excluded from Enterline's study groups.  Anderson et al. (1976)

                                     7-3

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examined 378 family members of asbestos workers 25 to 30 years after the onset
of initial  asbestos exposure.  Of these, 239 had one or more chest
abnormalities; five cases of mesothelioma were found in the study group.H  In
a case-control study of all female residents of New York State who died of
mesothelioma between 1967 and 1977, Vianna (1978) found that 15 of 62
confirmed cases had worked in asbestos-related industries and 10 had husbands
or fathers who worked in asbestos-related industries.^
     Several researchers have shown that asbestos-related diseases are endemic
in some villages in Turkey.  Ban's (1975) studied 120 cases of pleura!  disease
(108 of which were malignant mesothelioma)  and found only 2 with occupational
exposure to asbestos.  Of the other 118 cases, 16 had a history of
environmental exposure to asbestos.  No condition that may result in asbestos
inhalation was encountered in the rest of the cases, in which it was suggested
that the disease may result from ingestion of water, beverages, or food, or
from other sources.13
     Yazialogu (1976) investigated occurrence of pieural  calcification  '(an
early stage of asbestosis, from which mesothelioma also may develop)  among
inhabitants of several  southeastern Turkish towns located in areas of
naturally occurring chrysotile.  No industrial  source of asbestos is located
in the area.  Upon examination, 389 individuals (2.6 percent of the total
population) showed pi eural calcifications.^
7.4  FACTORS THAT MODIFY THE RISK OF ASBESTOS-INDUCED DISEASE
7.4., 1  Smoking Habits
     The major factor affecting risk of asbestos-induced  lung cancer, besides
the intensity and duration of the exposure, is the smoking habit of the
exposed individual.  The effects of asbestos exposure and cigarette smoke  are
multiplicative, not simply additive (Selikoff et al., 1980).15   Stopping
cigarette smoking is likely to be of paramount importance in reducing excess
cancer risks in asbestos-exposed individuals (Gil son, 1976).16
     The scientific community's current consensus is that mesothelioma  occurs
with equal  frequency among smoking and nonsmoking asbestos workers.   Available
studies of asbestos workers are inadequate to determine whether smoking
increases the risk of developing asbestosis.
                                     7-4

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7.4.2  Age
     Children exposed  to asbestos have greater lifelong risk than adults
equally exposed.   The  factor can be significant when long latency periods are
encountered for diseases such as lung cancer and mesothelioma.  The question
of susceptibility  has  been raised by some researchers.  Kotin  (1977) and
Wasserman et al. (1979) suggest that children are more susceptible than adults
are to carcinogens, including asbestos.^.IS  Other researchers (Doll, 1962;
Cole, 1977) state  that special biological susceptibility has not been
demonstrated for children exposed to asbestos.-^j 20

7.5  FIBER CHARACTERISTICS
7.5.1  Fiber Size
     A great deal  of research has addressed risk variation posed by fibers
differing in size  and chemical composition.  Potentially adverse health
effects of long fibers (>5 micrometers in length) vs.  short fibers (<5
micrometers in length) currently is a topic of debate.  So far, nothing is
known about the importance of fiber size in bronchial  tumor production.16  The
primary research relating fiber size to carcinogenic potency applies only to
pleura!  m.esothelioma and involves direct injection or implantation of fibers
into the pleura of rats.  Some evidence suggests that  fibers may have to  be
2.10 micrometers in length and <1 micrometer in diameter to produce
mesothelioma.1^  pott  (1978), however, states that fibers as short as 3
micrometers in length have carcinogenic potency.-1  Selikoff believes that
fibers less than 3 micrometers in length can produce tumors.  Gross  (1974)
disagrees with his colleagues and believes that fibers <5 micrometers in
length are devoid  of carcinogenic potency.22  stanton  and Layard (1977)
investigated the carcinogenicities of 37 different dimensional  distributions
of 7 fibrous materials and attained optimum correlation with fibers  that
measured <0.25 micrometer in diameter and >8 micrometers in length.23  jhe
authors  did not state that fiber sizes outside this optimal  range were devoid
of carcinogenic potency.
     Presently, there is no firm conclusion concerning relative activities of
short and long fibers.  It cannot be said confidently that fibrogenicity  drops
to negligible proportions at 5 micrometers or 1 micrometer.24  Pott  (1978)
states that even if the carcinogenic potential  of a relatively short fiber is
weak, many short fibers may induce a tumor as easily as a few large  fibers.

                                     7-5

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The author further states that special problems arise in calculating
carcinogenic potency when bundles of asbestos fibers are encountered.  The
possibility of an asbestos fiber bundle splitting when inhaled easily can
increase carcinogenic potency.
7.5.2  Fiber Type
     Human occupational  exposures to all cominercial asbestos fiber types, both
individually and in various combinations, have been associated with high rates
of asbestosis, lung cancer, and mesothelioma.  Presently available information
indicates that the incidence of lung cancer does not depend on the fiber type
but mainly on the dose level.  The incidence of mesothelioma appears to be
linked to the type of asbestos.5  There is general  agreement that risk of
mesothelioma is fiber related in the following order:   crocidolite > amosite >
chrysotile > anthophyllite.  The magnitude of the difference between, for
example, crocidolite and chrysotile is not well  understood.  Timbrell  (1973)
states that chrysotile fibers normally are not observed  near the  pleura
because of their curved  shape; however, short chrysotile  fibers may behave
like crocidolite and penetrate into deeper regions  of  the respiratory
system.^5

7.6  SUMMARY OF HEALTH EFFECTS
     Asbestos inhalation is known to cause asbestosis,  lung cancer, and
mesothelioma in humans.   Current knowledge of carcinogenic  effects of asbestos
is almost entirely derived from occupational  studies.   Recent studies of
chrysotile workers that  relied on older methods  (i.e.,  impingers)  of
estimating dust exposure support the linear dose-response hypothesis for lung
cancer among most exposure groups.  The most  recent study of chrysotile
workers (Dement et al.,  1980) estimated exposure to airborne asbestos fiber
concentrations using phase contrast microscopy and  indicated that  there is no
threshold to the linear  relationship for lung cancer and  nonmalignant
respiratory diseases.   Evidence of asbestos-related disease in  members of
asbestos-worker households and in persons living near  asbestos-contaminated
areas adds support to  the no-threshold, linear dose-response hypothesis.
     Smoking habits and  age are two important cofactors  associated with
increased risk of asbestos-related diseases.   Currently,  researchers have
reached no consensus concerning relative carcinogenic  potency of  short vs.
                                     7-6

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 long fibers.   The varying intensity and  type of exposure, the problem of
 exposure estimation, and the influence of cofactors make it extremely
 difficult to  specify safe exposure  levels for the general public.
 Consequently,  EPA recommends that  public exposure to airborne asbestos be
 reduced  to the greatest  extent  practical.

 7.7   REFERENCES
'-1.    National  Institute  for Occupational  Safety and Health (NIOSH),  U.S.
      Department of Health,  Education,  and Welfare.   Revised Recommended
      Asbestos  Standard.   Washington, D.C.  DHEW (NIOSH)  Publication  Number
      77-169.   December 1976.  p. 53-57.

 2.    McDonald,  J.  C.,  and F.  D. Kiddell.   Mortality in  Canadian  Miners and
      Millers Exposed to  Chrysotile.  Annals of the  New  York Academy  of
      Science.   330:1-9.   December 14,  1979.
 3.    McDonald,  J..C.,  et al.  Dust  Exposure and Mortality in Chrysotile
      Mining.   British  Journal of Industrial  Medicine.  _37_:ll-24.   1980.
 4.    Henderson, V.,  and  P.  E. Enter!ine.   Asbestos  Exposure:   Factors
      Associated With Excess  Cancer  and Respi-ratory  Disease Mortality.  Annals
      of  the New York Academy Sciences.  _330_: 117-125.  December 14, 1979.
 5.    Dement, J. M.,  R. L.  Harris, M. J.  Symons,  and C.  Shy.   Estimates of
      Dose-Response For Respiratory  Cancer Among  Chrysotile Asbestos  Textile
      Workers.   (Presented at  the Fifth International Symposium on  Inhalable
      Particles  and Vapors.   Cardiff, Wales.   September 1980.)  p.  10.4-1
      to  10.4-23.

 6.    Zielhuis,  R.  L.   Public  Health Risks  of Exposure to  Asbestos.   Report of
      a Working  Group of  Experts Prepared  for the  Commission  of the European
      Communities.   Directorate-General for Social Affairs, Health  and  Safety
      Directorate.   Luxembourg,  Pergamon  Press.   1977.   143 p.

 7.    Robinson,  C.,  et  al.   Mortality Patterns,  1940-1975,  Among  Workers
      Employed  in  an  Asbestos  Textile,  Friction,  and Packing  Products
      Manufacturing Facility.  In:   Dust  and  Diseases, Lemen,  R.  A.,  and
      Dement, J.  M.  (eds.)   Park Forest South,  Pathatox  Publishers, Inc.   1979.
      p.  131-143.

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8.   Becklake, M. R.  Asbestos  Related  Diseases  of the  Lung  and  Other Organs:
     Their Epidemiology and  Implications  for  Clinical  Practices.   American
     Review of Respiratory Disease.   114:210.   1976.

9.   Wagner, I. C., C. A. Sleggs', and P.  Marchand.   Diffuse  Pleura!
     Mesothel ioma and Asbestos  Exposure in  North Western  Cape  Province.
     British Journal of Industrial Medicine (London).  J7:260-271.   1960.

10.  Newhouse, M. L., and H. Thompson.  Mesothelioma of Pleura and  Peritoneum
     Following Exposure to Asbestos  in the  London  Area.   British  Journal  of
     Industrial Medicine (London).  _22_:261-269.   1965.

11.  Borow, M. A., et al.  Mesothelioma Following  Exposure to Asbestos:   A
     Review of 72 Cases.  Chest. 6>4_:641-646.   1973.

12.  Anderson, H. R., et al.  Household Contact  Asbestos  Neoplastic  Risk.
     Annals of the New York  Academy  of Science.  ^71^:311-323.  May 23, 1976.

13.  Vianna, N. J., and A. K. Polan.  Non-occupational Exposure to Asbestos
     and Malignant Mesothel iomas in  Females.   The  Lancet.  JL_:1061.   May 20,
     1978.

14.  Baris, Y. I.  Pleural Mesotheliomas  and Asbestos Pleurisies  Due  to
     Environmental Asbestos  Exposure  in Turkey:  An Analysis of 120  Cases.
     Hacettepe Bulletin of Medicine.  _8(4):165-185.  December 1975.

15.  Yazialoglu, S.  Pleural Calcification  Associated with Exposure  to
     Chrysotile Asbestos in  Southeast Turkey.  Chest. K>.:43-47.   July 1976.

16.  Selikoff, I. J., et al.  Mortality Effects  of  Cigarette Smoking  Among
     Amosite Factory Workers.   Journal of National  Cancer Institute.
     65_(3): 507-513.  1980.
17.  Gil son, J. C.  Asbestos Cancers  as an  Example  of the Problem of
     Comparative Risk.  INSERM.  _55_: 107-166.   1976.

18.  Kotin, P-  Briefing Before the  Consumer Product Safety Commission-
     Federal Register.  22 FR 38786.  July  29, 1977.
                                     7-8

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19.  Wassermann, M., et al.  Mesothelioma in Children.   (Presented  at  the
     Symposium on the Biological Effects of Mineral  Fibers.   Lyon,  France.
     September 25-27, 1979.)
20.  Doll, R.  Susceptibility to Carcinogenicities at Different Ages.   Geron
     Clin.  .4:211-221.  1962.
21.  Cole, P.  Cancer and Occupation.  Cancer.  _39_: 1788-1791.  1977.

22.  Pott, F.  Some Aspects of the Dosimetry of the  Carcinogenic Potency of
     Asbestos and Other Fibrous Dust.  Staub-Reinhalt Luft.  _12:486-490.
     December 1978.

23.  Gross, P.  Is Short-Fibered Asbestos Dust a Biological Hazard?  Archives
     of Environmental Health.  _29:115-117.  August 1974.

24.  Stanton, M., and M. Layard.  The Carcinogenicity of Fibrous Minerals.
     National Cancer Institute.  Bethesda, Maryland.  Presented at Proceedings
     of the Workshop on Asbestos:  Definitions and Measurement Methods.
     Gaithersburg, Maryland.  1977.)  p. 143-151.

25.  Selikoff, I., and D.  Lee.  Asbestos and Disease.  Academic Press.   1978.
     p. 428.

26.  Timbrel!, V.  Physical Factors as Etiological  Mechanisms.  Biological
     Effects  of Asbestos.   IARC.  Lyon, France,  p. 295.  1975.
                                     7-9

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                  S.  ENFORCEMENT AND COMPLIANCE EXPERIENCE

8.1  JURISDICTION:  STATE VS.  FEDERAL
     Section 116 of the Clean  Air Act addresses the retention of authority by
States or political  subdivisions within States.  Such political entities may
regulate air pollution by limiting emissions from sources or by requiring use
of control  or abatement methods.  The only stipulation is that for sources
regulated under Sections 111 or 112 (New Source Performance Standards [NSPS]
and National Emission Standards for Hazardous Air Pollutants [NESHAPs],
respectively) of the Clean Air Act, States or their political  subdivisions
cannot adopt standards less stringent than those under Sections 111 or 112.
States that have been delegated partial  or total NESHAP authority are listed
in Table 8-1.  Most  States with NESHAP authority have simply adopted the
Federal  standard by  reference.  Some States; e.g.,  Illinois, New Jersey, and
New York, have developed and enforced their own regulations, which differ from
the NESHAP.  In States that have no regulations specifically governing
asbestos, the Federal  NESHAP is applicable and is enforced by EPA's regional
enforcement branches.

8.2  INDUSTRY CONCERNS
     In  general, industry personnel  did  not object  strongly to the present
asbestos NESHAP.  In a letter  to the President's Task Force on Regulatory
Relief,  the Asbestos Information Association/North  America (AIA)  discussed
several  pending regulatory actions it considered likely to affect the asbestos
industry adversely.2  The existing asbestos NESHAP  was described  as
"... workable for  industry and effective in reducing asbestos
exposures ..."
     The most frequently negative comment  from industry personnel  was that the
NESHAP was  difficult to understand and often resulted in confusion in standard
compliance.  For example, in complying with the "no visible emission"
limitation, some plant personnel  were uncertain if  they must also comply with
                                     8-1

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TABLE 8-1.   STATES WITH NESHAP AUTHORITY1
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Del aware
Florida
Georgia
Hawaii
Idaho
111 inois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Mary! and
Massachusetts
Michigan
Status of NESHAP delegation
Yes
No
__a
No
__a
Yes
Yes
Yes
No
Yes
No
No
No
Yes
No
No
Yes
No
Yes
No
Yes
Yes
                                              (Continued)
                  8-2

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TABLE 8-1.   STATES  WITH  NESHAP  AUTHORITY1  (Continued)
State
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Status of NESHAP delegation
Yes
No
No
Yes
No
	 a
Yes
Yes
No
Yes
Yes
Yes
No
No
Yes
Yes
No
Yes
No
Yes
Yes
                                                    (Continued)
                        8-3

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            TABLE 8-1.  STATES WITH NESHAP AUTHORITY1 (Continued)
State
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Status of NESHAP delegation
No
Yes
Yes
Yes
No
Yes
No
aMany States are divided into air quality control  districts for NESHAP
 enforcement and report directly to the Federal  EPA.   Some State districts,
 counties, and cites have developed and enforce  their own regulations.

California--Bay Area, Del Norte, .  .  ., and S.  Coast  District.

Nevada--Clark and Washoe districts.

Arizona--Pima County and Maricopa County.
                                     8-4

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control equipment specifications in Section 61.23.  During one plant visit,
plant personnel  suggested that the standard's control  equipment specifications
in Section 61.23 might be more appropriately designated guidelines instead of
regulations to allow individual  plants opportunity to design and operate
control systems that better meet their specific needs.3  Generally, industry
personnel  considered the "no visible emission" limitation adequate.

8.3  REGIONAL EPA CONCERNS
     Major concerns expressed by regional  enforcement personnel  are described
below.
8.3.1  Work Practice Enforcement
     Many Federal  enforcement personnel  believe they cannot enforce the work
practice and nonemission provisions of the standard as a result of the U.S.
Supreme Court ruling in the Adamo case.   Therefore, enforcement activities are
directed primarily at the "no visible emission" limitation.
8.3.2  Regulatory Language
     Regional enforcement personnel have commented that the standard is
difficult to understand, adding  uncertainty to already uncertain enforcement
activities.  The difficulty in interpretation is caused partially by unclear
terms.  For example, the definitions of "manufacturing," "fabricating," and
"commercial asbestos" are not clear and have resulted  in uncertainty regarding
applicability of the standard.
8.3.3  Notification
     Regional EPA personnel have identified several problems with notification
requirements for demolition and  renovation.  Some contractors and building
inspectors responsible for permitting demolition jobs  appear to be unaware of
reporting requirements and do not inquire of the presence of asbestos in a
building.   Enforcement personnel believe a substantial amount of demolition
occurs when the contractor at least suspects that asbestos is present and does
not make the proper notification.  Owners of buildings to be demolished also
seem to be unaware of or ignore  the possible presence  of asbestos.  When
received,  notifications often lack information, arrive late, or arrive after
the job is completed.  EPA enforcement officials state that enforcement is
difficult because of personnel shortages.   If notifications were received for
                                     8-5

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all  demolition and renovation jobs, it would be extremely difficult, if not
impossible, to inspect each site.
8.3.4  Emission Limitation
     Although "no visible emissions" is considered a fairly stringent
standard, a quantitative limit would be easier to enforce because it would
eliminate subjectivity.
8.3.5  Unregulated Source
     The only potential emission source enforcement officials identified as
not being covered by the asbestos NESHAP was the application of encapsulants
over asbestos-containing materials.  The pressure with which encapsulants are
applied causes asbestos fiber release.

8.4  APPLICABILITY DETERMINATIONS
     Since promulgation of the asbestos NESHAP,  numerous inquiries have been
made concerning the standard's applicability to  various asbestos uses.   Table
8-2 presents examples of the type of inquiries directed to the Division of
Stationary Source Enforcement (DSSE).

8.5  UNREGULATED EMISSION SOURCES
     Several potential sources of asbestos emissions  are unregulated by the
current standard but were considered during promulgation of the  standard and
its amendments.  In addition, two potential  sources not considered
previously~spray-on encapsulants and  drilling muds—have now been identified.
These unregulated sources are discussed below.
8.5.1  Onsite Fabrication
     Asbestos-containing building materials, such as  asbestos/cement (A/C)
pipe and A/C sheet, may undergo cutting, drilling,  or grinding  at the
installation site.  Such onsite fabrication previously was considered to occur
infrequently and was not considered a  major emission  source.   More recent
information indicates that this infrequency continues.^
8.5.2  Demolition
     Where less than 80 meters (260 feet)  of pipe or  less than  15 meters^  (160
feet^)  of surface is covered with asbestos or where apartments  with  four or
fewer dwelling units are to be demolished, the NESHAP does not  apply.   These
                                     8-6

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                                    TABLE 8-2.  ASBESTOS NESIIAP DETERMINATIONS
                 Question
                                      Determination
                                  Discussion
CO
    Is the cutting  of asbestos  paper
    covered?
A manufacturer has two plants.
Plant A produces asbestos paper
shipped to Plant B.  Plant B
makes roofing tile from the
asbestos paper and treats it
with an asphalt mix.  Is Plant  B
covered by the standard?

Are visible emissions from
asbestos block curing ovens
subject to NESHAP regulations?

What is an acceptable method for
identifying asbestos samples found
in demolition/renovation
inspections?

Can the fencing requirement in
Section 61.25(c) be satisfied by
placing a fence along the property
line of a plant containing an
asbestos disposal site rather than
around the perimeter of the disposal
site?
Yes


No



No
                                             No
                                          Microscopy
                                              Yes
Asbestos paper cutting is covered if done prior to
initial marketing.

Asbestos paper cutting is not covered if it has been
marketed initially.  This would be fabrication and
not manufacturing.

The standard covers manufacturing of asbestos paper
paper but not fabrication of asbestos paper
products.
             Visible emissions  from these  sources  are  caused  by
             resins (hydrocarbons)  and  not by  asbestos.
             EPA has relied  on  polarized  microscopy  in  most
             enforcement  cases.   This  method  is  used to identify
             hard samples of asbestos  found  at demolition,
             renovation,  and waste disposal  sites.

             This question was  resolved  in 40 FR 48294, October
             14, 1975,  in response to  a  comment  on  amendments
             proposed on  October 25,  1974.   A fence  that
             surrounds  a  plant  property  and  adequately  deters
             public access may  substitute for a  fence around
             the perimeter of a disposal  site located within the
             property fence.
                                                                                       (Continued)

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                             TABLE 8-2.   ASBESTOS NESHAP  DETERMINATIONS  (Continued)
                Question
Determination
                     Discussion
oo
i
co
   Does the 1-percent limit on asbestos
   content of spray-on materials apply
   to naturally occurring and
   commercially-added asbestos?
   Is a wallboard manufacturing
   facility that uses tailings fines
   from an asbestos mine as filler
   material subject to Section
   61.22(c)7  Is it subject to any
   other section of the asbestos
   regulations?
     Yes
     No
   In reference to the asbestos
   regulations, are inactive waste
   disposal sites prevented or
   restricted from future use as
   commercial or residential sites?
 Conditional
The 1-percent limit on spraying of asbetos-
containing materials in Section 61.22(e) does not
specify commercial  asbestos.   Therefore, the
limitation is applicable to naturally occurring and
commercial asbestos.

Section 61.22(c) applies to manufacturing operations
that use commercial  asbestos.   Since tailings fines
do not fall'into the "commercial  asbestos" category,
as defined in Section 61.21(h), the operation is not
subject to Section  61.22(c).   Since the source of
the tailings fines  is a mine,  use of the tailings in
the wallboard manufacturing process is not covered
by any section under Subpart  B.  However, if the
source of the tailings fines  was an asbestos mil 1 ,
any operations involving collection, processing,
packaging, transport, or deposition of the tailings
fines would be subject to the requirements.

Inactive disposal  sites may be used for commercial
or residential development provided asbestos
exposure is avoided in accordance with Section
61.22(e).

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exemptions were made because such situations did not constitute major emission
sources.  Nothing was identified during the Phase I study to alter these
exemptions.
8.5.3  Contaminant Sources
     Various other minerals, such as iron ore and serpentine rock, may contain
asbestos.   The industries that process these minerals are not regulated by the
asbestos NESHAP.   EPA previously has considered regulating production and use
of these contaminant sources.  For iron ore, EPA concluded that the primary
emission sources  are now being controlled as a result of State and Federal
litigation.  For  crushed rock from serpentine deposits used to maintain
unpaved roads, EPA concluded that local, State and Federal  authorities
responsible for limited areas of concern were best able to assess and control
use of the stone.  EPA published "Assessment and Control  of Chrysotile
Asbestos Emissions from Unpaved Roads" to provide guidance to the appropriate
authorities.6
8.5.4  Asbestos Mining
     The Bureau of Mines regulated asbestos exposures from mining operations
at the time of the April 6,  1973, promulgation.  Now the Mine Safety and
Health Administration (M-SHA) has the safety and health responsibilities that
once belonged to  the Bureau  of Mines.  MSHA regulates airborne asbestos
concentration and requires use of respirators only after available
environmental  control measures have been used first.  The number of U.S. mines
has declined from the number that existed during the early 1970s and domestic
production has declined.
8.5.5  Fabricators
     The NESHAP regulates fabricators of A/C building products, friction
products,  and A/C or asbestos-silicate board for ventilation hoods, ovens,
electrical  panels, laboratory furniture, bulkheads, partitions and ceilings
for marine construction, and flow control  devices for the molten metal
industry.   Other  fabricators or secondary processors were not considered
major emission sources.  No  increase in emissions from fabrication or
secondary  processing was found, and some asbestos uses have significantly
declined because  of the availability of asbestos substitutes, increasing
concerns about health risks, increasing regulations, and present day economy.
                                     8-9

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8.5.6  Encapsulants
     Use of encapsulants or sealants over sprayed asbestos surfaces is a
potential emission source not previously considered.  Sealing of sprayed
asbestos surfaces involves application of material that will envelop or coat
the fiber matrix, eliminate fallout, and protect against contact damage.
Sealants usually are applied to asbestos surfaces by spraying and consist of
polymers with an agent added to enhance penetration into the fiber matrix.
Currently available sealants include water-based latex polymers, water-soluble
epoxy resins, and organic-solvent-based polymers of various types.
     Application of a sealant to friable asbestos by spraying will disseminate
small fibers by contact.  A sealant should be applied with as much caution and
at as low a nozzle pressure as possible to reduce contact disturbance.?
8.5.7  Drilling Muds
     A potential emission source that has not been considered for regulation
is asbestos use in drilling muds.  The following description is taken from a
1976 report.8
     Drilling fluids (muds) are essential  for drilling oil  and gas wells.
Asbestos use in drilling muds is well established-and can lower the cost of
drilling and completing wells significantly.   Drilling muds are pumped down
through the drill pipe and up the annul us between the drill pipe and the well
bore wall.  When the drilling muds arrive on  the surface, they flow over a
shaker screen to remove the drill bit cuttings and into a mud pit.   The fluid
is recirculated through the hole.  Materials  needed  to maintain properties of
the drilling fluid are added in the surface pit.
     The main function of the drilling mud is to remove drill  cuttings from
the hole and to contain formation pressures in the hole.   The mud  also removes
heat from the drilling action, acts as a lubricant,  and prevents excessive
hole erosion.  The drilling mud must remain fluid enough  to be pumped  with
minimum pressures.  The mud must not be lost  to the  formation yet  must
overcome formation pressures to prevent ingress of oil, gas,  or water.
     Asbestos is added to the drilling mud to improve its carrying  capacity
without appreciably increasing viscosity.   Other methods  of improving  carrying
capacity markedly increase viscosity, which increases pump pressures,  reduces
power available at the bit, and slows drilling.  Slow drilling rates increase
                                     8-10

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ciriTHng costs.  Asbestos is used in concentrations of from 0.9 to 2.3
kilograms (2 to 5 pounds) per barrel (1 barrel  equals 42 gallons)  of mud.
     Asbestos is added to the drilling fluid through a mud  hopper or large
funnel  with the potential for fibers being released into the atmosphere.
Initially, a volume of mud of from 150 to 200 barrels is prepared.  As
drilling progresses, additions are made to the system to maintain and to
accommodate the volume of the hole being drilled.   Typically,  these conditions
occur only once during an 8-hour shift.  The asbestos added is minimal — rarely
exceeding 225 kilograms (500 pounds) at a time.
     Over 30,000 wells are drilled per year in the United States,  and
approximately 1,500 drilling rigs are used.  Frequent movement from site to
site makes fixed control  equipment for asbestos  fiber exposure infeasible.   A
normal  drilling crew consists of four men working  an 8-hour shift; that  is,
three 8-hour crews per day.  Drilling sites may  be miles from  any  population
center and are subject to extreme climatic conditions (e.g., the  north coast
of Alaska to the Gulf of Mexico).
     According to the AIA, the quantity of asbestos fiber annually consumed
for drilling fluids is approximately 9,100 metric  tons (10,000 short tons).
The shorter grades of chrysotile fibers are normally used,  and pelletized
fiber and loose fiber can be used.9

8.6  REFERENCES
1.   Asbestos Information Association.  Asbestos State and  Federal
     Regulations, Annex A.  Arlington, Virginia.  February  1978.
2.   Letter and attachments from Dougherty, T.  A., Asbestos Information
     Association/North America, to the Honorable George Bush,  Vice President,
     United States.  April 30, 1981.  11 p.  Asbestos industry issues for the
     Task Force on Regulatory Relief.
3.   Laney, M.  Trip Report—Initial Plant Visit,  Bendix Corporation, May 14,
     1981.  Research Triangle Institute.  Research Triangle Park,  North
     Carolina.  May 21, 1981.  5 p.
                                     8-11

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4.   Wright, M. D., et a"!.  Asbestos Dust, Technological  Feasibility Impact
     Analysis of the Proposed Federal Occupational  Standard.   Part  I:
     Technological Feasibility Assessment and  Economic  Impact  Analysis.
     Research Triangle Institute.  Research Triangle  Park,  North  Carolina.
     (Prepared for the Occupational Safety and Health Administration.
     Washington, D.C.)  NTIS No. RTI/1370/02-01-F.  September  1973.
     p. 111-20 to 111-34.
5.   U.S. Environmental Protection Agency.  National  Emission  Standards  for
     Hazardous Air Pollutants, Development of Asbestos  Standard for  the
     Production and Use of Crushed Stone:  Advanced Notice  of  Proposed
     Rulemaking.  Federal Register.  _42_(217) :58543.   November  10, 1977.

6.   Serra, R. K., and M. A. Connor.  Assessment and  Control of Chrysotile
     Asbestos Emissions from Unpaved Roads.  Midwest  Research  Institute.
     Raleigh, North Carolina.  (Prepared for the Office of  Air Quality
     Planning and Standards, U.S. Environmental Protection  Agency.   Research
     Triangle Park, North Carolina.)  EPA-450/3-81-006.  May 1981.   105  p.

7.   Sawyer, R. N., and C. M. Spooner.  Yale University and GCA Corporation.
     Sprayed Asbestos-Containing Materials in Buildings:  A Guidance Document.
     (Prepared for Office of Air Quality Planning and Standards, U.S.
     Environmental Protection Agency.  Research Triangle Park, North
     Carolina.)  EPA-450/2-78-014.  March 1978.  133 p.

8.   Daly, A. R.  Technological  Feasibility and Economic Impact of OSHA
     Proposed Revision to the Asbestos Standard.  Westchester, Pennsylvania.
     Roy F- Weston, Environmental Consultants-Designers.  (Prepared for the
     Asbestos Information Association/North America.  Washington, D.C.)
     March 1976.  189 p.
                                     8-12

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Meylan, W. S., P- H. Howard, S. S. Lande, and A.  Hanchett.  Chemical
Market Input/Output Analysis of Asbestos to Assess Sources of
Environmental Contamination.  Syracuse Research Corporation.  Syracuse,
New York.  (Prepared for the Office of Toxic Substances, U.S.
Environmental Protection Agency.  Washington, D.C.)   EPA-560/6-78-005.
August 1978.   323 p.
                                8-13

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                   9.  OTHER FEDERAL REGULATORY ACTIVITIES

     Asbestos is probably one of the most regulated substances in this
country.  Numerous standards address asbestos directly; e.g., the U.S.
Environmental Protection Agency's (EPA) National  Emission Standard for
Hazardous Air Pollutants (NESHAP), the Occupational Safety and Health
Administration's (OSHA) work place standards for asbestos, and the Mine Safety
and Health Administration's (MSHA) health and safety standards for workers.
Several  generic standards also address hazardous  substances and eventually may
result in asbestos regulation.  In addition, several  proposed or outstanding
regulations are aimed at regulating different aspects of asbestos use.
     The objective of this chapter is to identify existing and proposed
asbestos-specific and generic regulations.  The exact manner in which all
current  and proposed regulations will interface with the revised asbestos
NESHAP will depend substantially on details of the revision.  As part of the
Phase II revision process, all of the various standards will be evaluated  to
determine how they should interface with the NESHAP revision.
     The discussion of regulations is segregated  by regulatory agency.  A
brief statement summarizes major points of each standard, and standards are
designated proposals or existing regulations.

9.1  ENVIRONMENTAL PROTECTION AGENCY
9.1.1 Clean Air Act
     The purpose of the Clean Air Act is to achieve and maintain air quality
to protect the public health and welfare.  Primary and secondary ambient air
quality  standards were established under the Act, and States were required to
prepare  implementation plans to attain and maintain those standards.  EPA  must
also establish performance standards for new and  modified stationary sources
and standards for hazardous air pollutants (e.g., asbestos).  The Office of
Air Quality Planning and Standards (OAQPS) has authority under the Clean Air
Act to research and develop air quality standards.
                                     9-1

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     9.1.1.1  National  Standards for Hazardous Air Pollutants; Policy and
              procedures for Identifying, Assessing, and Regulating Airborne
              Substances Posing a Risk of Cancer; Proposed Rulemaking 44 FR
              58642;  October 10. 1979
     Proposed pursuant  to the Clean Air Act, the carcinogen rule considers
policies and procedures to determine carcinogenicity and risks for a specific
pollutant, establish  priorities for regulatory action, specify degree of
control, and provide  public input to the decisionmaking process.
9.1.2  Resource Conservation and Recovery Act
     The objectives of  the Resource Conservation and Recovery Act (RCRA) of
1976 (PL 94-580) are  to promote protection of health and the environment and
to conserve valuable  materials and energy through regulation of solid waste
disposal, including hazardous waste disposal.  RCRA regulates waste from point
of generation, through  transporation, storage, and disposal.  Records are kept
of the quantity, composition, origin, routing, and destination of waste  from
"cradle-to-grave."  Authority for administering RCRA lies with the Office of
Solid Waste.
9.1.3  Toxic Substances Control  Act
     The purpose of the Toxic Substances Control  Act (TSCA)  of 1976 (PL  94-
469) is the regulation  of chemical  substances that present a hazard to health
or the environment.  The Act has a broad purview and deals with  toxic
substances throughout their life cycle, including manufacturing,  distribution,
use, and disposal.  Authority for administering TSCA lies with the Office of
Pesticides and Toxic  Substances.  Rules and proposals that affect asbestos  are
listed below.
     9.1.3.1  Chemical  Imports and Exports;  Notification of  Exports;  Final
              Rule 40 CFR 707, Subpart D
     Section 12(b) of TSCA requires anyone who exports  to another country a
chemical substance to notify EPA of such plans if the substance  meets one of
several criteria.  One  of the criteria, which would require  asbestos  to  comply
with the exporting rule, is that a rule has been  promulgated or  proposed, under
Section 6 of TSCA with  respect to the chemical  substance.   Section 6  of  TSCA
defines regulatory alternatives  to be used to reduce health  risks.  A proposal
                                     9-2

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under Section 6 has been issued for asbestos;  therefore,  asbestos is subject
to EPA's export rule.
     9.1.3.2  Commercial and Industrial  Use of Asbestos Fibers;  Advance Notice
              of Proposed Rulemaking;  44 FR 60061  (October 17,  1979)
     Pursuant to Section 6 of TSCA, EPA  is  considering  various  approaches to
control  risks from asbestos, including banning certain  products  and  limiting
asbestos imported and produced annually  in  the United States.
     9.1.3.3  Asbestos;  Reporting and  Recordkeeping  Requirements, Proposed
              Rule; 46 FR 8200 (January  26, 1981)
     Pursuant to Section 8(a)  of TSCA, EPA  is  proposing that manufacturers,
importers,  and processors of asbestos  report certain information  to  EPA to
help regulate asbestos.   Information to  be  reported  includes quantities of
asbestos used, employee  exposure and monitoring data, and  waste disposal  and
pollution control information.
     9.1.3.4  Asbestos-Containing Materials in School Buildings;  Advance
              Notice of  Proposed Rulemaking; 44 FR 54676  (September  20, 1979)
     Pursuant to Section 6 of TSCA, EPA  announced  plans to require all  public
and private schools to identify asbestos-containing  products in schools and
then to  take corrective  steps to reduce  exposures.-
     9.1.3.5  Friable Asbestos-Containing Materials  in  Schools; Proposed
              Identification and Notification, Proposed Rule;  45 FR 61966
              (September 17, 1980)
      Pursuant to Section 6 of TSCA, EPA proposed  the first phase in
identifying asbestos in  schools, including  bulk sampling  and analysis,
recordkeeping, and notifying affected  persons.
9.1.4 Clean Water Act
     The Clean Water Act of 1977 (PL 95-217) comprehensively amends  the
Federal  Water Pollution  Control  Act as amended in  1972.   The Clean Water Act
significantly changes requirements  for control  of  industrial discharges,
construction of municipal  sewage treatment  plants, management of  nonpoint
sources, protection of wetlands, and other  related concerns.  Pursuant  to
Section  304(a) of the Clean Water Act, EPA  adopted water  quality  criteria for
asbestos (44 FR 56628, October 1, 1979). Prior to the  Clean Water Act  of
1977, effluent limitation guidelines were established (39  FR 7526, February
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26, 1974) for existing sources and standards of performance and pretreatnent
standards for new sources within the asbestos/cement (A/C) pips, A/C sheet,
asbestos paper (starch binder) and (elastometric binder), asbestos millboard,
asbestos roofing products, and asbestos floor tile subcategories of the
asbestos manufacturing category of point sources were set.  Final  effluent
guidelines were established (40 FR 1847, January 9, 1973) for additional
related subcategories within the asbestos manufacturing category.

9.2  OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
     The current OSHA standard, 29 CFR 1910.1001,  is applicable to both
general industry and construction.  The standard limits employee exposure to 2
fibers per cubic centimeter over an 8-hour period  or to a ceiling
concentration of 10 fibers per cubic centimeter.  The standard specifies
compliance methods, use of personal protective equipment, measurement methods,
use of signs, housekeeping and recordkeeping practices, and use of employee
medical examinations.  OSHA proposed in 40 FR 47652, October 9, 1975, to lower
allowable exposure limits from 2 to 0.5 fiber per  cubic centimeter.   However,
it is not clear that they are now actively pursuing promulgation of this more
stringent standard.
9.3  CONSUMER PRODUCT SAFETY COMMISSION
     The Consumer Product Safety Commission (CPSC)  banned asbestos-containing
consumer patching compounds and artificial  emberizing materials on December
15, 1977, (42 FR 63354).  On October 17, 1979, in  44 FR 60057, CPSC  issued an
Advance Notice of Proposed Rulemaking soliciting information on the  use of
asbestos in consumer products.  This information may be used to regulate
asbestos further in consumer products.

9.4  FOOD AND DRUG ADMINISTRATION
     Pursuant to the Federal Food, Drug, and Cosmetic Act, the Food  and Drug
Administration (FDA) banned asbestos-containing garments for general  use in
households from interstate commerce in  37 FR 14872, July 26,  1972.   On  March
14, 1975, in 40 FR 11865, the FDA required that filters used in manufacturing,
processing, or packaging of drugs used  for human parenteral  injections  cannot
release fibers into such products.  The Act established other manufacturing
practices to limit asbestiform particles in drugs  for parenteral  injection.
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On January 22, 1976, the FDA revoked the regulation (41 FR 3236) allowing the
use of the electrolytic diaphragm process for salt because the process does
not remove asbestos as well  as conventional  methods.

9.5  DEPARTMENT OF TRANSPORTATION
     Pursuant to the Hazardous Materials Transportation Act, the Department of
Transportation (DOT) proposed rules in 43 FR 8562 (March 2, 1978) for
regulation of transporting asbestos.  The rules specify containment measures
for asbestos and asbestos-containing materials but exclude asbestos that is
immersed or fixed in a binder material and that is in a manufactured product.

9.6  MINE SAFETY AND HEALTH ADMINISTRATION
     The Mine Safety and Health Administration (MSHA)  regulations provide for
employee protection and are similar to the OSHA standards.  In 41 FR 10223
(March 10, 1976), MSHA established that mine workers cannot be exposed to
greater than 2 fibers per cubic centimeter over an 8-hour period, nor could
they be exposed to a ceiling concentration greater than 10 fibers per cubic
centimeter for more than 1. hour each 8-hour  day.

9.7  OTHER FEDERAL AGENCIES
     Pursuant to the Asbestos School Hazard  Detection  and Control Act of 1980
(PL 96-270), on September 17, 1980, the Department of Education issued in
45 FR 61950 a Notice of Proposed Rulemaking, entitled  "Asbestos Detection and
Control; Local Educational  Agencies; Asbestos Detection and State Plan:   State
Educational Agencies."  The proposal establishes  procedures to make Federal
grants available to local and State educational  agencies to help them identify
and correct asbestos hazards in school buildings.  The National Institute of
Environmental Health Sciences (NIEHS), the National Institute for Occupational
Safety and Health (NIOSH),  the National  Cancer Institute (NCI), and the Public
Health Service are other Federal agencies that have interests related to
regulation of asbestos.
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