EPA-450/2-74-009a
OCTOBER 1974
BACKGROUND INFORMATION
ON NATIONAL EMISSION STANDARDS
FOR HAZARDOUS AIR POLLUTANTS -
PROPOSED AMENDMENTS
TO STANDARDS FOR ASBESTOS
AND MERCURY
UA ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/2-74-009a
BACKGROUND INFORMATION
ON
NATIONAL EMISSION STANDARDS
FOR
HAZARDOUS AIR POLLUTANTS-
PROPOSED AMENDMENTS TO STANDARDS
FOR
ASBESTOS AND MERCURY
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1974
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This report is published by the Environmental Protection Agency to report
information of general interest in the field of air pollution. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - as supplies permit - from the
Air Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711. This document is also avail-
able to the public for sale through the Superintendent of Documents, U.S.
Government Printing Office, Washington, D.C. 20402.
Publication No. EPA-450/2-74-009a
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TABLE OF CONTENTS
LIST OF FIGURES v1
LIST OF TABLES v11
CHAPTER 1. INTRODUCTION 1
CHAPTER 2. ASBESTOS: MANUFACTURING 4
SUMMARY OF PROPOSED AMENDMENT 4
RATIONALE FOR PROPOSED AMENDMENT 4
Shotgun Shell Manufacture 4
Asphalt Concrete Plants 6
CHAPTER 3. ASBESTOS: DEMOLITION AND RENOVATION 10
SUMMARY OF PROPOSED AMENDMENTS 10
RATIONALE FOR PROPOSED AMENDMENTS 11
Addition of Renovation Operations 12
Revisions in Demolition Drocedures 13
Definition of "Friable Asbestos Materials". . . .15
Suspension of Certain Wetting Requirements
in Sub-Freezing Temperatures 17
Emergency Reporting Requirements 19
CHAPTER 4. ASBESTOS: FABRICATION 21
SUMMARY OF PROPOSED AMENDMENTS 21
RATIONALE FOR PROPOSED AMENDMENTS 21
Field Fabrication 24
Central Shop Fabrication 26
CHAPTER 5. DISPOSAL OF ASBESTOS WASTES 31
SUMMARY OF PROPOSED AMENDMENTS 31
Disposal of Wastes from Manufacturing,
Fabricating, Demolition, Renovation, and
Spraying Operations 31
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Disposal of Wastes from Asbestos Mills 31
Waste Disposal Sites 32
RATIONALE FOR PROPOSED AMENDMENTS 33
Process Wastes 34
Waste Disposal Practices 39
Waste Disposal Sites 50
CHAPTER 6. MERCURY EMISSIONS FROM SLUDGE INCINERATION
AND DRYING FACILITIES 73
SUMMARY OF PROPOSED AMENDMENT 73
RATIONALE FOR PROPOSED AMENDMENT 73
Description of Industry 77
Mercury Emissions 90
CHAPTER 7. ENVIRONMENTAL IMPACT 103
ASBESTOS 103
MERCURY 105
CHAPTER 8. ECONOMIC IMPACT 107
ASBESTOS 107
Asbestos Manufacturing 107
Asbestos Fabrication 110
Asbestos Demolition and Renovation Ill
Disposal of Asbestos Wastes 114
Waste Disposal Sites 116
MERCURY 121
APPENDIX A. OPTIONAL AIR-CLEANING METHODS FOR COMPLIANCE
WITH ASBESTOS STANDARD 124
APPENDIX B. CHEMICAL STABILIZATION OF WASTE DISPOSAL SITES . .126
IV
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APPENDIX C. ESTIMATION OF ALLOWABLE MERCURY EMISSIONS FROM
SEWAGE SLUDGE INCINERATION FACILITIES 132
APPENDIX D. SOURCES CONSULTED DURING STANDARDS DEVELOPMENT . .137
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LIST OF FIGURES
5-1. Sources of asbestos emissions in Ambler,
Pennsylvania 54
5-2. Sources of asbestos emissions in Hyde Park, Vermont . . 63
6-1. Total mercury content of sewage sludge for incineration,
assuming 0 percent control of emissions 96
6-2. Total mercury content of sewage sludge for incineration,
assuming 50 percent control of emissions 97
C-l. Calculated maximum allowable mercury emissions from a
sewage sludge incinerator under applicable Pasquill
stability classes (C and D) and wind speed of 2 mps . .134
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LIST OF TABLES
4-1. ASBESTOS CONSUMPTION BY MAJOR PRODUCT CATEGORIES 22
5-1. SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED
OCTOBER 15-18, 1973, IN AMBLER, PENNSYLVANIA 58
5-2. SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED
SEPTEMBER 25-OCTOBER 1, 1973, IN HYDE PARK, VERMONT 64
5-3. AMBIENT ASBESTOS CONCENTRATIONS FROM TAILINGS PILE AND
ON PUBLIC ROADWAY 66
5-4. ASBESTOS CONCENTRATION OF MATERIAL SAMPLES TAKEN IN
VERMONT 69
5-5. LOCATION OF SAMPLING SITES 71
6-1. AVERAGE CHARACTERISTICS OF SEWAGE SLUDGE 79
6-2. MERCURY CONCENTRATION IN SEWAGE SLUDGES, DRY SOLIDS BASIS. . 80
6-3. DISTRIBUTION OF EXISTING PLANTS ACCORDING TO SLUDGE
BURNING CAPACITIES 86
6-4. SLUDGE BURNING CAPACITIES OF LARGEST PLANTS 87
6-5. NUMBER OF SEWAGE SLUDGE INCINERATORS, 1970 THROUGH 1980. . . 89
6-6. MERCURY EMISSIONS FROM SEWAGE SLUDGE INCINERATORS 91
8-1. SUMMARY OF ECONOMIC IMPACT OF PROPOSED AMENDMENTS TO
ASBESTOS STANDARD 108
C-l. SOURCE CHARACTERISTICS OF A HYPOTHETICAL SEWAGE SLUDGE
INCINERATION FACILITY 132
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1. INTRODUCTION
Section 112 of the Clean Air Act requires the Administrator
to list hazardous air pollutants for which he intends to set emission
standards and to then establish National Emission Standards for Hazardous
Air Pollutants (NESHAP) for such substances. A hazardous air pollutant
is defined as ". . .an air pollutant to which no ambient air quality
standard is applicable and which in the judgment of the Administrator
may cause, or contribute to, an increase in mortality or an increase
in serious irreversible, or incapacitating reversible, illness."
National emission standards for three hazardous air pollutants
(asbestos, beryllium and mercury) were promulgated on April 6, 1973
(38 FR 8820). Clarifying revisions to these standards were promulgated
on May 3, 1974 (39 FR 15396). In April 1973, the Environmental Defense
Fund filed a petition for review of the standards with the United
States Court of Appeals for the District of Columbia. This petition
led to Agency investigation of additional sources of asbestos and
mercury emissions. Appendix D presents a summary of the information
sources consulted during the Agency's investigation. This investigation,
together with information gained through enforcing the standards, has
led to the Administrator's determination that the standards should be
amended. Such amendments are being proposed in the Federal Register.
The preamble to the proposed amendments includes a brief
explanation and rationale for the proposed actions. This document
provides a more detailed discussion of the statements made in the
preamble concerning the basis for the proposed amendments, which
deal mainly with expanding the standards to cover additional
major sources. Changes have also been made to improve the uniformity
of enforcement and workability of the standards.
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The basic approach used to develop the standards was to first
identify ambient concentrations of the pollutants which were judged to
provide an ample margin of safety to protect the public health.
Allowable emissions were then derived from the safe ambient concen-
trations by using meteorological procedures. For asbestos, however,
it is impossible to prescribe and enforce allowable numerical
concentrations or mass emission limitations known to provide an
ample margin of safety to protect public health, since no safe level
has been identified. Although improvements have been made in asbestos
measurement techniques since promulgation of the standard, and although
the Agency has used these methods to estimate emissions from two large
asbestos waste disposal sites in developing the proposed regulations,
the techniques have yet to be sufficiently refined to provide a
reliable basis for standard setting. Therefore, the promulgated
standard for asbestos includes limitations on visible emissions or,
as an option in some cases, the use of designated control equipment;
requirements that certain procedures be followed; and prohibitions
on the use of certain materials or of certain operations. The
promulgated standard for mercury specifies an allowable mass emission
rate which was derived from dispersion estimates as the rate which
would protect against the violation of an average daily ambient
concentration of 1 microgram per cubic meter averaged over a 30-day
period.
A complete explanation of the basis and rationale for the
asbestos and mercury standards that were promulgated on April 6,
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1973, (38 FR 8820) may be found in the preamble to the regulation
and in Background Information on Development of National Emission
Standards for Hazardous Air Pollutants: Asbestos, Beryllium, and
Mercury, EPA Publication No. APTD-1503, March 1973.
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2. ASBESTOS: MANUFACTURING
SUMMARY OF PROPOSED AMENDMENT
There shall be no visible emissions of asbestos-containing
participate matter to the outside air from two additional
manufacturing operations:
(1) The manufacture of shotgun shells.
(2) The manufacture of asphalt concrete.
As an alternative to the no-visible-emission standard, specified air
cleaning methods may be used (see Appendix A).
RATIONALE FOR PROPOSED AMENDMENT
Asbestos is a significant raw material in the manufacture
of numerous products. The standard promulgated April 6, 1973
(38 FR 8820), limits the emissions of asbestos from nine manu-
facturing operations. In the course of enforcing the standard
for asbestos, the Agency discovered that the manufacture of
shotgun shells utilizes a substantial amount of asbestos and
observed that asbestos emissions were poorly controlled at some
asphalt concrete plants. On the basis of a subsequent investigation
of these two source categories (see Appendix D), the Administrator has
determined that they are major sources of asbestos emissions and is
therefore proposing that the asbestos standard be extended to Include
these two manufacturing operations.
Shotgun Shell Manufacture
The investigation into the manufacture of shotgun shells
included a visit to the only shotgun shell manufacturing plant
in the United States that is known to use commercial asbestos,
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and discussions with the plant operator and the Asbestos
Information Association (AIA).
Asbestos is used to manufacture base wads for shotgun shells.
The asbestos is mixed with wood flour and wax, and then pressed
into base wads. The weight composition of the final mixture at the
plant visited was 54 percent wood flour, 36 percent asbestos,
and 10 percent wax. Asbestos emissions can occur during asbestos
addition to the mixture, during mixing operations, and at the wad presses
The emission points are vented to the outside air through particulate
collection devices.
The quantity of asbestos used in the manufacture of shotgun
shells as a category is about 0.06 percent of the total asbestos
consumption in the United States, a low usage level for a major source
category. However, the annual asbestos consumption for the shotgun
shell plant visited is approximately 454 metric tons (ca. 500 tons).
The usage of this amount of asbestos at one location is large
compared to that of many individual plants that are regulated by
the asbestos standard.
The raw material handling and wad pressing operations potentially
generate asbestos emissions comparable to those from manufacturing
operations presently covered by the asbestos standard. Because
asbestos emissions at shotgun shell plants are directly proportional
to the asbestos usage rate, and because the plant uses relatively
large quantities of asbestos, the Administrator has determined that
the manufacture of shotgun shells is a major source of asbestos
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emissions and is therefore proposing to cover it under the
asbestos standard.
The gas streams that ventilate the material-hand!ing systems
and presses present no unique problems in employing commercially
available particulate control devices. The promulgated standard
for asbestos manufacturing operations allows no visible emissions
of asbestos-containing particulate matter to the outside air from
the facility or, as an alternative, the use of specified fabric
filtration devices or other control devices of equivalent effectiveness.
The proposed amendment would make this provision applicable to
shotgun shell plants.
Asphalt Concrete Plants
In developing the proposed standard for asphalt concrete
plants, Agency personnel visited several asphalt concrete plants
and had discussions with the National Asphalt Paving Association
(NAPA), the AIA, asphalt plant operators, and distributors of
commercial asbestos.
Asbestos is added to asphalt to give it greater strength
and longer wear life. The asbestos-asphalt mixture is usually
applied as a thin topping layer and is most commonly used on
airport roadways, bridges, or street curbing. Only about 50 of
the estimated 5000, asphalt concrete plants in the United States
use asbestos each year, and the total amount of asbestos consumed by
an individual plant will vary greatly from year to year. For
example, in 1971, 1972, and 1973 one asphalt plant that was
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visited by Agency personnel produced 2300 metric tons (ca. 2500 tons),
none, and 410 metric tons (ca. 450 tons), respectively, of 3 percent
to 4 percent asbestos-asphalt concrete mix.
Some 4100 metric tons (ca. 4500 tons) of asbestos per year are
used in the manufacture of asphalt concrete. On an annual average this
amounts to 80 to 90 metric tons (ca. 90 to 100 tons) of asbestos per
asphalt concrete plant that manufactures asbestos-asphalt concrete
mix. The plants generally use the asbestos within a short period
of time, usually less than one week. Although the annual amount
of asbestos used by the individual plants is not unusually high, the
rate at which individual plants use the asbestos is very high.
Ninety tons of asbestos when used in one week yield an equivalent
usage rate of 4500 metric tons (ca. 5000 tons) of asbestos per year.
In such a situation it is possible to have high concentrations of
asbestos in the vicinity of the plant during the period of usage.
The asbestos emissions of most concern are associated with
the asbestos handling and mixing operations that occur during
the manufacture of asphalt concrete. The asbestos fibers are
bound into the asphalt concrete product, and the asbestos emissions
that occur during the handling and use of the asphalt-concrete
product are not considered to be major sources of asbestos emissions.
In the manufacturing process, asbestos is mixed with dried
aggregate. After a short dry mixing time, hot liquid asphalt
is added to the asbestos-containing aggregate and thoroughly mixed.
Asbestos emissions to the outside air can occur during the addition
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of asbestos to the mixing device and from ventilation gases during
the mixing operation. Asbestos is added to the mixing device
during the dry aggregate mixing stage by use of an enclosed
conveyor or, more commonly, by dumping asbestos directly into the
mixer in unopened plastic bags. When asbestos is added to the mixer
by an enclosed conveyor, asbestos emissions can occur during the
emptying of asbestos into the conveyor hopper and from the
ventilation of the mixer. The asbestos emissions during the
bag-emptying operation can be controlled by hooding and ventilation
of the asbestos-addition hopper. In the other, more commonly used
asbestos addition method, the plastic bag is ruptured by the mixer
and its contents thoroughly mixed with the aggregate. The empty
plastic bags melt and become part of the product when the hot asphalt
is subsequently added to the asbestos-aggregate mix. If the mixer
is properly ventilated and under negative pressure, no asbestos
emissions should result at the point of addition of the asbestos
bags; however, the mixer ventilation gas stream is an asbestos
emission point.
The raw material handling and the mixing operations potentially
generate asbestos emissions comparable to those from manufacturing
operations presently covered by the promulgated asbestos standard.
Since the asbestos emissions at asphalt batch plants are directly
proportional to the asbestos usage rate, and because some plants
use relatively large quantities of asbestos for certain periods
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of time, the Administrator has determined that the manufacture
of asphalt concrete is a major source of asbestos emissions
and is therefore proposing to cover it under the asbestos standard.
The gas streams that ventilate the mixing operation and
product-handling operation present no unique problem in employing
commercially available particulate control devices. The asbestos
emissions from the ventilation gas stream of the asbestos-addition
hoppers and the mixer ventilation gas streams can be effectively
controlled with commercially available technology.
The standard for asbestos manufacturing operations
allows no visible emissions of asbestos-containing particu-
late matter to the outside air from the facility or, as
an alternative, the use of specified fabric filtration devices
or other control devices of equivalent effectiveness. The proposed
amendment would make this provision applicable to asphalt concrete
plants.
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3. ASBESTOS: DEMOLITION AND RENOVATION
SUMMARY OF PROPOSED AMENDMENTS
The proposed standard applies to two types of operations:
(1) The demolition of any institutional, commercial,
or industrial building (including apartment buildings
having more than four dwelling units), structure,
facility, installation, or portion thereof which contains
any pipe, boiler, tank, reactor, turbine, furnace, or
structural member that is insulated or fireproofed
with friable asbestos material.
(2) The renovation of any institutional, commercial, or
industrial building, structure, facility, installation,
or portion thereof involving the removing or stripping
of friable asbestos materials used to insulate more
than 80 meters (ca. 260 feet) of pipe, or the removing
or stripping of more than 15 square meters (ca. 160
square feet) of friable asbestos material used to insulate
or fireproof any boiler, tank, reactor, turbine, furnace,
or structural member.
The owners or operators of these operations must comply
with the following requirements:
(1) Intention to demolish or renovate and specified
details of the operation must be declared to the
Administrator in a written notice postmarked at least
10 days prior to commencement of demolition, or as early
as possible prior to commencement of either emergency
demolition or renovation.
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(2) Prior to wrecking, all friable asbestos materials
except those encased in concrete or similar material
must be removed, either by dismantling in units or
sections any apparatus that is insulated or fireproofed
with friable asbestos materials or by stripping the
asbestos materials from the apparatus. Handling procedures
for removal are specified.
(3) Throughout the removal and handling operations, all
asbestos materials must be wetted except that:
(a) Specified atr cleaning methods (see Appendix A)
may be used as an alternative to wetting for stripping
apparatus that has been removed in units or sections.
(b) Wetting requirements are suspended in certain
instances when the temperature at the point of
stripping is below 0°C (32°F).
(4) The demolition of buildings that have been determined to
be structurally unsound and in danger of imminent collapse
is exempt from certain requirements, including the removal
of friable asbestos materials prior to wrecking.
RATIONALE FOR THE PROPOSED AMENDMENTS
After promulgation of the asbestos demolition standard on
April 6, 1973, several questions and comments from demolition
contractors were brought to the attention of the Agency concerning
identification of friable asbestos materials, reporting procedures,
and work practices acceptable under the standard. In response,
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certain clarifying changes which did not alter the intent or stringency
of the standard were promulgated on May 3, 1974 (39 FR 15396). In
addition, the Agency investigated those questions which involved
possible changes in the intent of the regulation. Demolition
operations involving a variety of sizes and types of buildings
were visited, samples of friable and non-friable asbestos materials
were taken, and demolition practices were observed. Additional
information was obtained through discussions with demolition
trade association personnel, demolition contractors, and local
and State air pollution control personnel (see Appendix D).
The investigation indicated that amendments to the asbestos
standard were necessary to more clearly define the intent of
applicability of the standard, to extend the coverage of the
standard, and, for some operations, to make the standard less burdensome
to demolition contractors without decreasing the protection afforded.
Therefore, amendments to the standard are being proposed to extend
coverage to renovation operations and the stripping and removal
of certain items in addition to pipes, boilers, and load-supporting
structural members; to suspend certain wetting requirements under
freezing weather conditions; and to clarify the types of materials
and operations intended to be covered by the standard.
Addition of Renovation Operations
The asbestos standard applies to demolition operations that
involve the wrecking of load-supporting structural members. Certain
major renovation operations, where load-supporting structural
members are not wrecked but where significant quantities of friable
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asbestos materials are removed, will potentially result in asbestos
emissions of a magnitude similar to that from demolition. The Administrator
has determined that a four-unit apartment building, the maximum size
apartment building that is excluded from the asbestos demolition
standard, could contain up to 80 meters of insulated pipe and
15 square meters of insulation on a boiler. Renovation operations
involving the removal or stripping of quantities of friable asbestos
in excess of this amount would create asbestos emissions of the same
magnitude as the demolition operations presently covered by the
standard. Therefore, the Administrator is proposing to extend the
asbestos standard to cover renovation operations of the scale
previously described.
Rather than requiring 10 days' notice of intention to renovate
as in demolition operations, the Agency has specified that notice of
any renovation operation must be provided as early as possible prior
to the commencement of the operation. In some renovations, such as
the replacement of a boiler in an apartment building, it may be
infeasible to delay taking corrective action in order to provide 10
days' notice. Since the amount of notice which is feasible will vary
from case to case, the Agency has made this requirement flexible.
Revisions in Demolition Procedures
The definition of "demolition," which was promulgated
May 3, 1974 (39 FR 15396), potentially allows circumvention
of the intended applicability of the asbestos standard. Under
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the original wording, removal of friable asbestos materials is
not strictly considered "demolition" if it is accomplished prior
to "the wrecking or removal of-any load-supporting structural member."
The intent of the standard is to control emissions from the
stripping and removal of the friable asbestos materials as well
as from the actual wrecking operations. Consequently, a revision
to the definition of "demolition" is being proposed to clarify
that demolition involves the removal of friable asbestos materials
or specified items insulated or fireproofed with friable asbestos
materials as well as the wrecking and removal of load-supporting
structural members.
Under the asbestos standard, only demolition involving
boilers, pipes, and load-supporting structural members insulated
or fireproofed with friable asbestos materials is required
to be controlled. However, enforcement of the standard has
revealed that the stripping or removal in units or sections of
tanks, reactors, turbines, furnaces, and non-load-supporting structural
members covered with friable asbestos materials can generate asbestos
emissions of a similar magnitude. The Administrator has therefore
determined that the asbestos demolition standard should be
expanded to regulate the stripping or removal in sections of
these specified items as well, since these operations also constitute
significant sources of asbestos emissions.
In addition, the asbestos demolition standard is being extended
to regulate the stripping of friable asbestos materials from units
or sections of pipes, boilers, tanks, reactors, turbines, furnaces,
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and structural members after their removal from a facility that
will be demolished. Significant asbestos emissions can occur from
such operations, and the Administrator is proposing that these
operations should also be regulated by the asbestos demolition
standard.
Demolition contractors have commented that the requirement
for all friable asbestos materials to be removed from a building
or structure prior to beginning demolition is not necessary in
certain types of sectionalized structures which are independently
supported, and that this requirement is unnecessarily burdensome.
The Agency visited demolition sites where buildings and structures
were being demolished in sections and observed that friable
asbestos insulation in one independently supported section was not
disturbed by demolition procedures in the adjoining sections.
The stringency of the standard will not be altered by allowing
this practice under appropriate conditions. The Administrator is
therefore proposing that the demolition standard be amended to allow
a load-supporting structural member to be wrec'-ed before all friable
asbestos material is removed from a building or si ucture, provided
that: (a) the friable asbestos material in the area that is being
actively wrecked is first removed according to the procedures required
by the standard, and (b) the friable asbestos material in areas not
being wrecked is not broken up and can still be stripped or removed
prior to active wrecking in those areas.
Definition of "Friable Asbestos Materials^'
The asbestos standard specifies work practices for the handling
of asbestos materials during demolition operations only if those
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materials are "friable." The use of the word "friable" is intended
to distinguish between such materials as vinyl-asbestos floor tile,
in which the asbestos fibers are well bound, and such materials
as the common types of molded asbestos pipe insulation, from which
the asbestos fibers can be readily released. The intent of the
asbestos standard is not to control handling of vinyl-asbestos
floor tile, asbestos felt roofing, or other similar materials, since
it is the Administrator's judgment that such activities will not
release asbestos in a manner which is dangerous to human health.
However, the standard does not specify a rrjethgd for determining
if a particular asbestos-containing material is "friable." Therefore,
in order to make the intent of the standard more explicit, the
Agency is proposing to define "friable asbestos materials" as "any
materials that contain more than 1 percent asbestos by weight and
that can be crumbled, pulverized, or reduced to powder, when dry,
by hand pressure."
"Friable asbestos materials" is defined to exclude those
materials that contain less than 1 percent asbestos by weight.
The exclusion is intended to be consistent with section 61.22(e)
of the asbestos standard which permits the use of spray-on asbestos
insulation or fireproofing that contains less than 1 percent asbestos
by weight. In the past, asbestos insulation or fireproofing materials
have generally contained between 10 and 90 percent asbestos by weight.
No known materials now contain less than 1 percent asbestos
by weight except spray-on insulation or fireproofing products
and materials that contain asbestos as a natural contaminant.
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It is the Agency's proposed intent that such spray-on materials
not be subject to the stripping and removal provisions of the
demolition standard.
The Agency has received several comments from demolition trade
associations and air pollution control personnel concerning the
friability of corrugated asbestos paper insulation. The determination
of whether this type of insulation is friable is complicated, because
in some cases it is not friable and in other cases it seems to be.
Friability of such paper seems to depend on the degree of deterioration
of the paper binders. New paper insulation does not seem to be
friable; however, if the insulation has been installed for a long
period of time and subjected to a series of wetting and drying cycles,
it is more likely that the binders will deteriorate and that the
material will become friable. Therefore, the determination
of whether corrugated asbestos paper insulation is friable or
not will be made on a case-by-case basis. If demolition contractors
have questions concerning whether a particular asbestos paper
insulation product is friable, they should request assistance from
the Enforcement Division of the appropriate EPA Regional Office.
Suspension of Certain Wetting Requirements in Sub-Freezing Temperatures
The asbestos standard contains no exemption from the
wetting requirements during cold weather conditions. Demolition
contractors commented that wetting at temperatures below 0°C produces
freezing of oversprayed water and hazardous footing for workers.
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On the basis of observations of demolition sites during freezing
weather, the Administrator has determined that the spraying of water
in those areas where workers will be walking presents a serious
hazard. The Agency is proposing a narrow exemption from the wetting
requirements during freezing weather in an attempt to balance the
hazards of workmen slipping on ice and of increased asbestos
emissions due to stripping inside of a building without wetting.
It should be noted that only the wetting requirements are suspended
in freezing weather; friable asbestos materials must still be
removed from buildings prior to wrecking.
Procedures are specified in the proposed amendments which
will minimize asbestos emissions when the wetting requirements are
suspended because of freezing weather. Friable asbestos materials
must be removed in sections whenever possible prior to the commence-
ment of actual wrecking. Once these sections are removed from
buildings, subsequent stripping of friable asbestos materials is
not exempt from the wetting requirements, regardless of outside
temperature. Additionally, friable asbestos material wastes must
be wetted under all circumstances. The Administrator has judged
that, when the above measures are taken, the suspension of wetting
requirements during freezing weather will continue to protect
human health with an ample margin of safety.
Methods other than wetting with water, such as the use of anti-
freeze compounds, portable evacuation hoods and associated air filtering
equipment, and the suspension of demolition operations in freezing
weather were determined to be infeasible. The increment of
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additional emission control to be gained by each of the above
alternatives is outweighed by practical difficulties.
Emergency Reporting Requirements
An amendment to the asbestos standard is being proposed which
makes the reporting requirements for emergency demolition operations
more explicit. Only buildings, structures, facilities, and
installations which have been ordered to be demolished by an authorized
representative of the State or local governmental agency responsible
for building demolition would be exempted from the requirement
of removing asbestos materials before demolition. However, the
proposed amendment requires that the portions of the structure
containing friable asbestos material must be wetted during the
wrecking operation. This requirement applies even in freezing
weather, since the spraying operation will not endanger workmen
within the building. As specified in the asbestos standard,
it is also necessary that the building, structure, facility, or
installation be structurally unsound and in danger of imminent
collapse. Agency personnel contacted State and local governmental
agencies responsible for building demolition to determine the
approximate annual number of emergency demolition operations.
No specific number was obtained, but estimates from State and
local governmental agencies indicated that emergency demolition
operations do not occur frequently.
Under the proposed amendment, the report of intention to demolish
submitted by the owner or operator of the demolition operation must
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include the name, title, and authority of the person who. orders
the demolition to be carried out. The proposed amendment requires
such reports to be postmarked as early as possible prior to the
commencement of demolition.
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4. ASBESTOS: FABRICATION
SUMMARY OF PROPOSED AMENDMENTS
There shall be no visible emissions to the outside air
from the following operations:
(1) The fabrication of friction products, excluding those
operations that primarily install asbestos friction
materials on motor vehicles.
(2) The fabrication of asbestos-cement building products.
(3) The fabrication of asbestos-cement 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.
As an alternative to the no-visible-emission standard, specified
air-cleaning methods may be used (see Appendix A).
Molded insulating materials that are friable and wet-applied
insulating materials that are friable after drying, installed after
the effective date of the standard, shall contain no commercial asbestos.
Spray-applied insulating materials are excluded.
RATIONALE FOR THE PROPOSED AMENDMENTS
Asbestos is used in numerous products because of its multi-
beneficial properties. For example, one company advertises that
there are over 3200 end uses for asbestos. Although the number of
specific uses is large, the major uses of asbestos can be categorized
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into the following groupings:
Table 4-1. ASBESTOS CONSUMPTION BY MAJOR PRODUCT CATEGORIES
1972 Consumption1
Asbestos End Use (Metric Tons) (Ca. Short Tons) Percent
Floor Tile """80,800 89,000 Vl
Friction Products 73,600 81,000 10
Felt and Paper 109,900 121,000 15
Packing and Gaskets 29,000 32,000 4
Textiles 7,300 8,000 1
Sprayed Insulation 14,500 16,000 2
Construction Industry 308,700 340,000 42
Miscellaneous 109,900 121,000 15
This listing is based on the most recent Bureau of Mines reporting
format. It differs significantly from the method previously used to
present such data because it is based on an expanded list of
consumers. A further breakdown of the 42 percent tis-ed in the
construction industry ts:
Asbestos-Cement Pipe 19%2
Asbestos-Cement Building Products 7%
Floor Tile used in Construction 8%
Miscellaneous Q%
Many of these products are fabricated, either at the manufacturing location
or at a separate location, prior to application in an end use.
Some fabrication involves cutting or shearing operations which
do not generate large quantities of asbestos emissions, for example,
the cutting to size of vinyl-asbestos floor tile during installation.
In other instances, processing which could be performed at fabrication
22
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sites is incorporated into manufacturing operations; emissions from
this type of processing are already covered by the asbestos standard.
However, some fabrication operations, such as the grinding of motor
vehicle brake linings, can be carried out either at the site of manufacture
or at a different central fabricating site. Fabrication at a different
site is not covered by the asbestos standard.
The petition of the Environmental Defense Fund questioned the
exclusion of fabrication operations from the asbestos standard. As
a result of these questions, the Agency visited 15 plants that perform
fabricating operations on manufactured asbestos products and consulted
with several plant operators and trade associations (see Appendix D).
From this investigation, it was concluded that asbestos products other
than friable insulating products are field-fabricated to only a limited
extent, but that the fabrication of certain categories of asbestos
products in central shops is a major source of asbestos emissions. The
investigation was thus divided into the two main areas of field fabrication
and central shop fabrication.
The proposed asbestos standard for fabrication includes all known
major fabrication categories. The major fabrication categories were
determined by the Agency to be the fabrication of friction products,
the fabrication of asbestos-cement products, and the fabrication of
asbestos-cement or -silicate boards for several end uses. These
categories account for approximately 40 percent (see Table 4-1) of
the asbestos consumed in the U. S. The asbestos product categories
of floor tile, felt and paper, packing and gaskets, textiles, and
sprayed insulation account for approximately 35 percent of the U. S.
asbestos consumption, but do not generate significant amounts of
asbestos emissions.
"3
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Field Fabrication
The investigation revealed that installation of friable asbestos
insulation materials for pipe, boilers .tanks, reactors, turbines, and
furnaces is the only known major source of asbestos emissions from
field fabrication. The task of installing and removing asbestos
insulating materials is a known source of occupational asbestos
exposure.3'4'5 Asbestos products have been used extensively for thermal
insulation of pipes, boilers, tanks, reactors, and furnaces. The
products are used in residential, commercial, and industrial buildings,
as well as on ships. The asbestos functions as a reinforcing agent
in molded semicircular sections, sheets, and blocks of such materials
as magnesium carbonate and calcium silicate.
Molded asbestos '.insulation is field-fabricated by cutting and
sawing the insulating material at the site of installation to fit
contours of specific equipment. This type of field fabrication
was common practice in the past, frequently at new construction sites
for buildings and industrial plants. Powdered material of similar
composition is mixed with water into a slurry and applied by hand trowel
to fill the crevices between molded sections and to insulate irregular
shapes. Most of the molded asbestos insulating products are friable
and can create, along with wet-applied insulation, significant amounts
of dust during field-fabrication operations. Some control methods
exist for installation, but these methods still permit asbestos
emissions.
The use of molded asbestos insulation is currently being phased
out.6'7 Asbestos-free insulating products have been developed
for a number of applications largely because of the known occupational
24
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hazards of installing products such as the common types of molded
asbestos pipe insulation. These substitutes are available for the
complete range of temperature requirements. Fiberglass is used at
lower temperatures and refractory fiber insulations can be used
for extremely high temperature requirements.^
Because an economical and effective control method (i.e.,
the adoption of asbestos-free insulating products) is available,
the Administrator has determined that, in order to protect public
health with an ample margin of safety, it would be prudent to
prohibit the use of friable asbestos insulating products and
is proposing to do so. Even though the use of these asbestos
products in the U. S. has been largely discontinued, a regulation
is necessary to stop the use where it is being practiced and to
prevent the possible future use of friable asbestos insulating
products.
Asbestos products other than insulating products are field-
fabricated to only a limited extent. Asbestos-cement pipes,
asbestos-cement building products, and asbestos board products were
found to be fabricated almost completely in central shops. The
only required field fabrication of such products is drilling holes
and cutting pieces to fit in a limited number of cases. The Agency
found that the asbestos-cement products that were field-fabricated
were usually cut with knives or saws equipped with dust-collection
devices, and holes were drilled with drills equipped with dust-
collection devices. Accordingly, the Agency has determined that the
field fabrication of asbestos products other than insulating products
is not a major source of asbestos emissions to the air.
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Central Shop Fabrication
Friction Products -- Enforcement of the asbestos standard revealed
the existence of facilities that fabricate large quantities of
automotive brake shoe linings, but do not manufacture the linings.
These fabrication sources are not covered by the standard because
the Agency was not aware of them at the time of promulgation. The
fabricating operations performed at these facilities are similar
to those performed at asbestos friction product manufacturing plants
which are covered aS major sources of asbestos emissions by the
asbestos standard. The amount of dust generated from grinding,
drilling, sanding, and cutting operations is about 450 grams
(ca. 1 pound) for every 30 brake shoes fabricated. For a large
facility that fabricates over 2 million brake shoes per year, this
amounts to over 27 metric tons (ca. 30 tons) of asbestos dust per
year. Because the operations are also similar in quantity of
asbestos emissions generated, the Agency is proposing that the
asbestos standard be amended to include these fabrication operations
Agency representatives also visited several individual brake
shoe installers to inspect the facilities and operations. The
installers radius-grind wheel drums as well as brake shoes to
ensure good braking immediately after installation. Relatively
small quantities of asbestos-containing dust are generated by the
individual installers, and even these small quantities were well
controlled by fabric filters at the facilities inspected. The
combination brake drum grinding and brake shoe radius-grinding
26
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machines are equipped with a local dust pickup and a small integral
fabric filter for collection of the brake dust. On the basis of
these inspections, the Administrator has concluded that these operations
do not cause an atmospheric emission problem, and therefore these operations
are not included in the proposed fabrication standard.
Building Products — Asbestos is used in numerous cement building
.products. The most common asbestos-cement building products include
flat sheets, corrugated sheets, shingles, and panels which are
used for walls and roofs of industrial buildings, canal bulkheads,
cooling tower construction, and other applications. Agency personnel
visited three distributors of asbestos building products that performed
fabricating operations in a central shop. The major fabrication
operations at these facilities involved sawing, trimming, drilling,
and grinding of asbestos-cement building products to meet customer
specifications. Cooling tower manufacturers that were contacted
have all sheets cut and drilled for each cooling tower by the
asbestos sheet manufacturer or distributor at a central fabricating
shop. Fabrication in the field is done only occasionally when a
pre-cut and pre-drilled sheet will not fit.9>10 The flat asbestos
sheets as used in homes, barns, or other inexpensive construction
are usually installed with fasteners or nails and require little
drilling. Similarly, asbestos shingles are delivered to the job
site with pre-punched holes and are nailed to the house. Additional
holes are punched out in the field with an anvil puncher, and the
siding shingles are cut using a guillotine cutter and knife. Little,
if any, field fabrication occurs which could cause asbestos emissions.
Fabrication of asbestos-cement pipe by the manufacturers involves
27
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machining ends and cutting pipe to exact dimensions which provides
for easy assembly and a water-tight fit. Therefore, fabrication of
asbestos-cement pipe rarely occurs after the pipe leaves the
manufacturing location. The only field fabrication is an occasional
cutting or tapping of a pipe. The amount of asbestos-containing dust
generated by central shops that fabricate asbestos-cement building
products was estimated to be approximately 90 kg/week (ca. 200 Ib/week).
The Administrator has judged that uncontrolled asbestos emissions from such
fabrication shops are comparable to uncontrolled asbestos emissions
from asbestos manufacturing sources presently covered by the standard,
and therefore is proposing standards to limit asbestos emissions
from these sources.
Specialty Products—Asbestos-cement and asbestos-silicate boards are used in
construction of ovens, electrical panels, laboratory furniture,
ship bulkheads, and flow control devices for the molten metal industry.
For example, the molten metal industry requires 1,200,000 board feet
of heat-treated asbestos boards per year. The number of plants
using these boards is large and includes most of the primary aluminum
plants as well as many other molten metal handling operations. The
largest of these facilities do their own fabricating work, though
many have it fabricated by distributors or small machine shops. Data
from an aluminum plant that was visited showed that the dust generated
during machining of flow control devices for the molten metal industry
could amount to 1/3 of the board weight prior to machining.
Asbestos board products are also used for bulkheads and ceilings
in commercial vessels and as partition walls in the living quarters
28
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of offshore oil derricks. Approximately 64 metric tons (ca. 70 tons)
were installed on one transport ship which was inspected by Agency
personnel. According to discussions with asbestos product manufacturers,
there are probably fewer than 10 distributors of asbestos board to
the marine industry, and fabrication performed by the distributors
generally involves cutting 4- by 8-ft sheets to specified lengths on
table saws. The Administrator has judged that uncontrolled asbestos
emissions from the fabrication of asbestos-cement and silicate boards
for ventilation hoods, ovens, electrical panels, laboratory furniture,
marine construction, and flow control devices for the molten metal
industry are comparable to uncontrolled asbestos emissions from asbestos
manufacturing sources presently covered by the asbestos standard and
therefore is proposing an amendment to limit asbestos emissions from
these sources.
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REFERENCES
1. Clifton, R. A., "Asbestos," Preprint from the Bureau of Mines
Minerals Yearbook, U. S. Department of the Interior, Bureau
of Mines, Washington, D. C. , 1972.
2. "U. S. Asbestos-Containing Product Shipment Values and Asbestos
Tonnages Used, for the Year 1971," Asbestos Information Association
of North America, Asbestos Magazine, p. 33, December 1973.
3. Mangold, C. A., R. R. Beckett, and D. J. Bessmer, "Asbestos Exposure
and Control at Puget Sound Naval Shipyard," Puget Sound Naval Ship-
yard, March 1970.
4. Selikoff, I. J. , Jacob Churg, and E. C. Hammond, "Asbestos Exposure
and Neoplasia," JAMA 188:22, April 6, 1964.
5. Marr, W. T. , "Asbestos Exposure During Naval Vessel Overhaul,"
American Industrial Hygiene Association Journal 25:264, May- June
~
6. National Insulation Contractors Association, "Notice of Application
for Variance and Interim Order; Denial of Interim Order," Federal
Register, August 23, 1973, pp. 22687-22691.
7. Phone conversations with John Wishaerd, Naval Supply Depot, April
5 and 9, 1974.
8. Phone conversation with Jack Barnhart , The Thermal Insulation
Contractors Association, March 14, 1974.
9. Meeting with Al Fay of National Gypsum, Ike Weaver of Raybestos-
Manhattan, and Robert Mereness of the Asbestos Information Association
of North America on March 1, 1974.
10. Phone conversations with cooling tower fabricators, the Marley
Company and Research Cottrell , February 22, 1974.
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5. DISPOSAL OF ASBESTOS WASTES
SUMMARY OF PROPOSED AMENDMENTS
Disposal of Wastes from Manufacturing, Fabricating. Demolition,
Renovation, and Spraying Operations
There shall be no visible emissions to the outside air from
any stage of waste handling, extending from collection through
deposition, of:
(1) Asbestos-containing waste generated by manufacturing and
fabricating operations, and by the sprayed application of
asbestos insulating or fireproofing materials, and
(2) Friable asbestos waste and control device asbestos waste
generated by demolition and renovation operations.
Alternatives to the no-visible-emission standard include:
(1) Specified wetting, packaging, and labeling procedures.
(2) Pelletizing of wastes into non-friable pellets prior to
disposal. Either the collecting and the pelletizing
of the wastes shall generate no visible emissions to
the outside air, or specified air cleaning methods
(see Appendix A) shall be used for these operations.
(3) Other disposal methods approved by the Administrator.
Incineration of containers that previously contained commercial
asbestos is prohibited.
Disposal of Wastes from Asbestos Mills
There shall be no visible emission to the outside air from
any stage of waste handling, extending from collection through
deposition, of asbestos ore tailings or control device asbestos
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waste generated by an asbestos mill.
As an alternative to the no-visible-emission standard, the
wastes may be transferred to the tailings conveyor in a manner
that generates no visible emissions to the outside air and may
then be wetted with a dust-suppression agent in a manner that
generates no visible emissions. Control device asbestos waste
may also be handled according to the alternative procedures specified
for wastes generated by manufacturing, fabricating, demolition,
renovation, and spraying operations (see previous section).
Haste Disposal Sites
There shall be no visible emissions to the outside air from
either active or inactive waste disposal sites where asbestos-
containing waste has been deposited.
Warning signs shall be posted at all entrances to active or
inactive waste disposal sites and at least every 100 meters
(ca. 330 feet) along property lines. Legend and format of the
signs are specified in the regulation.
Asbestos-containing sections of waste disposal sites shall
be fenced to deter public access unless specified requirements
for covering the area with non-asbestos-containing materials are met.
Alternatives to the no-visible-emission standard are divided
according to the type of site:
(1) Active sections -- Application of a dust-suppression agent
or a 15-centimeter (ca. 6-inch) layer of non-asbestos-containing
material at the end of each operating day or once every 24 hours
when the site is in continuous operation.
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(2) Inactive sections of disposal sites other than asbestos
mill tailings disposal sites — Application of a 15-
centimeter (ca. 6-inch) layer of compacted non-asbestos-
containing material on which a vegetation cover adequate
to control wind and water erosion is maintained, or
application of a 60-centimeter (ca. 2-foot) layer of
compacted non-asbestos-containing material maintained
to prevent exposure of the asbestos waste from erosion.
(3) Inactive sections of asbestos mill tailings disposal sites' --
Application of dust-suppression agents sufficient to
control wind erosion, or either of the two methods specified
for inactive sections of disposal sites other than asbestos
mill tailings disposal sites (see previous item).
RATIONALE FOR PROPOSED AMENDMENTS
The petition of the Environmental Defense Fund, et al., questioned
the exclusion of asbestos waste disposal operations, including
some portions of asbestos mill tailings disposal operations, from the
Standard. In response to the questions raised, the Agency
initiated a further study of emissions from the disposal of
asbestos-containing waste materials. During the course of this
investigation, which covered the waste disposal process from the
point of waste generation to the ultimate disposal site, waste
disposal practices were observed at six asbestos mill tailings
disposal operations, twenty-three fabrication and manufacturing plants,
one demolition waste disposal operation, and six ultimate waste
disposal operations.
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From observations at various facilities of the quantity
of waste handled, dustiness of the waste, and types of handling
operations necessary to dispose of the waste, it was concluded
that major asbestos emissions could occur at any point during the
disposal operations from the collection of asbestos-containing
waste to the depositing of the waste at a disposal area. The improper
operation of a disposal site where asbestos-containing waste is
deposited can also result in emissions from both active and
inactive portions of the site. The Agency's investigation included
ambient air studies in the vicinity of a large asbestos mill
tailings disposal site and a large manufacturing and fabrication
asbestos waste disposal site. The investigation concluded that:
(1) the disposal of asbestos waste generated by asbestos manufacturing,
fabrication, spraying, renovation, and demolition operations is a
major source of asbestos emissions and that emissions from all
stages of waste disposal, from collection to deposition at a
disposal site, from these operations should be regulated;
(2) the disposal of tailings and other wastes from asbestos
mills is a major asbestos emission source and that emissions
from all stages of waste disposal,.' from collection to deposition
at a disposal site, should be regulated; and (3) the asbestos
emissions from asbestos waste disposal sites are a major asbestos
emission source and should be controlled.
Process Wastes
Asbestos Manufacturing Waste — The manufacture of numerous asbestos-
cement board products involves mixing asbestos with cement, water and,
other additives; the mixture is subsequently allowed to dry or cure.
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Some of the products must be finished by grinding, sawing, and
polishing while others are ready for shipment without any fabrication.
Examples of products include high-density monolithic (stonelike)
board, asbestos board for marine applications, heat-treated
asbestos boards for marine applications, heat-treated asbestos
boards for the molten metal industry, corrugated asbestos siding,
and blackboards.
Four basic types of asbestos wastes were observed which can
exist at almost all asbestos-cement board plants: process slurry
wastes, asbestos dust collected in baghouses, scrap product, and
empty bags which previously contained asbestos. Amounts of each
type of waste depend on the product being made and the finishing
required. For example, a large plant that produces 3 million
board feed of product per year generates each day approximately
8 cubi.c meters (ca. 10 cubic yards) of dust, 9 cubic meters (ca.
12 cubic yards) of scrap board, and 9 cubic meters (ca. 12 cubic yards)
of empty paper bags that previously contained asbestos.
Fourteen pipe plants in the U.S. manufacture for various uses
asbestos pipe that ranges from 7.6 to 122 cm (ca. 3 to 48 inches)
in diameter. Differences were observed in the waste disposal practices
at the plants that were visited during the investigation, but the
techniques that were observed are representative of those used at
other asbestos-cement pipe plants.
Substantial amounts of dust and other waste are created in
the manufacturing of asbestos-cement pipe. The types of waste
generated at pipe plants include dust from various cutting and
machining operations, scrap and broken pipe, slurries, and solid
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waste that includes asbestos shipping bags (both plastic and paper).
The slurry is a waste product from the process and contains residual
constituents that do not bind into the pipe. As an example of the
quantity of waste generated, a pipe plant in California generates
6 cubic meters of dust, 14 cubic meters of paper bags and pipe, and
450 kg (ca. 1000 pounds) of slurry process waste each day.
In the production of friction products, asbestos emissions are
controlled from the handling of asbestos in bags and operations
(such as weighing of raw materials, charging of mixers, blending
of component ingredients, and discharging of mixers) that involve
asbestos in dry-mixed molding compounds. However, fabricating operations
on the products can generate much greater quantities of asbestos-
containing dust from the use of band saws, abrasive wheels, drills,
cylindrical grinders, and circular saws. The grinding and drilling
of brake linings during manufacture release as much as 30 percent
of the lining material as waste. In most cases these emissions
are significant and are collected in baghouses. Discussions
with plant operators indicated that 12,200 to 45,400 kg (ca. 27,000
to 100,000 pounds) per month can be generated by large brake shoe
manufacturing facilities. The only other asbestos wastes are
rejected products and paper or plastic bags which contained asbestos.
Wastes from the manufacture of asbestos paper consist of
asbestos sludge from the waste water and scrap pieces of asbestos
paper from edge trimmings and defective rolls. The asbestos fibers
are held together with such binders as starch, glue, water glass,
resins, latex, cement, and gypsum. Most of the scrap waste and
sludge can be recycled except when binders like rubber are used.
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The paper bags containing the asbestos are pulpable and become part
of the final product. The cohesive nature of the sludges
waiting to be recycled and the entrapped asbestos fibers in
scrap paper reduce any potential airborne emission problems.
Asbestos textile mills consume 1 to 3 percent of the
asbestos used in the U.S. in the production of roving, carded
lap, yarn, cord, rope, square-plaited goods, braided tubing,
tape, webbing, and cloth. Based on an inspection of a small spinning
operation, wastes consist of dry dusty asbestos, wet slurry
waste, and rejected pieces of yarn. Amounts of waste vary
depending on the size of the operation and the types of products.
The small yarn spinning operation which was inspected disposed of
9 kg (ca. 20 pounds) of waste per day.
All manufacturing operations producing asbestos-containing
products have the potential to create waste disposal problems.
The emission potential associated with! the wastes differs depending
on binding agents and dustiness of the waste. For example, cement
building products, in which the asbestos fibers are tightly
bound, will pose lesser air pollution problems during disposal.
Most plants mix asbestos waste such as shipping bags with non-
asbestos waste, and the local waste collector, either public or
private, picks up the mixture and usually dumps it in a landfill
area. These asbestos-containing waste materials are usually disposed
of without regard to their potential as emission sources.
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Asbestos Fabrication Waste -- The basic fabrication operations of
sawing, shearing, grinding, milling, and drilling of manufactured
asbestos products generate asbestos dust which' is vented to and
is collected by control devices. The asbestos-containing waste
generated from such operations includes control device waste as
well as scrap products from the fabrication operations.
Asbestos Demolition and Renovation Waste -- The waste generated
by demolition and renovation operations is friable asbestos
material waste, vacuum cleaner dust, and units insulated or fire-
proofed with friable asbestos material. The asbestos waste can
be removed from units or sections in pieces or left intact on
pipes, boilers, and other items, and the whole unit disposed of
in a section. The waste generated from renovation operations is
similar in nature to demolition waste.
Asbestos Spraying Waste -- Asbestos-containing waste from the spray
application of asbestos fireproofing and insulating products
consists mainly of oversprayed products. Approximately 10 percent
of the material that is sprayed ends as waste material and has to
be disposed of. This material is usually collected by sweeping
and scraping after a spray application and usually is disposed of
in a slightly wet form.
Asbestos Mill Waste -- Mill waste consists of the ore tailings,
which vary in size from dust to 1/2 inch diameter, and control device
asbestos waste (baghouse dust). All mills except one product dry
tailings. The exception uses a wet asbestos-extraction technique
and produces wet tailings.
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Waste Disposal Practices
Disposal of Manufacturing Wastes -- Asbestos waste materials generated
at manufacturing plants consist of process waste, control equipment
waste, scrap product waste, and emptied asbestos shipping bags.
Amounts and types of wastes that must be disposed of vary with the
product, production rate, and amount of waste that can be recycled.
Disposal practices vary somewhat among plants, but the basic
procedures are similar.
Collected baghouse dust and other dusty waste are disposed
of by (1) transferring the dust from the baghouse hopper to a
truck or trash dumpster, (2) transporting the dust to a disposal
site, and (3) depositing the dust in a landfill. Screw conveyor
systems are usually used to remove dust from baghouses, but an
emission-producing method of dumping the dust directly into a
truck is also used. At another plant, 6 cubic meters of dust
per day is placed in a truck and wetted down prior to being driven
to a county landfill operation. Although visible emissions generally
should not occur while the dust is in the dump truck, visible emissions
occur while the dust is being dumped and buried. Baghouse dust
that cannot be recycled at one plant is put into a dumpster and
transported to a company-owned waste pile. The handling of this
dust is a potential source of emissions. At one large plant,
11 cubic meters (ca. 15 cubic yards) per day is transported in a
dumpster to a slurry pond where the dust is emptied and later mixed
with water and slurry waste from the rest of the plant. An emission
problem does exist in this operation before the dust has been wetted.
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One method used to dispose of baghouse dust from machining operations
is to transport the collected dust (about 1 cubic meter per day in
a dumpster with the top sprayed with water and covered with a tarp)
to a pond where water is mixed with the dust to form a slurry, which
is subsequently mixed with waste slurry from the manufacturing process
Emission potential is reduced during transportation, but dust
near the pond shows some emissions still occur during dumping
operations.
To prevent asbestos emissions during transport to a landfill,
dust can be mixed with water, sprayed with water and covered,
transported in a closed container, or pelletized. The only disposal
techniques for baghouse dust that were observed to be emission-
free during landfill operations were those using sufficiently
wetted, pelletized, or slurried wastes. Where only small quantities
of dust must be handled, sealed plastic bags can be used to
contain asbestos fibers during disposal. Two asbestos brake
shoe lining manufacturers use pelletizing units to ensure dust-
free conditions during waste disposal operations. Baghouse dust
from one machining operation on asbestos boards is pelletized and
transported (about 8 cubic meters per day) to a landfill; this
method greatly reduces air pollution potential from the waste
during disposal.
Only one disposal technique used for non-friable asbestos
waste was observed to produce visible emissions. At an asbestos-
cement pipe manufacturing plant, scrap or reject pipe (about 900 kg
per day) that is not crushed and recycled to the process is
hauled by trucks to the plant-owned disposal dump. The company
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hires a contractor to crush the pipe with a bulldozer about every
8 weeks. Some emissions were visible during the crushing operation.
The visible dust usually settled to the ground in less than
15 seconds, and only crossed the plant boundary twice during
an 8-hour period.
One type of asbestos-containing waste common to almost all
manufacturers is shipping bags. The handling of these bags,
which contain residual amounts of asbestos fibers, presents
a potential emission problem. Several plants observed by the
Agency combine the bags with non-asbestos materials for disposal
by trash collectors. Several plants seal the emptied bags in
plastic bags before combining them in dumpsters or compactors
with non-asbestos waste for disposal. One asbestos-cement plant
seals the bags in plastic bags (about 9 cubic meters per day) and
then buries them in the plant landfill. One manufacturing plant
incinerates emptied bags contaminated with asbestos fibers, which
can result in asbestos emissions. There is no known control device
available that allows most solid waste incinerators to control
particulate emissions to the level achievable for such sources as
asbestos mills and manufacturing operations covered by the asbestos
standard. There are environmentally acceptable alternative disposal
methods for disposing of such waste, such as landfilling. Accordingly,
the Administrator has proposed to prohibit the incineration of
containers such as paper or plastic bags that previously contained
commercial asbestos.
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Process slurry wastes from manufacturing plants are disposed
of while wet and do not appear to pose atmospheric emission problems
during the disposal process. Each asbestos-cement manufacturing
plant has somewhat different disposal problems that depend on
location and recycle' capabilities. Volumes of process waste slurry
can be large; for example, at one plant about 23 cubic meters
per day of the wastes are pumped into a lagoon. Smaller amounts
of slurry wastes are dumped into the city sewer system at one
plant; this practice potentially causes a water pollution hazard.
Process slurry from an asbestos-cement pipe manufacturing plant
[about 45,000 liters (ca. 12,000 gallons) per week] is transported
to a section of a dump where it is allowed to dry in a settling
pond. When it reaches the consistency of damp clay, the material
is taken from the pond and stored in piles. This material is
finally mixed in layers with crushed pipe to form a solid waste
pile. One plant shovels slurry from a lagoon into piles where it is
allowed to partially dry before it is transported to a county landfill
(about 450 kg per day). The county dump requested that the
slurry be partially dried before it is brought to the landfill to
facilitate handling. Slurry from the settling pond at one plant
is scooped out, placed in closed containers on trucks, and taken
to the plant landfill. There appears to be no air pollution problem
in transporting the slurry to the plant landfill. At the landfill,
all plant waste is mixed with waste from the city and covered
within 24 hours. Slurry wastes are also disposed of from textile
manufacturing operations. Dried wastes from asbestos-cement
42
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products were observed to be cohesive and did not indicate
significant emission potential.
One of the best methods to reduce or eliminate waste
materials is to recycle them into asbestos manufacturing processes.
Asbestos-cement pipe plants recycle much of their dust waste
and scrap pipe. However, not all pipe can be recycled because
of either economics or type of pipe produced. Attempts have
been made to recycle dust from asbestos boards, but the result
was a weak product. All wastes at an asbestos paper plant can
be recycled except scraps of paper containing rubber-type binders.
Friction product scraps are generally not recyclable because
they degrade the quality of the product.
Disposal of Fabricating Wastes -- Asbestos fabrication waste materials
that must be handled can be classified into three basic types:
dusty wastes, slurry wastes, and material scraps. Most of the
dusty and slurry wastes are those collected by emission control
systems. The amount of this type of waste generated governs the
waste disposal techniques which can be used. For small amounts
of dust [up to about 0.3 cubic meters (ca. 10 cubic feet) per day],
plastic bags can be used as airtight containers during disposal.
Several methods are used to handle relatively small amounts
of dusty and slurry wastes at various plants. Waste collected
in the baghouses from table saw operations is placed inside
cardboard barrels and labeled with the OSHA asbestos warning
notice prior to disposal. Waste collected in cloth bags from
portable power tools is dumped into plastic bags, mixed with
cement and water, and then added to other trash for disposal.
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One central shop that sizes asbestos-cement boards prior to
shipment to a job site generates about 190 liters (ca. 50 gallons)
of dry dust per day from table saws. Eight liters (ca. 2 gallons)
per day of dust are collected from portable drills and saws used while
the boards are being installed. Waste generated from machining
asbestos boards for the molten metal industry varies in consistency
from fine dust (sawing and sanding operations) to chips (lathes
and drills). Waste generated from machining can amount to as much
as 30 percent of the board weight. About 380 liters (ca. 100 gallons)
per day of asbestos slurry is removed from a rotoclone at an aluminum
plant that was inspected by the Agency. This slurry is transported
by a dumpster and compactor to a landfill before it has time to
dry and become dusty. Baghouse waste from a large distributor of
molten metal board is sealed in plastic bags and placed in trash
dumpsters for transportation to a landfill. The amount of dust
generated from textile cutting operations is relatively small
and can be disposed of in impermeable containers.
Large quantities of dusty wastes are handled somewhat
differently than small amounts. Waste collected in large baghouses
at a brake shoe fabricating plant from drilling and grinding operations
is transported by truck to landfills and can amount to 12,200 kg
(ca. 27,000 pounds) per month for a plant producing 40,000 shoes
per day. At this plant, dust from the baghouse is dumped into a
special covered dump truck using canvas dust suppressors around each
spout. Some visible emissions were observed around the bottom of the
44
-------
baghouse, which indicates that emissions can occur during the operation
Water is then added and blended with the dust, using a large
mixer, before the loaded truck is washed to remove asbestos
dust and driven to a landfill. Some brake shoe fabricating plants
use pelletizers which, through the addition of water, convert the
dusty baghouse waste into small balls that are transported to
a landfill. Cement can be added to the pelletizer along with the
water as an additional binding agent for the asbestos.
Scrap asbestos wastes can often be handled in the same way
as non-asbestos wastes if the asbestos fibers have been bound or
encapsulated so that emissions to the atmosphere are not likely
to occur. This is the case for many asbestos wastes from fabrication
involving cement pipe, cement boards, cement building products,
friction products, floor tile, paper products (containing
appropriate binders), and many gasket materials. Scrap boards
from most operations inspected are placed in trash bins for
disposal along with non-asbestos wastes. One fabricator places
scrap boards from the cutting operations inside cardboard
drums which are lined with plastic bags. These are sealed,
transported to a storage area, covered with a plastic tarp, and then
trucked to a landfill. Scrap materials from fabricating operations
using paper consist of two types: scrap pieces of paper from
cutting operations and scrap or rejected pieces of finished
product. In most cases, finished product scrap has been modified
by the addition of a binding or waterproofing material such as asphalt
or vinyl, and this material should not pose an air pollution
threat regardless of disposal techniques used. Unmodified paper scrao
(excluding paper containing a rubber binder) can be recycled by the
paper manufacturers.
-------
Some types of asbestos scrap wastes are friable, and waste
disposal techniques similar to those used in handling asbestos
dust should be used. The installation and removal of asbestos
molded pipe, sheet, and block insulation during new construction
or repair from pipes, boilers, breechings, turbines, and
furnaces is the largest source of friable asbestos waste
materials. At one shipyard, asbestos waste is collected in
plastic bags and put into hoppers for pickup and disposal by a
private contractor. The amount of waste varies depending on
the extent of the repair job and the size of the ship, but usually
ranges between 0.7 and 4.5 metric tons (ca. 3/4 and 5 tons) per
ship. Because asbestos waste is not placed in separate dumpsters
from other waste, the private contractor handling the waste might
not know it contains asbestos. The wastes are trucked to a private
landfill.
The practice of transporting the waste to landfills along
with non-asbestos waste using several types of equipment
potentially presents a problem. Most of this material is handled
by non-company employees who are unaware of the potential
hazard in breathing asbestos fibers. Compactors, open dumpsters,
bulldozers, and careless handling of the plastic bags can cause
the bags to break open and create an asbestos emission problem.
Disposal of Demolition and Renovation Wastes — The friable
asbestos materials removed from demolition operations already
covered under the asbestos standard are required to be wetted but no
additional procedures are provided. The Agency's investigation
46
-------
indicates that the demolition debris is frequently deposited in
landfill operations.
Disposal of Spraying Wastes -- Spraying wastes are generally
collected and packaged before drying, and the containers are
subsequently deposited in landfills.
Disposal of Asbestos Mi. 11 Hastes — Waste disposal practices at
asbestos mills are usually different from the disposal techniques
used by asbestos manufacturing sources because the mills generate
much larger quantities of waste. A large asbestos tailings disposal
site may have a surface area of 400,000 m2 (ca. TOO acres) whereas
a large manufacturing and fabrication waste disposal site may have
a surface area of 12,000 m2 (ca. 3 acres). The largest mill in
the United States, located in Hyde Park, Vermont, disposes of over
one million metric tons of asbestos tailings annually. Smaller
operations in California have to dispose of lesser amounts of
tailings, but such quantities are large compared to quantities
of wastes from most asbestos manufacturing sources. Asbestos
mills generally dispose of wastes on a nearby area owned and
operated by the mill. The asbestos mill tailings contain from
less than 1 percent asbestos by weight, in the case of the
Vermont mill, to in excess of 30 percent asbestos by weight in
some California operations. Asbestos emissions from wind erosion
can result if methods to prevent such emissions are not employed.
During its investigation, the Agency visited all six of the
major asbestos mills in the United States and conducted an ambient
47
-------
air study at the large Vermont mill in order to determine whether
the disposal of tailings at asbestos mills is a major source of
asbestos emissions (see Appendix D)- The Agency's investigation
included inspections of active and inactive portions of tailings
disposal sites, and the deposition and distribution of the waste
on the disposal sites.
Mill wastes are usually conveyed from the mill on an enclosed
conveyor system to a disposal pile. The conveyor system usually
requires several transfer operations from one conveyor section
to the next. For example, the Vermont mill conveys the mill
tailings over 300 meters (ca. 1000 feet) to the tailings pile,
and the tailings conveyor has 13 transfer points. Asbestos emissions
from the enclosed conveyor and transfer operations are controlled
by the asbestos mill standard (38 FR 8820).
A primary purpose of the investigation was to observe methods
of controlling emissions during the dumping of tailings onto the
disposal pile. The tailings fall 2.5 to 3 meters from the discharge
conveyor to the disposal pile, and emissions from this operation
are often uncontrolled. One mill disposes of dry mill tailings
by dropping them onto the pile through an inverted-funnel-type device
intended to control emissions. A portion of this device is
ventilated to help reduce emissions during discharge of tailings
through the hood, and the ventilation stream is treated in a
baghouse. This type of dust control technique is evidently not
very effective in reducing dust emissions since visible emissions
48
-------
were noted at frequent intervals in an Agency inspection. Two mills
use another disposal method in which the tailings are wetted with a
screw mixer before being discharged to the tailings pile. The screw
mixing device is usually arranged so that the mixing occurs at a
conveyor transfer point. One device consists of a screw auger
approximately 1.5 meters long which turns in a trough where a spray
system installed over the length of the auger wets the tailings
with water and resinous or petroleum-based dust-suppression agents.
No visible emissions were noted during the wet tailings disposal
operation. This method of disposal also helps to reduce windblown
emissions from the tailings pile because the wetted tailings after
drying form a crust which reduces windblown emissions. Even
walking on one tailings pile did not break the crust layer.
The wet screw method is judged to be the most effective method
for controlling emissions from asbestos tailings disposal. None
of the mills presently operating in the United States would have
any major problems installing this system. Freezing weather may
cause some operational problems, but a Canadian asbestos mill has
successfully operated a wet asbestos tailings disposal system in
most cold weather conditions. The wet mixing operation is performed
in the mill at the bottom of the tailings conveyor and uses a
screw-type mixer. The coarse tailings (plus 35 mesh) are first
mixed with water in the screw mixer with sufficient water to
thoroughly coat each particle. This wet mixture is deposited on
the tailings conveyor belt, and finer tailings are then deposited
49
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on top of the wet mixture. This layered mixture is progressively
blended with each transfer point in the tailings system. Freezing
is not a major problem until temperatures become below -18°C
(ca. 0°F); some freezing at conveyor transfer points then restricts
the flow of tailings and causes tailings buildup in the transfer
chutes. This problem might be solved by insulating and heating
the transfer points and using nonmetallic chute linings. Since
a wet tailings disposal system is operated routinely in freezing
temperatures above -18°C (ca. 0°F), this method of tailings
disposal should be generally applicable to asbestos mills in the
United States. Only one mill in the United States may experience
some difficulty in wetting during the winter months because of
freezing weather.
Waste Disposal Sites
Control and Maintenance Practices — Disposal sites can be classified
into two types, active and inactive. An inactive site, or inactive
portion of a site, is an area where waste has been deposited but
where no additional waste is being added and the surface of the area
remains undisturbed by waste disposal activities. All other sites,
or portions of sites, are defined as active sites since waste is
being added or the surface is being otherwise disturbed. The basic
procedures that are currently used to control emissions are to
cover the asbestos waste with soil, to grow vegetation, or to apply
resinous or petroleum-based dust-suppression agents. The coverage
with soil or the application of a dust-suppression agent to an
active portion of a site has to be frequent enough to prevent
windblown emissions from the waste deposited between periods of
50
-------
coverage or application. The coverage or application at the end
of the operating day, or at least once in each 24-hour period, should
provide effective control of such emissions.
The asbestos emissions from an inactive site can be reduced
by applying soil to cover the waste and maintaining a vegetative
cover, or by applying dust-suppression agents to prevent windblown
emissions. When the waste is covered with soil and a cover of
vegetation is planted and maintained, the vegetative cover and
roots of the vegetation reduce water erosion and prevent wind
erosion. Since this does not require as great a degree of care
as is needed in maintenance for dust-suppression agents, it is
in most cases the most desirable control method. For very large
sites, however, this method is not practical. For example, an
asbestos mill waste disposal site can be as large as 400,000 m^
(ca. 100 acres) in area and have banked sides of up to 60°.
Vegetation does not grow naturally on such waste because of
the alkalinity of the waste, and coverage with soil is very
expensive because of the large area. Moreover, obtaining
sufficient soil to cover a large area could itself create
land and water environmental problems. However, resinous or
petroleum-based dust-suppression agents have been successfully
used to control wind erosion from large sites (see Appendix B).
These methods are effective with proper site preparation, application
and maintenance of the agent. The surface is wetted with the agent;
51
-------
after drying, the dust and waste are bound by the adhesive quality
of the agent and the waste forms a crust which reduces wind and
water erosion. These agents have to be reapplied at intervals
ranging from 1 to 3 years to maintain their effectiveness.
The methods proposed as alternatives to compliance with
the no-visible emission standard for inactive sections of disposal
sites require, where practical, the use of cover. Where cover
is judged to be impractical, i.e., on most asbestos tailings piles,
another effective control method allowing the use of dust-suppression
agents is proposed. Since dust-suppression agents must be maintained
more carefully than cover and since there may be a water pollution
problem associated with improper use of such agents, this control
method is not specified where cover can be practically applied.
Ambient Asbestos Concentrations Near Disposal Sites — The magnitude
of emissions from asbestos waste disposal operations such as
dumping and distribution, and from wind erosion of deposited
wastes, is not easily evaluated by visual observations. The
Agency therefore measured ambient asbestos concentrations in
the vicinity of the waste disposal area of a large manufacturing
and fabricating operation in Ambler, Pennsylvania, and in the
vicinity of the tailings disposal area of a large asbestos mill
in Hyde Park, Vermont. These concentrations were then compared to
the ambient asbestos background concentrations for the respective
areas of the sources. Although existing asbestos measurement
procedures are reproducible in inter-laboratory comparisons only
52
-------
to within a factor of approximately 5 according to experts, the
measured ambient asbestos concentrations analyzed by one laboratory
were judged to be useful in making relative determinations of
whether asbestos disposal sites are major sources of asbestos
emissions.
The individual studies indicate that the asbestos concentrations
in the vicinity of the asbestos waste disposal sites are higher
than the background levels by a factor of at least 13. The
Administrator has thus determined that uncontrolled asbestos
waste disposal operations and sites where asbestos waste is
deposited are major asbestos emission sources, and is proposing
standards for the control of these sources.
Ambient Asbestos Study in Ambler Pennsylvania — The potential
asbestos emission sources that contributed to ambient asbestos
concentrations monitored during the study in Ambler, Pennsylvania,
are two asbestos manufacturing plants (Plants A and B) and their
active and inactive waste disposal sites.
Plant A manufactures high- and low-density monolithic
asbestos-cement board and gasket material. The manufacturing
of boards and gasket material is performed at Building #1, and
the high-density monolithic boards are transported to Building #2
for grinding and finishing (Figure 5-1). Waste generated as a dust
(40 percent asbestos) from the sanding of monolithic board at
Building #2 is collected in baghouses. The dust is transferred
from the baghouse to containers where the material is wetted,
covered, and transported to a settling pond about one kilometer av/ay.
53
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M-M-M I I I I I I I I I I I I I M=H I I I I I I-U-U-U
? p^_^^^iC\\Y'W/
„?! I~?PLANT A
'-ACTIVE PILE
PLANT B'S
SUE #6 ACTIVE PILE
S
LOCUST STREET
SETTLING---,
PONDS
LEGEND:
S SAMPLER
M IVIETEOROLOGICAL
STATION
Figure 5-1 . Sources of asbestos emissions in Ambler, Pennsylvania.
-------
The waste material is dumped into a section of the settling
pond, mixed into a slurry, and pumped to the active disposal
lagoon approximately 50 meters away. Other asbestos-containing
waste generated at the plant empties into a wastewater system and
is channeled to the settling pond.
Plant B manufactures various sizes of asbestos-cement pipe
that contains 10 to 12 percent asbestos. Waste generated from
machining the pipe ends is collected in a baghouse and recycled
rather than being discarded as waste. Pipe scraps greater than
30 cm (ca. 12 inches) in diameter are not recycled, and this waste
is transported to the disposal pile. A large amount of asbestos-
containing sludge is created in the wastewater treatment operation
recently installed by Plant B. Tank trucks transport the slurried
sludge to the disposal lagoon; each truck carries approximately
23,000 liters (ca. 6000 gallons) per load and empties into the
lagoon at a rate of about 10 to 12 truckloads per 6-week period.
When enough water has evaporated, the semi dry waste is shoveled
from the lagoon and piled onto the adjacent disposal area. A
bullodzer then crushes the discarded pipe, the semi dried sludge
is mixed with the crushed pipe, and the mixture is spread uniformly
on the disposal pile. The crushing operation is performed for
approximately 1-1/2 days of an 8-week period.
The active disposal sites of Plants A and B are adjoining.
Plant A's site is approximately 20 meters high, 90 meters wide,
and 150 meters long (ca. 60 feet high, 300 feet wide, and 500 feet
55
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long), while Plant B's site is approximately 6 meters high,
90 meters wide, and 210 meters long.
After water evaporates from Plant A's disposal lagoon,
portions of the lagoon have a dry, cracked crust. The top layer
is light in color, has a relatively low density, and is fibrous.
The fibers appear to be bound securely enough so that they are
not released by wind action alone. The sides of the disposal
site are about 46 cm higher than the level of the lagoon
and form a roadway approximately 4.5 meters wide. Solid material
is deposited and spread on this roadway when it becomes necessary
to build up the sides of the lagoon. Plant B's active waste
disposal site is similar to Plant A's.
A waste disposal stte located southwest of Pla,nt A h.a,s been
inactive for about 4 years and covers approximately 40,000 rrr (ca.
10 acres) (Figure 5-1). The type of waste material deposited at
the site differs from the material currently being disposed of at
Plant A's active site. Trees, grass, shrubs, and weeds cover
approximately 75 to 90 percent of the surface area, but little
vegetation grows on the north bank of the pile, which borders
one side of a playground and is close (within 15 meters) to
occupied dwellings. This bank is approximately 180 meters long,
approximately 15 meters high, and has a slope of about 60 degrees.
A sampling network was designed to measure background concen-
trations to which the public would be exposed, and to isolate emissions
from specific sources at the disposal sites. See Figure 5-1 for
locations of the sampling sites. The sampling network was composed*
56
-------
of ten ambient air samplers and two meteorological wind data
systems. The study was performed on October 15-18, 1973. Sampling
times at various sites were 24 hours, 12 hours, 1 hour, and 30 minutes,
depending on site locations and operations to be isolated. Table 5-1
summarizes the site location, source of emissions to be isolated,
sampling time, wind speed and direction, asbestos concentration,
and the ratio (R) of the measured asbestos concentration to the
background level. It did not rain during the sampling period, and
therefore the measured concentrations do not reflect reduced
emissions which could result from wetting of the various operations
and piles.
The only activity on Plant B's active disposal pile during
testing was a truck dumping scrap pipe onto the pile twice a day.
No activity was reported on Plant A's active disposal pile, but
residue from polishing construction panels was dumped into a
section of the settling pond once a day.
Samples that isolated specific emission sources were selected
by using measured wind direction and speed.
The ambient asbestos concentrations listed in Table 5-1
range from 3.1 ng/m3 (nanograms per cubic meter) to 2600 ng/m3.
The samples obtained were representative of all the potential
emission sources except pipe crushing by Plant B, which could
not be scheduled during the sampling period. Agency personnel observed
the pipe crushing operation on October 1 and 2, 1973, at Plant B's
disposal pile. Visible emissions were generated by this operation
during approximately 25 percent of the bulldozer operating time,
57
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Table 5-1. SUMMARY OF AMBIENT ASBESTOS
OCTOBER 15-18, 1973, IN
Sample Meteorological Data
Nominal
Sampling
Time (hr) Wind Speed Direction
MONITORING DATA COLLECTED
AMBLER, PENNSYLVANIA
Asbestos Concentration
Measured (ng/m3) Average (ng/m3) R***
1
2
3
4
5
6
7
8
9
10
11
12
#1
#2
#3
#4
#5
#6
#6
#7
#7
#8
#9
#10
12
12
12
12
12
12
12
1, 1/2
12
12
24
24
™__--— L—
1-13 mph
2-13 mph
2-13 mph
2-13 mph
2-13 mph
7-14 mph
1-8 mph
1-8 mph
1-8 mph
2-13 mph
2-14 mph
2-14 mph
160°-220°
160°-280°
160°-270°
160°-280°
160°-270°
255°-280°
90°-270°
90°-260°
90°-270°
160°-280°
160°-280°
160°-270°
3.1, 11, 12, 22
19.0-210.0
29.0-53.0
5.5-16.0
97.0-130.0
48.0
160.0
890-2600
1200
7.2-12.0
13, 23, 27
49, 210, 500
12.0
114.5
41.0
10.7
113.5
48.0
160.0
1745
1200
9.6
21
253
1.0
9.6
3.4
0.9
9.5
4.0
13.3
145.0
100.0
0.8
1.8
21.0
*Case description.
1. Background ambient concentration.
2. Windblown emissions from Plant B's active
waste disposal pile.
3. Windblown emissions from Plant A's
active pile.
4. Windblown emissions from Plant A's
active disposal pile banks and
roadways.
5. Windblown emissions from both
Plant A's and B's -active
disposal piles.
6. Windblown emissions from Plant A's
active disposal pile.
7. Windblown emissions from Plant B's
active disposal pile.
8. Emissions from dumping of polishing
and grinding wastes into settling
pond.
9. Emissions from wetting and mixing
of polishing and grinding wastes.
10. Windblown emissions from Plant A's
inactive tailings pile near children's
playground.
11. Windblown emissions from Plant A's
active disposal site and truck traffic.
12. Emissions from both active disposal
piles.
**Sample site description.
1. Sewage disposal plant background,
sampler.
2. Plant B's active pile, sampler.
3. East sector of Plant A's pile, sampler,
meteorological station.
4. West sector of Plant A's pile, sampler.
5. North sector of Plant A's pile, sampler.
6. South sector of Plant A's pile, sampler.
7. Plant A's settling pond, sampler.
8. Playground on Locust Ave., sampler,
meteorological station.
9. South Chestnut Street, sampler.
10. Far east, street side of railroad tracks,
sampler.
aver, concentration at site
***R aver, concentration at background
(site #1 in this study)
58
-------
and the generated dust settled quickly. Maximum emissions were
15 percent opacity, but averaged approximately 5 percent opacity.
Once during the crushing operation, for a period of 15 seconds,
visible emissions were observed to go beyond the boundary of the
disposal site.
Ambient Asbestos Study in Hyde Park, Vermont--The potential
asbestos emission sources monitored during the study in Hyde Park,
Vermont, are mines and mine roads, ore storage areas near the mill,
ore crushing operations, the asbestos mill, mill tailings piles,
and non-plant roadways surfaced with mill tailings.
Emissions of asbestos from the mill are covered by the asbestos
standard, but the mill was operating under a waiver of compliance
during the ambient air study. The mill operations under waiver
were the dry-rock storage building, ore dryers, and all except one
of the tailings conveyor transfer points.
The asbestos ore is mined in two open-pit quarries. The ore
is then transported by trucks approximately 1 kilometer to the
location where it is crushed and subsequently deposited by a conveyor
onto an exterior wet-ore storage pile. The crushed ore is charged
into the dryers as needed and then conveyed to the dry rock storage
building. In the milling process, dried crushed ore is processed
through a series of screens and aspirators where the asbestos
fibers are separated and removed from the ore. The rocks and
dust remaining after the milling operation are conveyed to the
tailings pile for disposal.
59
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Four power shovels and two bulldozers are used to load the trucks
with either ore or waste rock in the quarries. Three ore trucks
serve each shovel when the mine is in operation (8:00 a.m. to 12:00
midnight during the sampling program). The loaded trucks travel
an average of 650 meters from the quarries to the mill over mine roads.
The roads have a minimum width of 10 meters and a maximum grade of
8 percent. During the summer, a 1.5 cm -thick layer of mill
tailings is applied to the mine roads for surfacing, and during the
winter the same material is added to improve traction over icy
roads.
Ore which has passed through the primary and secondary crushers
is stored in an open area called the wet-rock storage area prior to
being dried. The capacity of the storage area is approximately
68,000 metric tons (ca. 75,000 tons) of ore. The ore is moved
continuously from storage to the dryer by vibrating feeders which are
located beneath the surface of the pile. The majority of emissions
from the storage area probably occur when the ore drops from the end
of a conveyer belt to the surface of the storage area approximately
4.5 meters below; however, wind could also entrain emissions from the
surface of the pile. A bulldozer moves the rock fairly continuously
while the conveyer is in operation to keep the area level and to
fill the vibrating feeders to ensure a consistent withdrawal rate
from the pile.
The opening, screening, aspirating, and packaging of asbestos
fibers are carried out in the main section of the mill, which has
*
60
-------
a capacity of approximately 3,200 metric tons (o,a. 3500 tons) of ore
per 3-shift day. Material in the mill is transferred either by
belt conveyor, gravity, or air stream, depending upon the job being
performed. A dust collector (vertical, pressure-bag-type air filter)
is used as the final filter for the ventilation and process air
streams. The filtered air from the open pressure baghouses is
recirculated to the building to conserve heat during the winter.
The unit handles air at the rate of 9100 m3/min (ca. 320,000 cfm)
with a 10 cm (Ca. 4 inch) w.c. pressure loss.
Ore which has passed through the mill's screens and aspirating
hoods is transported to the tailings pile by conveyors. The tailings
pile has been in use for over 15 years and contains approximately
20 million metric tons of tailings. The tailings pile is approximately
o
120 meters high and 240,000 m (ca. 60 acres) in area. Several potential
emission sources from the tailings pile are: conveyor transfer points,
vehicle traffic on the pile, the deposit of tailings from the
conveyor belt onto the pile, distribution of tailings on the pile
with a bulldozer, and wind erosion. The leading edge of the tailings
pile is the portion that is most susceptible to windblown emissions.
The lower, older part of the pile was observed to have a light crust
and did not appear to contain finelv divided dust.
A sampling network was designed to measure background concentrations
to which the public is exposed and to isolate emissions from specific
sources of asbestos emissions in the vicinity of the mine-mill complex.
61
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See Figure 5-2 for locations of the sampling sites. The sampling
network was composed of ten ambient air samplers and five meteorological
wind data systems. The study was performed September 25 through
October 1, 1973. Sampling times at various sites were 12 hours
and 4 hours, depending on site locations and operations to be
isolated. Table 5-2 summarizes the site location, source of
emissions to be isolated, sampling time, wind speed and
direction, asbestos concentration, and the ratio (R) of the
measured asbestos concentration to the background level. Table 5-3
lists the specific data for asbestos ambient concentrations from
only the tailings pile; from the tailings pile, conveyor transfer
points, and disposal of the tailings; and along a public roadway
off plant property. Table 5-4 presents the asbestos concentration
of solid material samples taken from the roadway, ore storage
areas, and mill tailings. Asbestos concentrations are presented
both for the material as obtained and for the fraction of the
material that passes through a minus 140 mesh screen. This fraction
is of particular interest because particles of this size can
be entrained by moderate wind speeds.
It did not rain during the sampling period; therefore, the
measured concentrations do not reflect reduced emissions which
could result from wetting of the various operations and piles.
The testing program was completed without any major problems.
On September 29, 1973, the plant agreed to close down certain operations
62
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OVERBURDEN
DISPOSAL AREA
SITE 4
SITE 10
O
SITE 11
PRIMARY
CRUSHER
SITE 5
O
SITE 6
O
MILLING DRYER
SITE 9
O
WET ORE
STORAGE
TAILINGS PILE
~400 FT. HIGH
OVERBURDEN
DISPOSAL AREA
SITES
O
POWER
STATION
N
a
«Ł
s
<
Q.
SITE 2
O
SITE1
•1,000ft.
I
Scale
Figure 5-2. Sources of asbestos emissions in Hyde Park, Vermont.
63
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Table 5-2. SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED
SEPTEMBER 25-OCTOBER 1, 1973, IN HYDE PARK, VERMONT
Meteorological Data
Asbestos Concentration
Case*
1
2
3
4
5
6
7
8
9
9A
10
10A
11
12
13
14
15
16
17
18
19
A
B
C
Sample
Site**
#1
#1
#2
#2
#3
#3
#3
#4
#4
#1 & #4
#5
#5
#6
#6
#6
#7
#7
#8
#8
#10
#11
2 & 8
2 & 8 & 10
1 - 4
Wind Speed
2-8 mph
2-7 mph
2-8 mph
6-9 mph
1-7 mph
6-9 mph
4-8 mph
3-11 mph
3-6 mph
1-5 mph
3-10 mph
1-3.5 mph
3-10 mph
1-9 mph
1-3 mph
3-11 mph
5-13 mph
3-10 mph
3-5 mph
1-5 mph
1-5 mph
-
-
-
Direction
340°
90°
250°
250°
200°
183°
200°
190°
208°
135°
360°
140°
90°
200°
220°
100°
202°
210°
210°
350°
30° -
30° -
-
_
40°
- 270°
- 295°
- 295°
- 230°
- 247°
- 275°
- 230°
- 220°
- 180° @1
- 45° 04
- 210°
- 270°
- 230°
310°
- 150°
18°
- 30°
- 120°
- 60°
90°
90°
Range
0.012
0.002
0.05
0.15
0.12
4.2
1.6
1.3
0.03
0.002
0.24
5.2
1.9
0.03
0.71
0.03
4.78
0.06
5.2
0.25
0.14
0.06
0.05
0.002
(pg/m ) Average (yg/n
- 0.180
- 0.02
- 1.5
- 13.6
13.6
- 13.1
- 0.4
- 10.8
-106.5
- 50.0
- 8.1
- 67.6
- 46.1
- 7.6
- 22.9
- 1.1
- 0.94
- 1.2
- 7.6
13.6
0.096
0.008
0.445
0.15
7.35
4.20
6.57
4.14
0.03
0.067
5.15
5.2
33.56
18.81
3.78
22.5
24
3
9.76
0.54
0.53
0.410
2.091
2.33
)3) R***
12.0
1.0
55.6
18.7
919.0
525.0
821.0
518.0
3.7
8.4
644.0
650.0
4,195
2,350
472.0
2,818
3,000
377
1,120
67
66
51
261
291
64
-------
Table 5-2 (continued). SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED
SEPTEMBER 25-OCTOBER 1, 1973, IN HYDE PARK, VERMONT
Case 1
Case 2
Case 3
Case 4
Case 5
Case 6
Case 7
Case 8
Case 9
Case 9A
Case 10
Case 10A
Case 11
Case 12
Case 13
Case 14
Case 15
Case 16
Case 17
Case 18
Case 19
Case A
Case B
*Case Description
Windblown emissions from mine-mill complex
Background samples
Windblown emissions from tailings pile with conveyor system operating
Windblown emissions from tailings pile with conveyor system not
operating
Windblown emissions from tailings pile, wet-rock storage, and mill
with mill operating
Windblown emissions from tailings pile and wet-rock storage with mill,
primary crusher, and ore dryer shut down
Windblown emissions from tailings pile and mill with primary crusher
not operating
Windblown emissions from tailings pile, wet-rock storage, mill, and
ore dryer with mill operating
Windblown emissions from tailings pile and wet-rock storage with mill,
primary crusher, and ore dryer shut down
Emissions from roadways off plant property
Windblown emissions from roadways, tailings pile, ore dryers, mill,
and wet-rock storage
Windblown emissions from primary crusher and its conveyor
Windblown emissions from tailings pile, mill, ore dryer and wet-
rock storage
Windblown emissions from wet-ore storage and primary crushing operation
Ambient asbestos concentrations in and around working areas
Windblown emissions from tailings pile and conveyors
Windblown emissions from mill, ore dryer, and dry-rock storage area
Windblown emissions from tailings pile
Windblown emissions from mill, drying, and crushing operations
Windblown emissions from tailings pile and milling complex
Windblown emissions from tailings pile and milling complex
Windblown emissions from only the tailings pile
Windblown emissions from tailings pile, plus emissions from
tailings conveyor transfer points, plus emissions from dumping
of tailings.
Ambient concentrations measured along public roadway off plant property
Case C
**Site Description
Site 1 C. Jones Barn
Site 2 Corez Pond
Site 3 Power Substation
Site 4 Far North
Site 5 Equipment Storage
Site 6 Working Area
Site 7 Dry Storage
Site 8 Quarry Road
Site 9 Lowell Quarry
Site 10 Disposal Area
Site 11 Far South
Site 12 Top of Tailings Pile
_ aver, concentration at site
aver, concentration at site
(background)
65
-------
Table 5-3. AMBIENT ASBESTOS CONCENTRATIONS FROM
TAILINGS PILE AND ON PUBLIC ROADWAY
Case A
Windblown emissions from only the tailings pile.
Location Date Time (hr) Asbestos Cone. (ng/m3)
Site 2
Site 8
Site 8
Site 8
Site 8
9/30/73
10/1
10/1
10/1
10/1
1200-1600
0800-1200
1200-1600
0000-0400
0400-0800
150
400
1200
240
60
Case B
Windblown emissions from tailings pile, plus emissions from
tailings conveyor transfer points, plus emissions from dumping
of tailings.
Location
Date
Time (hr)
Asbestos Cone. (ng/m3)
Site 2
Site 2
Site 2
Site 2
Site 8
Site 8
Site 8
Site 8
Site 8
Site 8
Site 10
Site 10
Site 10
9/26/73
9/26
9/27
9/28
9/27
9/27
9/28
10/1
10/1
10/1
9/28
9/28
9/30
1200-1600
1600-2000
1600-2000
1200-1600
0400-0800
0800-1200
2000-2400
0800-1200
1200-1600
1600-2000
0000-0400
0800-1200
0000-0400
90
50
140
1500
5600
2500
6500
400
1200
7600
260
1100
250
66
-------
Table 5-3 (continued).
AMBIENT ASBESTOS CONCENTRATIONS FROM
TAILINGS PILE AND ON PUBLIC ROADWAY
Case C
Ambient concentrations measured along public roadway off plant
property
Location
Date
Time (hr)
Asbestos Cone, (ng/m^)
Site 1
Site 1
Site 1
Site 1
Site 1
Site 1
Site 1
Site 1
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 2
Site 3
Site 3
Site 3
Site 3
Site 3
Site 3
Site 3
Site 3
Site 3
Site 3
Site 3
Site 4
Site 4
Site 4
Site 4
Site 4
Site 4
Site 4
Site 4
9/28/73
9/29
9/26
9/26
9/27
9/29
10/1
10/1
9/26
9/26
9/27
9/28
9/30
9/30
9/28
9/27
9/27
10/1
10/1
10/1
10/1
10/1
9/26
9/26
9/26
9/27
9/27
9/27
9/29
9/29
9/30
9/29
9/30
9/28
9/29
9/26
9/26
9/26
9/27
9/27
9/27
0000-1200
1200-2400
0000-1200
1200-2400
0000-1200
0000-1200
0000-1200
1200-2400
1200-1600
1600-2000
1600-2000
1200-1600
1200-1600
0400-0800
1600-2000
0400-0800
0800-1200
0000-0400
0400-0800
0800-1200
1200-1600
1600-2000
0000-0400
0800-1200
1200-1600
0000-0400
1200-1600
1600-2000
0400-0800
0800-1200
1200-1600
1200-1600
0400-0800
0000-0400
2000-2400
0000-0400
0800-1200
1200-1600
0000-0400
1200-1600
1600-2000
12
180
5
2
15
20
3
4
90
50
140
1500
150
2600
180
40
70
50
70
20
83
170
2000
4500
12,700
120
8300
13,100
4500
13,600
4200
1600
2100
13
400
1300
1900
2500
1500
3500
6500
67
-------
Table 5-3 (continued). AMBIENT ASBESTOS CONCENTRATIONS FROM
TAILINGS PILE AND ON PUBLIC ROADWAY
Location Date Time (hr) Asbestos Cone, (ng/m3)
Site 4 9/29/73 0400-0800 13,100
Site 4 9/29 0800-1200 2800
Site 4 9/30 1200-1600 30
Site 4 9/28 0400-0800 22
Site 4 9/29 2000-2400 400
Site 4 9/28 0800-1200 14
Site 4 9/30 0400-0800 8400
Site 4 9/30 0800-1200 150
Site 4 9/30 0000-0400 1800
68
-------
Table 5-4. ASBESTOS CONCENTRATION OF MATERIAL SAMPLES TAKEN IN VERMONT
% of Sample Represented % Chrysotile in % Chrysotfle in
Sample # Site Description by -140 Mesh Fraction Unfractionated Sample -140 Mesh Fraction
72 From road just 2.0 0.2 4.2
above site #10
test
73 Wet-ore storage 2.4 0.4 15.8
74 -1/2" + 10 mesh 0.2 0.02 33.4
tailings (used in
asphalt pavement)
75 1/4" tailings gravel 0.2 0.1 24.1
for sale (used to
sand highways)
76 Dry-rock storage 10.7 1.0 12.7
site #7
82 Dry storage area 10.8 2.0 21.1
site #12
-------
to enable the isolation of potential asbestos windblown emissions
from the tailings pile.
The sampling sites were located to isolate specific emission
sources and also to have background samples for each specific
emission source. After the meteorological data and the plant
operations data were checked, samples were selected which
represented emissions from specific sources. For more information
on the selection of sampling sites and validation of selected
samples, refer to Table 5-5.
70
-------
Table 5-5. LOCATION OF SAMPLING SITES
Site 1 - In order to determine background ambient asbestos concen-
trations, a sampler was placed at Mr. Jones' barn. Mr. Jones'
barn is approximately 1.5 kilometer SE of the mill, with pre-
vailing winds from the S-SW, the ambient concentrations obtained
were representative background levels.
Site 2 - The Corez Pond location was selected as a sampling site
to measure windblown emissions from the tailings pile.
With a westerly wind, emissions from the mill were
excluded and only emissions from the tailings pile
measured.
Site 3 - In order to measure windblown emissions from the entire
mine-mill complex, samplers were placed on the northern
side of the mine-mill complex. With the wind prevailing
from the S-SW, the power substation was directly upwind
from the mine-mill complex.
Site 4 - A sampler was put at' site 4 because, although this
location was also directly upwind from the mine-mill
complex, it was more removed from the mine-mi 11 than
site 3. By selecting samples taken at site 4 with
samples taken at site 3 at corresponding times, the
dispersion or fallout of emissions from the mine-mill
complex could be determined.
71
-------
Table 5-5 (continued). LOCATION OF SAMPLING SITES
Site 5 - A sampler was placed at the Foundry Building to measure
the emissions from the primary and secondary crushers
and also from the wet-ore storage pile. The crushers
and ore storage pile are very close to each other, which
caused difficulty in distinguishing the individual
emissions.
Site 6 - A sampler near the Engineering Drafting Building measured
fallout emissions from the two ore dryer stacks. At this
site, the ambient asbestos concentration inhaled by workers
in this area was measured.
Site 7 - The main objectives in placing a sampler on the tailings
pile near the dry storage area were to measure windblown
emissions from the tailings pile and emissions from the
ventilation system of the dry-rock storage building.
Site 8 - This sampler measured windblown emissions from the side
of the asbestos tailings pile and served as background
for samples obtained at site 2.
Site 10 - This sampler measured windblown emissions from the mill
and tailings pile, and also served as background for
samples taken at sites 3 and 4.
Site 11 - This sampler measured background asbestos concentrations
and emissions from blasting in the quarries.
72
-------
6. MERCURY EMISSIONS FROM
SLUDGE INCINERATION AND DRYING FACILITIES
SUMMARY OF PROPOSED AMENDMENT
Emissions to the outside air from sludge incineration plants,
sludge drying plants, or a combination of these that process waste-
water treatment plant sludges shall not exceed 3200 grams of mercury
per 24-hour period.
RATIONALE FOR PROPOSED AMENDMENT
Disposal of wastewater treatment plant sludge is a responsibility
of all major and many smaller municipalities and also various in-
dustries that choose to dispose of their own wastewater treatment
plant sludge. In the majority of cases, raw waste is transported
to centralized wastewater treatment plants, where various waste
treatment methods are used to process the raw waste into sludges
that must be disposed of in the environment—via land, water,
air, or a combination of these media. Mercury emissions result
from the incineration and drying of sludge that contains small quan-
tities of mercury.
At the time of proposal and promulgation of the national emis-
sion standard for mercury [March 31, 1971 (36 FR 23239), and April 6,
1973 (38 FR 8820), respectively], available information indicated
that sewage sludge incineration plants did not emit mercury in a man-
ner that could cause the ambient concentration to exceed the inhala-
tion health effects limit of 1 microgram per cubic meter averaged
73
-------
over a 30-day period. Consequently, the Administrator determined
at that time that it was not necessary to regulate mercury emis-
sions from this category of sources in order to protect public
health with an ample margin of safety. At the time of promulgation,
information available to the Agency included mercury stack emission
tests at five sewage sludge incineration plants. Of the five emis-
sion rates determined, the maximum was 125 grams of mercury per
day based on one test which was later judged to be invalid on the
basis of mercury mass balance calculations. Emissions for the re-
maining four tests ranged from 1 to 40 grams of mercury per
day.
After promulgation of the national emission standard for mer-
cury, questions concerning the impact on public health of mercury
emissions from sewage sludge incinerators were raised by the En-
vironmental Defense Fund, et al., in their Petition for Review
of the national emission standards for hazardous air pollutants.
Similar questions arose in connection with proposals to construct
several large sludge incineration facilities. In response, the
Agency initiated a study to more completely characterize emissions
of mercury from sewage sludge incinerators (see Appendix D).
The results from one of two stack tests that were performed
during the more recent investigation are available. The emission
results from this test and the four former tests suggest that a
significant quantity of mercury is collected by water scrubbers.
74
-------
Mercury is emitted from the drying of sludge and the incin-
eration of industrial wastewater sludge., as well as from the in-
cineration of municipal sludges. There are approximately 280
municipal sludge incineration sites, 17 sludge drying sites, and
an undetermined number of industrial waste sludge incineration sites
in the U.S. The pretreatment of industrial wastewater streams to
remove mercury before discharge into municipal wastewater treatment
streams may be required in the future. This could produce industrial
sludges—which might be incinerated—with higher concentrations of
mercury than either municipal or combined municipal-industrial
wastewater treatment plant sludges. Mercury concentrations of
sewage sludges nationally average about 5 ppm on a dry solids basis;
however, approximately 10 percent of the sludge samples have mercury
concentrations in excess of 15 ppm.
Very large sludge incineration facilities are being contem-
plated for the future; for example, one existing facility will in the
near future incinerate 900,000 kg (ca. 2 million pounds) of dry solids
per day. If sludge with the highest reasonably expected mercury con-
tent of 15 ppm (parts per million) were incinerated, and if only
50 percent of the mercury in the sludge were emitted into the atmos-
phere, the plant would emit 6,800 grams of mercury per day. This
amount is over twice the maximum allowable mercury emissions that
will protect the public health with an ample margin of safety.
Sludge incineration facilities with capacities of 1,800,000 kg
75
-------
(ca. 4,000,000 pounds) per day are being planned for operation in
2005.
In view of the potentially large mercury emissions from sludge
incineration plants, the Administrator has determined that it is
prudent to regulate mercury emissions from this category of sources.
While no sludge incineration facilities are known to be exceeding
the proposed mercury emission limitation at this time, the
proposed standard will prevent a mercury emission problem from
occurring in the future by ensuring that new and modified facilities
investigate and provide for limiting potential mercury emissions
prior to construction.
The proposed emission limit of 3200 g/day was derived from dispersion
estimates as the level which would protect against the violation of an
ambient mercury concentration of 1 microgram per cubic meter averaged over a
30-day period. The meteorological estimating procedure is the same as
that used to develop standards for mercury ore processing facilities and
mercury chlor-alkali plants (38 FR 8820), except that emission release
conditions representative of sludge incineration sites are used. The
assumptions and equations used to make the dispersion estimates are
discussed in Appendix C of this report.
Both the original national emission standard for mercury
and the proposed amendments are designed to control the concentra-
tion of mercury in the ambient air adjacent to the point source.
Since the standard is concerned primarily with the threat posed
by inhalation of mercury in air immediately proximate to the point
76
-------
source, it does not deal with the potential long-range hazard posed
by the addition of mercury from these point sources to the total
environmental burden. Not addressed, for example, is the mercury
discharged from chlor-alkali, ore processing, and sludge incineration
plants that can eventually be transported to water systems where it
may potentially be methylated and bioconcentrated in fish. The Agency
has become increasingly concerned about the total environmental burden
of mercury, however, and is initiating studies to determine how
this aspect can most effectively be addressed under the provisions
of the Clean Air Act and other authorities.
Description of Industry
Raw waste originates from a variety of sources which can be roughly
classified into the major categories of industrial and residential
sources. The raw waste is transported to wastewater treatment
plants. Primary treatment of raw waste is designed to remove the
bulk of the non-dissolved solids present. In many cases the waste-
water remaining after primary treatment is given secondary and, in
a few cases, tertiary treatment prior to discharge. Sludges produced
by primary treatment can be combined with secondary and tertiary sludges
prior to final disposal.
Average characteristics of dry sewage sludge solids range from
30.2 to 88.5 percent combustibles, from 11.5 to 69.8 percent ash, and
from 9,300 cal/g (ca. 16,750 Btu/lb) for grease and scum to 2,220 cal/g
(ca. 4,000 Btu/lb) for grit. Characteristics of both raw and digested
77
-------
sludge fall within these ranges. Table 6-1 presents the average
characteristics of various sewage sludges. Sludge characteristics,
such as dryness of solids, percent combustibles, and percent ash, can
be modified significantly by the addition of filter aids, such as
lime, ferric chloride, and polymers.
Prior to incineration, concentrations of elements and materials
in sewage sludge are usually expressed on a dry solid basis. Dry
solids are also called total residue. The residue after incineration
is called ash, or fixed solids. The laboratory method for determining
dry solids (total residue) and ash (fixed solids) is described by
American Public Health Association (APHA), American Water Works
Association (AWWA), and Water Pollution Control Federation (WPCF).2
Sludge concentration data from approximately 42 sewage treat-
ment plants indicate a range of mercury content on a dry solids
basis from 0.6 ppm to 43 ppm; the average value is 4.9 ppm. Table
6-2 lists the individual values of mercury concentration in sewage
sludges. The upper limit would be 90 ppm, but 90 ppm and three other
values from Bergen County and Joint Meeting, New Jersey, in October
1971 seemed inordinately high compared to the other values in the
table. Additional sludge samples obtained from these same facilities
in November 1973 averaged 9.2 ppm as compared to the October 1971
average of 75.5 ppm. It is concluded that the October 1971 values
are erroneous due to sampling or analytical errors.
78
-------
Table 6-1. AVERAGE CHARACTERISTICS OF SEWAGE SLUDGE1
Heat Content
Combustibles Ash
Material (%) (%) (cal/g) (Btu/lb)
Grease and scum 88.5 11.5 9300 (16,750)
Raw sewage solids 74.0 26.0 5710 (10,285)
Fine screenings 86.4 13.6 4990 ( 8,990)
Ground garbage 84.8 15.2 4580 ( 8,245)
Digested sewage
solids and ground garbage 49.6 50.4 4450 ( 8,020)
Digested sludge 59.6 40.4 2940 ( 5,290)
Grit 30.2 69.8 2220 ( 4,000)'
79
-------
Table 6-2. MERCURY CONCENTRATION IN SEWAGE SLUDGES, DRY SOLIDS BASIS
Data Sewage Treatment Plant
No. Location
1 Chicago, Illinois
2 Chicago, Illinois
3 Chicago, Illinois
4 Chicago, Illinois
5 Chicago, Illinois
6 Chicago, Illinois „
7 Greensboro, North Carolina
8 San Lorenzo, California
9 San Mateo, California
10 Edmonds, Washington
11 Morristown, Pennsylvania
12 Lynwood, Washington
13 Tahoe, California
14 Tahoe, California
15 Tahoe, California
16 Tahoe, California
17 Tahoe, California
18 Tahoe, California
19 Tahoe, California
20 Bars tow, California
21 Barstow, California
22 Barstow, California
23 Lorton, Virginia
24 Lorton, Virginia
25 Lorton, Virginia
26 Lorton, Virginia
27 Lorton, Virginia
28 Cincinnati, Ohio
29 Cincinnati, Ohio
30 Dayton, Ohio
31 Indianapolis, Indiana
32 Indianapolis, Indiana
33 Indianapolis, Indiana
34 Monterey, California
35 Monterey, California
36 Bergen County, New Jersey
37 Bergen County, New Jersey
38 Bergen County, New Jersey
39 Passaic Valley, New Jersey
40 Middlesex County, New Jersey
41 Joint Meeting, New Jersey
Date of
Collection
3/18/71
3/19/71
3/22/71
3/23/71
3/24/71
3/25/71
7/71
7/71
7/71
7/71
7/71
7/71
7/15/71
7/15/71
7/15/71
7/15/71
7/15/71
7/15/71
7/16/71
7/21/71
7/21/71
7/22/71
7/71
7/71
7/71
8/5/71
8/5/71
8/20/71
8/20/71
8/25/71
8/23/71
8/23/71
8/23/71
10/14/71
10/14/71
10/26/71
10/26/71
10/26/71
11/1/71
10/25/71
10/27/71
Mercury,
ppm
4.6
4.8
4.8
4.7
4.6
4.7
6.5
5.6
5.0
3.8
6.0
5.3
5.5
5.5
5.7
12.0
15.0
7.5
7.5
5.5
5.5
5.5
4.6
2.6
2.0
1.9
4.0
6.0
3.6
11.5
4.2
3.0
3.6
8.6
9.0
88.0*
90.0*
50.0*
3.9
4.9
*See text, page 78 for discussion of these values.
80
-------
Table 6-2 (continued).
MERCURY CONCENTRATION IN SEWAGE SLUDGES,
DRY SOLIDS BASIS
Data
No.
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
Sewage Treatment Plant
Location
Northwest Bergen County,
Northwest Bergen County,
Cedar Rapids, Iowa
Cincinnati Ohio
Cincinnati Ohio
Cincinnati Ohio
Cincinnati Ohio
Cincinnati Ohio
Dayton, Ohio
Columbus, Ohio
Columbus, Ohio
Columbus, Ohio
Columbus, Ohio
Columbus, Ohio
Columbus, Ohio
Columbus, Ohio 5
Piscataway, Maryland
Piscataway, Maryland g
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
(City Unknown), Indiana
Kansas City, Missouri
Kansas City, Missouri
Sioux City, Iowa
Joplin, Missouri
Grand Island, Nebraska
Jefferson City, Missouri
N.W. Bergen Co., Waldwick
N.W. Bergen Co., Waldwick
N.W. Bergen Co., Waldwick
N.W. Bergen Co., Waldwick
N.W. Bergen Co., Waldwick
Joint Meeting, Elizabeth,
Joint Meeting, Elizabeth,
Joint Meeting, Elizabeth,
New Jersey
New Jersey
7
, New Jersey
, New Jersey
, New Jersey
, New Jersey
, New Jersey
New Jersey
New Jersey
New Jersey
Date of
Collection
11/18/72
11/18/72
2/22/72
1/24/72
1/25/72
1/26/72
4/3/73
4/3/73
4/4/73
2/27/73
2/27/73
2/27/73
2/27/73
2/26/73
2/27/73
2/27/73
8/8/73
8/9/73
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
11/12/73
11/13/73
11/13/73
11/13/73
11/13/73
11/13/73
11/13/73
11/14/73
Mercury,
ppm
8.0
12.0
0.6
3.0
1.0
2.0
6.0
4.0
15.0
6.0
8.0
10.5
7.0
13.0
11.0
11.0
0.83
,54
1.
2.
8
5.2
1.0
2.3
13.2
1.8
2.0
4.6
43.0
26.0
5.0
5.9
3.6
3.9
7.3
5.8
14.
11.
8.6
81
-------
Table 6-2 (continued). MERCURY CONCENTRATION IN SEWAGE SLUDGES,
DRY SOLIDS BASIS
Sewage Treatment Plant Date of Mercury,
Location Collection ppm
83 Bergen County, Little Ferry, New Jersey 11/13/73 7.1
84 Bergen County, Little Ferry, New Jersey 11/13/73 7.7
85 Bergen County, Little Ferry. New Jersey 11/14/73 5.5
86 Greensboro, North Carolina 9 12/7/73 4.2
87 Pittsburgh, Pennsylvania 12/73 3.3
88 Pittsburgh, Pennsylvania 12/73 4.8
89 Hartford, Connecticut 12/73 3.7
90 Hartford, Connecticut 12/73 __*
91 New Haven Connecticut 12/73 __*
92 New Haven, Connecticut 12/73 -_*
93 Detroit, Michigan 12/73 2.3
94 Detroit, Michigan 12/73 2.6
95 Chicago, Illinois 12/73 "*
96 Chicago, Illinois 12/73 —*
97 Indianapolis, Indiana 12/73 2.3
98 Indianapolis, Indiana 12/73 2.0
*Result not available at present time.
82
-------
The total input of mercury to an incinerator or dryer may be
calculated by multiplying the concentration of mercury in the sludge
by the total incinerator sludge incineration or drying rate
according to the following equation:
0)
i x i
where CM = concentration of mercury in sludge, ppm dry
solids basis
I = sludge incineration or drying rate, kg/day dry
o
solids basis
IM = mercury incinerator input, grams per day
1 x 10 3 = conversion
83
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Incineration of sludges involves combustion of greater than
99 percent of the combustible content of the sludges. Drying is the
removal of water from sludge by heating it with combustion gases
to a temperature above 65°C (ca. 150°F). Flash drying is the almost
instantaneous removal of moisture from solids by introduction into
a hot gas stream.
Temperatures of incineration range from 700 to 980°C (ca. 1300 to
1800°F). Auxiliary heat or fuel requirements to maintain these temperatures
depend upon the combination of moisture and combustible content of the
sludge. Dwell times of sludge at this temperature range from less
than 10 seconds in a cyclonic reactor to a much longer
time in a multiple-hearth furnace. Inert ash is produced by incin-
eration and this ash is disposed of mainly by landfill, although it
is sometimes used in the manufacture of building products. The
principal types of sludge incineration systems currently used in the
United States are listed below in order of number in use:
1. Multiple-hearth
2. Fluidized bed
3. Flash drying with incineration
4. Wet oxidation
5. Cyclonic reactor
Flash drying is the major sludge drying process used in the
United States and consists of the introduction of dewatered sludge
84
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(15 to 25 percent dry solids) into a hot combustion gas stream that
is normally maintained at a temperature of 590 to 700°C (ca. 1100 to
1300°F). The sludge is heated to a temperature of approximately 65
to 95°C (ca. 150 to 200°F), and its moisture content is reduced to
8 to 10 percent. The flash-dried sludge can then be used for various
purposes, including fuel and fertilizer. Systems have also been
designed so that sludge can be dried in modified multiple-hearth
incinerators; sludge temperatures are similar to those used for flash
drying.
Existing capacities for incineration or drying of sewage sludge
range from less than 4,540 kg/day (ca. 10,000 Ib/day) to approximately
454,000 kg/day (ca. 1,000,000 Ib/day) on a dry solids basis. Table
6-3 presents the distribution of sludge burning capacities of existing
plants. The largest known capacities in the U.S. are presented in
Table 6-4. Detroit, Michigan, will have the largest existing burning
capacity at 862,600 kg/day (ca. 1,900,000 Ib/day) and an actual burning
rate of 408,600 kg/day (ca. 900,000 Ib/day), as reported in Table 6-4.
However, Chicago, Illinois, is producing approximately 681,000 kg/day
(ca. 1,500,000 Ib/day) of dry solids; an average of 408,000 kg/day
(ca. 900,000 Ib/day) are disposed of on land, and 272,400 kg/day (ca.
600,000 Ib/day) are flash-dried to 97 percent dry solids for subsequent
use as fertilizer. Based on tests performed at the West-Southwest Treatment
Plant in Chicago, approximately 40 percent of the mercury that enters
the dryer is volatilized.
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Table 6-3. DISTRIBUTION OF EXISTING PLANTS ACCORDING
TO SLUDGE BURNING CAPACITIES9
Dry solids burning capacity
(kg/day)
Less than
4,540
4,540 to
45,400
45,400 to
227,000
Greater than
227,000
(Ib/dav)
(Less than
10,000)
(10,000 to
100,000)
(100,000 to
500,000)
(Greater than
500,000)
Number of plants
17
173
37
6
This tabulation, derived from installation lists of major
manufacturers (1973), represents approximately 83 percent
of existing plants.
86
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Table 6-4. SLUDGE BURNING CAPACITIES OF LARGEST PLANTS
Dry Solids Burned
Location
Detroit, Mich.
Cleveland, Ohio
Minn. - St. Paul
St. Louis, Mo. (Bissell)
Louisville, Ky.
Cincinnati, Ohio
Pittsburgh, Pa.
Indianapolis, Ind.
St. Louis, Mo. (Le May)
Hartford, Conn.
Kansas City, Mo.
Actual
Capacity,
Actual Plus
Current Construction
(kg/day) Cca. Ib/day) (kg/day) (ca. lb/day)
408,600 (900,000) 849,900 (1,872,000)
136,200 (300,000) 544,800 (1,200,000)
272,400 (600,000) 472,160 (1,040,000)
76,270 (168,000) 283,750 ( 625,000)
272,400 ( 600,000)
261,500 ( 576,000)
217,920 ( 480,000)
181,600 ( 400,000)
170,250 ( 375,000)
163,440 ( 360,000)
150,270 ( 331,000)
108,960 (240,000)
136,200 (300,000)
(120,000)
(120,000)
54,480
54,480
54,480 (120,000)
87
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Raw waste supply to wastewater treatment plants and in turn
to incinerators will increase because of increasing population,
consolidation of sewer systems, tertiary treatment of sludges, and
increasing use of sewerable materials. Direct land disposal, ocean
disposal, and incineration and drying of sludges will continue to be
used for sludge disposal. An accurate prediction of the favored method
of disposal is not possible at this time because of energy and
economic considerations and land and water disposal site availability.
Table 6-5 shows the estimated sewage sludge incinerator increase
through 1980. The figures may be reduced because of energy considera-
tions but are the best estimates at this time. The size distribution
of the additional incinerators is expected to be similar to those
shown in Table 6-3. Existing sewer systems in the United States and
potential future systems could produce large amounts of waste sludge.
Estimates of dry solids sewage produced per capita at present range
from 95 to 182 g/day. Using the average per capita figure of 136 g/day
and assuming a New York City population of 10,000,000 served, 1,362,000
kg/day of sewage sludge on a dry solids basis would be produced. This
would require at present an incineration capacity three times as large
as any in existence and would require an even larger burning capacity
for contingency and future needs. Detroit has long-range plans past
the year 2000 for potential burning capacities of approximately
1,816,000 kg/day of dry solids, four times their present capacity.
Detroit currently has additional incineration capacity in construction
and expects to have total capacity of 908,000 kg/day of dry sewage sludge
in operation in 1975. Chicago, the Los Angeles area, and other metro-
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Table 6-5. NUMBER OF SEWAGE SLUDGE INCINERATORS,
1970 THROUGH 1980a
Year Number Comments
1970 200 Manufacturer's estimate
1973 275 Manufacturer's estimate
1975 375 Estimated 30 for 1974 and 70 for 1975
1977 515 Estimated 70/year
1980 725 Estimated 70/year
Factors such as the availability of alternative methods of sludge
disposal and auxiliary combustion energy (when necessary) will have
a significant effect on the actual rate of construction.
89
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poll tan communities produce large amounts of sewage sludge that
are not disposed of by incineration at this time but could be in the
future. Presently New York City disposes of its sludge in the ocean,
and Chicago has the capability to use a variety of treatment and
disposal methods.
Large population centers may in the future install much larger
incineration capacities than are currently in operation. Although
auxiliary fuel is a consideration that will tend to discourage the
short-term use of sludge incineration, new, more efficient sludge
dewatering processes may make incineration more attractive as a
sludge disposal method.
Mercury Emissions
As previously stated, stack emissions were tested at seven sewage
sludge incineration sites; Table 6-6 summarizes the test data. Results
from the Piscataway, Md. plant are not yet available. All sites used a
water scrubber particulate emission control device. Operating scrubber
pressure drops ranged from 6.4 cm water column (w.c.) (ca. 2.5 in. w.c.)
at the Fairfax County, Virginia, incinerator to 145 cm w.c. (ca. 57 in.
w.c.) at the Piscataway, Maryland plant. Mercury removal efficiencies of
water scrubbers varied from a high of 96 percent at South Lake Tahoe,
California, to a low of 68 percent at Waldwick, New Jersey. Data from the
Barstow, California, test are considered invalid because they show that a
quantity of mercury four times greater than the mercury content of the
sludge incinerated was emitted from the stack during the test, indicating
a mistake in the sampling or in the handling or analysis of the samples.
No correlation has been established between the process or scrubber
90
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Table 6-6. MERCURY EMISSIONS FROM SEWAGE SLUDGE INCINERATION9'5
Sewage sludge
Stack test
No.
1
2
3
4
5
6
Plant name
and address
South Lake Tahoe12'13
Plant
South Lake Tahoe, Ca.
Barstow Plant12'14'0
Barstow, Ca.
Fairfax County12'15
Lower Potomac
Sewage Treat. Pit.
Lorton, Va.
Monterey Water12'16
Poll. Cont. Plant
Monterey, Ca.
Northwest Bergen12'1'7
County
Waldwick, N.J.
Northwest Bergen
Date of
test
July 15,
1971
July 21 ,
1971
Aug. 5,
1971
Oct. 13,
1971
Jan. 11,
1972
Nov. 1973
kg/day
burned
during
test
^,405
5,176
13,620
7,264
11 ,986
8,535
Hg, ppm
dry
solids
during
test
8.2
5.5
3.0
8.6
10.0
5.7
Hg
g/day
»
to
incineration
during
28
28
40
62
119
48
test
.0
.44
.82
.5
.7
.7
Hg,
pg/
dscm
21.4
2537.0
31.5
95.1
338.0
113.9
Stack
flow,
dscrn/min
38.8
34.0
270.5
79.0
75.5
85.2
Hg,
g/day
emitted
1.195
124.1
12.25
10.82
37.21
13.85
Hg
Col lection
Efficiency,
%
96
.
70
83
68
72
Emission factor
(grams Hg emitted/
metric ton of slu<
incinerated, dry
solids basis)
0.35
.
0.90
1.49
3.08
1.65
County
Waldwick, N.J.
Washington Suburban Feb. 1974
Sanitary Sewer Comm.,
Piscataway, Md.
Results not available
-------
Table 6-6 (continued). MERCURY EMISSIONS FROM SEWAGE SLUDGE INCINERATION
NOTES:
a. Information was obtained from reports on file at EPA about the source tests at the above
locations, and from EPA internal communications: McCarthy, J.A., to Durham, J.F., May 18,
1972, titled "Summary of Sewage Sludge Incinerator NSPS Development," and Salotto, B.V., to
Ward, T.E., October 11, 1973, titled "Mercury Analysis of Municipal Sludges."
b. Tests 1 through.5 were performed prior to promulgation of Method 101. They were not isokinetic,
were not traversing, employed midget impingers, and are not representative of particulate mercury
that probably was present. Method 101 was used in tests 6 and 7.
c. The data on this test would indicate that more mercury (436.4 percent) was emitted from the
stack than was introduced into the incinerator by the sludge. In view of the other data, this
would appear highly unlikely. Therefore, it is concluded that the emission data from this site
are invalid.
ro
-------
parameters and the mercury removal efficiency of a scrubber. The
results of all tests suggest that a significant quantity of mercury
is collected by water scrubbers.
Mercury removal efficiencies in Table 6-6 are calculated by
the following equation:
RH removal = 100 (1 - Jli ) (2)
iM
where RHg remova] = removal efficiency, %
EHQ = mercury stack emissions, grams/day
I|-lg = mercury input with the sludge, grams/day
The stack test method used in the first five tests in 1971 and 1972 was
designed to measure gaseous mercury emissions; stack traversing and
isokinetic sampling were not performed. Emissions measured in these
tests are therefore not necessarily representative of the mercury in
the stack emissions since particulate mercury may not have been
representatively sampled. The sixth and seventh tests were performed
using Method 101 published in Appendix 2 of the mercury standard
(38 FR 8820); this method is designed to accurately account for both
gaseous mercury and mercury particulate matter. The average mercury
emission factor measured in the first five tests (excluding the Barstow plant)
was 1.65 grams of mercury emitted per metric ton of dry sludge incinerated,
and the emission factor measured in the sixth test was also 1.65
grams of mercury emitted per metric ton of dry sludge. Results from the
seventh test are not yet available. The similar results obtained
93
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by both methods indicate that the mercury emitted in a sludge
incinerator stack gas that has passed through a wet scrubber is
in the vapor form.
Appendix C describes the method of determining atmospheric
dispersion estimates and maximum allowable mercury emission levels.
Table C-l describes the source characteristics of a meteorologically
restrictive hypothetical sewage sludge incinerator facility, and
Figure C-l describes the maximum allowable emissions. Pasquill Class D
stability applies to mercury emissions from sewage sludge incinerators
since most incinerators are located away from the centers of cities
at suburban and even more remote'locations so that tall buildings
that cause air disturbances are not expected in the vicinity of such
sites. The diffusion model assumes a single emission point and a
relatively low effective stack height of 20 meters. The referenced
restrictive assumptions in Appendix C were used in order to be reasonably
confident that the calculated maximum emission rate would not exceed
the ambient concentration guideline of 1.0 yg/m3 for a 30-day average
under realistic circumstances. Under these conditions, therefore,
the maximum allowable emission of mercury from a sludge incineration
or drying site is 3200 grams of mercury per 24-hour period.
One of the assumptions used in deriving the maximum allowable
mercury emissions from mercury cell chlor-alkali plants and mercury extrac-
tion plants differs from those discussed above.11 An effective stack height
of 10 meters, which implies essentially ground-level emissions, was usted
94
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because: (1) chlor-alkali plants discharge some emissions directly
from building vents, frequently resulting in aerodynamic downwash,
and (2) many mercury extraction plants are located in mountainous
areas where the relatively short stacks used result in impingement
on1 the mountains. The decreased stack height results in a lower
emission limit of 2300 grams per 24-hour period for these sources.
The solid line in Figure 6-1 is a curve showing the total daily
mercury content of sewage sludge for incineration (incinerator input)
for Pasquill D stability, assuming no control of mercury emissions,
which will result in a mercury concentration of 1 yg/m3 in the
ambient air. The curve represented by the solid line is the locus
of the equation:
3200 g/day (allowable mercury emissions)
UHg) Allowable Mercury Input = 1- (mercury removal efficiency)
Available data indicate that various degrees of mercury emission con-
trol are achieved but that the control efficiency of water scrubbers
is not predictable and may be low in some cases. If the level of control
of mercury emissions can be established, then a new curve of total
mercury content of sewage sludge can be constructed according to equation
(3) above, as shown by the curve in Figure 6-2 for 50 percent control of
mercury emissions. Total daily mercury incinerator input for all known
incineration sites with present maximum potential burning capacities
greater than 149,820 kg/day (ca. 330,000 Ib/dav) of dry solids are
plotted in Figures 6-1 and 6-2. Other selected daily mercury inputs
are also plotted.
95
-------
1,000,000
CC
100,000
10,000
o
LU
Legend:
—— Limit of mercury input with sludge, considering D stability,
3200 g/day maximum allowable Hg stack emission, and 0%
454,000 emission control
— — Limit of mercury input with sludge, considering C stability,
1500 g/day maximum allowable Hg stack emission, and 0%
emission control
ODetroit, Mich., max. potential burning rate in~2005
D Detroit, Mich., max. potential burning rate in 1974
A Detroit, Mich., actual burning rate in 1974
• Other known sludge incinerator sites using maximum
potential burning rate and either:
1. An actual sludge mercury concentration from
the site, or
2. An average sludge mercury concentration of
5 ppm when no mercury analysis was
available.
NOTE: All known sites greater than 150,000 kg/day (ca. 330,000
Ib/day) burning capacity are plotted. Selected other sites
are also plotted.
cr
a
45,400
4,540
1 10 100
CONCENTRATION OF MERCURY IN SEWAGE SLUDGE, ppm dry solids basis
Figure 6-1. Total mercury-content of sewage sludge for incineration, assuming 0 percent control of emissions.
-------
1,000,000
CŁ
=3
co
CO
Q
_J
O
cc
a
100,000
10,000
Legend:
——— Limit of mercury input with sludge, considering D stability,
454 000 320° ?'/day maximum allowable Hg stack emission, and 50%
' emission control
— -—Limit of mercury input with sludge, considering C stability,
*. 1500 g,/day maximum allowable Hg stack emission, and 507,
. ^ emission control
* O Detroit, Mich., max. potential burning rate in ~2005
g D Detroit, Mich., max. potential burning rate in 1974
A Detroit, Mich., actual burning rate in 1974
• Other known sludge incinerator sites using maximum
potential burning rate and either:
1. An actual sludge mercury concentration from
the site, or
cc
=3
03
45,400
2. A hypothetical sludge mercury concentration
of 5 ppm when no mercury analysis was
available.
NOTE: All known sites greater than 150,000 kg/day (ca. 330,000
Ib/day) burning capacity are plotted. Selected other
sites are also plotted.
J 4,540
CONCENTRATION OF MERCURY IN SEWAGE SLUDGE, ppm dry solids basis
Figure 6-2. Total mercury content of sewage sludge for incineration, assuming 50 percent control of emissions.
-------
No presently known sludge incineration site has a total
daily mercury incinerator input in excess of 3200 grams per day.
The highest known input is 1000 grams per day at the Detroit,
Michigan, incineration site. The Detroit value is based on a
sludge incineration rate of 408,600 kg (ca. 900,000 Ib) of dry
solids burned per day and on a mercury concentration of 2.5 ppm Hg,
dry solids basis, which is the average of two sludge analyses in
December 1973. If mercury concentrations of sludge corresponding to
the upper limit of the range of mercury content as shown in Table 6-2
occurred at the maximum burning capacities shown in Table 6-4, the
total daily mercury content of the sludge produced would far exceed
3200 grams. The largest sludge Incineration facility that is
contemplated for the near future would incinerate 908,000 kg
(ca. 2,000,000 Ib) of dry solids per day; if sludge with the highest
reasonably expected mercury content of 15 ppm were incinerated, and if
50 percent of the mercury in the sludge were emitted into the atmosphere,
the plant would emit 6,800 grams of mercury per day.
The production of sewage sludge in excess of 1,362,000 kg/day
(ca. 3,000,000 Ib/day) of dry solids is approaching reality in
New York City; other smaller municipalities could produce amounts
well in excess of 681,000 kg/day (ca. 1,500,000 Ib/day) of dry solids.
Although our investigations were mainly focused on the
incineration of municipal sewage sludge, it became apparent during
98
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the investigation that the incineration of wastewater treatment
plant sludges and pretreatment sludges from various industries
could present the same problems as the incineration of municipal
sludges. Information obtained from the City of Chicago
indicates that approximately 40 percent10 of the mercury content
of sewage sludge can be emitted during the drying operation.
For this reason, the proposed standard is made applicable to the
incineration and dryjng of all wastewater treatment plant sludges.
The proposed standard also applies to the incineration and
drying of industrial wastewater sludges.
The most direct method for demonstrating compliance with
the emission standard is performing an approved stack emission
test demonstrating that the actual stack emissions are below
the maximum allowable emission level of the regulation. However,
the mercury stack emission test (Method 101) can cost in excess
of $5,000. If the mercury input into the incinerator or dryer is
determined and if it is further assumed that all of the mercury
that enters into the incinerator or dryer is emitted to the atmosphere,
an effective method of compliance would be to demonstrate that the
mercury input into the process is less than the emission standard.
An advantage of this method of compliance is that it is relatively
inexpensive and would cost less than $200 per compliance test.
A plant whose input is measured to be less than the standard
is in compliance. An operator of a plant whose input is in excess
of the standard has the option of testing mercury emissions by the
99
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stack sampling method. In the latter case, any collection efficiency
achieved by the control system will be reflected in the results.
For a facility in excess of the standard after stack testing,
no mercury removal processes for sludge or stack gases are currently
available. A plant in this situation would have to reduce mercury
emissions by (1) reduction of the burning rate, (2) determination
of sewage system users, if any, which put high mercury content sludges
into the sewage system, and the requirement that those users pretreat
their sludges to remove mercury, and (3) any other acceptable means
to achieve reduction of emissions to acceptable levels.
Most affected facilities will probably choose the less
expensive sludge sampling compliance option; relatively few, if
any, will find it necessary to sample stack emissions.
100
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REFERENCES
1. Balakrishman, S., Williamson, D.E., and Okey, R.W., State of
the Art Review on Sludge Incineration Practice, Federal Water
Quality Administration, Program #17070 DIV, Contract #14-12-499,
Cincinnati, Ohio, April 1970, p. 5.
2. APHA, AWWA, WPCF, Standard Methods for the Examination of Water
and Wastewater, Twelfth Edition, Boyd Printing Co., Inc.,
Albany, N.Y., 1965.
3. Krup, M., internal memo in the Metropolitan Sanitary District
of Greater Chicago (MSDGC) to D. Zenz, April 5, 1971. (Telephone
confirmation October 30, 1973, by T. Ward, EPA, with Lue-Hing,
Zenz, and Krup, MSDGC, that data in April 5, 1971, MSDGC memo
are dry solids basis.) Data Nos. 1-6 in Table 6-2.
4. Salotta, B.V., Environmental Protection Agency internal memo
to T.E. Ward, October-11, 1973. Data Nos. 7-57 in Table 6-2.
5. Acting Director, Annapolis Field Office, Environmental Protection
Agency internal memo to Z. Antoniak, August 21, 1973. Data Nos.
58 and 59 in Table 6-2.
6. Chaney, R.L., U.S. Department of Agriculture memo to Environmental
Protection Agency Sludge Disposal Work Group (Ken Johnson, Chairman),
Attachments B and C, February 26, 1974. Data Nos. 60-74 in Table 6-2,
7. Neulicht, R.L., Environmental Protection Agency, EPA-OAWM-OAQPS-
ESED-EMB, File No. 74-SSI-l, 1974. Data Nos. 75-79 in Table 6-2.
8. Ward, T.E., Environmental Protection Agency, EPA-OAWM-OAQPS-
ESED-EMB, File No. 74-MISC-2, 1974. Data Nos. 80-85 in Table 6-2.
9. Ward, T.E., Environmental Protection Agency, EPA-OAWM-OAQPS-
ESED-EMB, File No. 74-SSI-2, 1974. Data Nos. 86-98 in Table 6-2.
10. Lue-Hing, Cecil (Metropolitan Sanitary District of Greater Chicago),
letter to S.L. Roy (EPA), October 23, 1973.
11. Background Information - Proposed National Emission Standards
for Hazardous Air PollutantsTAsbestos, Beryllium. Mercury),
APTD-0753, Environmental Protection Agency, Research Triangle
Park, N.C., December 1971.
12. McCarthy, J.A., Environmental Protection Agency internal memo
to J.F. Durham, "Summary of Sewage Sludge Incinerator New
Source Performance Standard'.Development," May 18, 1972.
101
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13. York Research Corp., South Lake Tahoe Public Utility District
Sludge Incinerator, South Lake Tahoe, California, EPA Contract
No. CPA-70-131, Report No. Y-7394-H, Sept. 28, 1971.
14. York Research Corp., Barstow Reclamation Plant Sludge Incinerator,
Barstow, California, EPA Contract No. CPA-70-131, Report No. Y-7394-H,
Sept. 29, 1971.
15. York Research Corp., Lower Potomac Sludge Incinerator, Fairfax
County, Va., EPA Contract No. CPA-70-131, Report No. Y-7394-I,
Sept. 1, 1971.
16. York Research Corp., Monterey Water Pollution Control Plant
Sludge Incinerator, Monterey, California, EPA Contract No.
CPA-70-131, Report No. Y-7394-I, December 8, 1971.
17. Engineering-Science, Inc., Northwest Bergen County Sewer
Authority Sludge Incinerator, Waldwick, N.J., EPA Contract
No. 68-02-0225, Task No. 7, May 1972.
ADDITIONAL SOURCES OF INFORMATION
Background Information on Development of National Emission
Standards for Hazardous Air Pollutants: Asbestos, Beryllium
and Mercury, Publication No. APTD-1503, Environmental Protection
Agency, Research Triangle Park, N.C., March 1973.
Control Techniques for Particulate Air Pollutants, Publication
No. AP-51, Environmental Protection Agency, Research Triangle
Park, N.C., January 1969.
Task Force Report on Sludge Disposal, Environmental Protection
Agency, Office of Research and Monitoring, Washington, D.C.,
April 1972.
Sewage Sludge Incineration. Environmental Protection Agency,
Task Force for Office of Research and Monitoring Report No.
EPA-R2-72-040, August 1972.
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7. ENVIRONMENTAL IMPACT
ASBESTOS
The proposed amendments to the asbestos standard will have
significant beneficial effects by reducing emissions of asbestos
and mercury to the outside air; they may also have limited adverse
effects on land and water resources. In the judgment of the Admini-
strator, however, the beneficial effects of the proposed amendments
outweigh the following potentially adverse effects that were con-
sidered:
1. More asbestos waste will be collected in control
devices and will have to be disposed of.
2. The use of dust-suppression agents to prevent wind
erosion of asbestos waste may cause water pollution.
3. Other possibly harmful fibers such as fiberglass and
mineral wool are substituted for asbestos in friable
insulating materials.
4. Alternative disposal methods to the incineration of
wastewater treatment plant sludges may cause mercury
pollution of land and water.
The proposed amendments will force more efficient cleaning of
gases now being emitted to the outside air from some asbestos manu-
facturing and fabrication plants; this action in turn will result
in the production of more asbestos-containing material for disposal.
103
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However, the land disposal of such waste will be regulated by
the proposed standard, which will ensure protection against emis-
sions to the outside air during all steps of the disposal process.
Further, potential asbestos water pollution problems at disposal
sites can be prevented by proper selection, design, and operation
of the sites. All landfill sites where asbestos wastes are deposited
should be selected so as to prevent horizontal and vertical migra-
tion of asbestos fibers to ground or surface waters. In cases
where geologic conditions may not reasonably ensure this, adequate
precautions, such as the installation of impervious liners for the
waste disposal site, should be taken to ensure long-term protection
of the environment. Further, the intrusion of moisture into land
disposal sites for asbestos should be minimized. To assist in the
appropriate future use of asbestos waste disposal sites, the loca-
tion of such sites should be permanently recorded in the appropriate
office of the legal jurisdiction where the site is located. The
asbestos waste disposal standard will be beneficial in reducing
the amount of asbestos wastes that are disposed of, since it will
stimulate some manufacturers who produce large quantities of poten-
tial wastes to reuse more of these wastes in their processes. The
proposed standard will not increase the total quantity of asbestos
waste to be disposed of from demolition and renovation operations,
but will result in the segregation of the asbestos waste from large
quantities of other demolition and renovation debris. Because the
asbestos waste will then be more concentrated, strict control of the
disposal operations under the proposed standard will be more econom-ical
and manageable.
104
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The use of dust-suppression agents as optional methods to
control wind erosion on all portions of asbestos mill tailings
piles and on active sections of other asbestos waste disposal sites
should reduce the total amount of asbestos entering surface waters
from such sites. Such agents have been used successfully to pre-
vent wind erosion of dust from various sources such as dirt roads,
mine tailings disposal areas, farm lands, and airports. Although these
agents could possibly cause land and water pollution problems, the
history of usage over a period of more than 10 years has not re-
vealed any substantial pollution problems. These agents are not
toxic in the dilute form in which they are applied. After the
agents have cured for a few hours, they will erode away only with
long-term weathering.
Although asbestos is no longer used in manufacturing friable
insulating materials in the United States, the proposed standard
bans the use of asbestos and therefore allows the use of substitute
fibers such as ceramic wool, mineral wool, and fiberglass. In
contrast with asbestos, there is no evidence that these materials
cause adverse health effects in the concentrations found in
occupational or ambient environments.
MERCURY
The proposed mercury standard will limit mercury emissions
from wastewater treatment plant sludge incinerators and dryers.
No known existing incinerator sites are exceeding the standard.
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Should an incineration or drying site exceed the maximum allow-
able emission and have to reduce its capacity, there are three
known major alternatives for disposal of sewage sludge: (1)
burning at an acceptable separate location or in acceptable
separate incineration systems, (2) land disposal, or (3) ocean
disposal. Wet oxidation and pyrolysis are other less used alter-
natives. The first alternative includes burning or drying at ad-
ditional locations, burning in conjunction with municipal solid
waste, or burning in conjunction with coal-fired boilers. Land
disposal includes soil improvement by addition of liquid and dry
sludge, landfilling of sludges, and composting of sludges with
solid wastes. Few new ocean disposal sites for sludges are an-
ticipated.
In summary, no presently known facilities will be affected.
The number of potential affected facilities is small, and in those
facilities only a fraction of sludge production would have to
be disposed of by alternative methods. The relative significance
of the quantity of sludge that may have to be disposed of on land as
a result of the proposed standard is anticipated to be insignificant
compared to the amounts of sludge that are already being disposed of on
land. The impact of the standard on air is considered to be positive
in every conceivable case. Therefore, the adverse environmental
impact of this standard is considered to be minimal.
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8. ECONOMIC IMPACT
ASBESTOS
Although the proposed amendments are not based on economic
considerations, EPA has evaluated the economic impact and judges
it to be reasonable. Costs for compliance among the various sources
covered by the amendments are variable. In most cases the economic
impact is not based on detailed cost estimates because such
information is not available; for example, detailed information
concerning the number, size, and characteristics of additional
sources covered by the proposed demolition and renovation regulation
is not available. Although the amendments may adversely affect some
marginal plants or companies, the impact to the asbestos industries
as a whole should not be large. A summary of the economic impact
is given in Table 8-1.
Asbestos Manufacturing
Only one known shotgun shell manufacturing plant in the
United States uses asbestos. This plant already has mechanical
particulate collectors and spray scrubbers which reduce the asbestos
emissions; however, it may be necessary for the plant to install
the fabric filtration devices specified by the regulation. Such
additions would include two 28-am /min (ca. 1000-acfm)*
baghouses at an installed cost of approximately $8400. The annual operating
cost would be approximately $2100, which amounts to about 1.5 cents
per 100 boxes of shells or about 0.005 percent of the product value.
The plant is expected to be able to manage this increased cost if
additional controls are necessary to comply with the proposed regulation.
*
3
am/min = actual cubic meters per minute;
acfm = actual cubic feet per minute.
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Table 8-1. SUMMARY OF ECONOMIC IMPACT OF PROPOSED
AMENDMENTS TO ASBESTOS STANDARD
Industry
1.
2.
3.
4.
5.
6.
Manufacturing
A. Shotgun Shell
B. Asbestos Asphalt
Plants
Fabrication
A. Asbestos Building Products
B. Asbestos Friction Products
(i) Large
(ii) Intermediate & Small
C. Asbestos Board Fabricators
Demolition
Renovation
Disposal of Wastes
A. Mills
B. Manufacturing & Fabrication
C. Demolition
D. Spraying
Waste Disposal Sites
A. Mills (In Use
B. Industry Operated
Disposal Sites
«C. Private & Municipal
(i) Covered
(ii) Open
Number of
Potential
Sources
1
5000 (50/year)
12
20
380
100
300
No estimate
6
1250
3300
No estimate
6
6
15
1200-2000
6000-14,000
Estimated No. of Sources
That Must Add Additional
Controls
1
10 /year
0
0
100
20
300
1000
3
625
3300
0
6
6
10
500 (Sanitary landfill)
200 (Open dump)
Estimated Maximum Cost to Industry
to Comply with Proposed Amendments
Capital ($)
8,400
42,000
0
0
420,000
84,000
75 ,000
0
48 ,000
48,000
95,000
400 ,000
Annual ($)
2,100
11 ,000
0
0
110,000
21 ,000
520,000
500 ,000
24,000
1 ,250,000
1 ,650 ,000
0
150,000
0
50,000
600,000
o
CO
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The asphalt concrete industry consumes approximately 4500 tons
of asbestos per year and the total amount of asbestos-asphalt concrete
produced nationwide is estimated to be 136,200 metric tons (ca. 150,000
tons) per year. This amount of asbestos-asphalt concrete represents
less than 0.1 percent of the total amount of asphalt concrete produced
in the United States, and involves approximately 50 plants annually of
the estimated 5000 asphalt concrete plants in the United States. Eyen
for these plants, asbestos-asphalt concrete represents less than 10
percent of the total amount of asphalt concrete produced.
EPA estimates that approximately 10 percent (500) of the existing
plants can already comply with the proposed regulation; no additional
expense would be required if such plants chose to manufacture asbestos-
asphalt concrete. The existing asphalt concrete plants that
cannot comply with the proposed amendment (approximately 4500 plants)
will have to install additional controls if they desire to manufacture
asbestos-asphalt concrete. Such plants will probably install a small
control device to treat only the asbestos-contaminated gas streams,
rather than a control device for all emission streams from the
facility. For an average-sized plant, the maximum amount of ventilation
air flow attributable to the mixer and the ventilation system for
asbestos materials handling would be approximately 28 am3/min. The
installed capital cost of a baghouse of this size would be $4200 and the
annual operating cost would be $1100. The capital cost of the small
baghouse represents approximately 1.5 percent of the total capital
invested in an average-sized plant. The annual cost amounts to 0.5
percent of the value of the asbestos-asphalt concrete produced.
If as many as 10 asbestos-asphalt concrete plants per year installed
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such a baghouse, the capital investment for the entire industry
would be $42,000, and the annual operating cost would be $11,000.
The additional control required by the provisions of the proposed
amendment will be taken into consideration in the calculated
profitability of manufacturing asbestos-asphalt concrete by each
plant operator on a case-by-case basis. If the venture is profitable,
the. operator will add the appropriate control device and manufacture
asbestos-asphalt concrete. If it is not, the operator will not use
asbestos and will still manufacture asbestos-free asphalt concrete.
The Agency estimates that some 80 to 90 percent of the new and modified
asphalt concrete plants will install fabric filter collection devices,
and the remainder will install venturi scrubbers to comply with
the Federal new source performance standard for particulates (40 CFR
Part 60). New fabric filter collection devices can meet the require-
ments specified under 40 CFR 61.23(a). Most of the scrubbers installed
on new and modified plants are also expected to be able to comply
with the no-visible-emission requirement of the proposed amendment.
The economic impact of the proposed amendment for new and modified
plants is therefore expected to be minimal.
Asbestos Fabrication
The Agency's investigation of the asbestos fabrication industry,
which included inspections of fabrication sites and air pollution
control equipment, and consultations with industrial representatives
and trade associations, was used as a basis for the estimates
presented in this section.
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All of the 12 estimated fabricating facilities for asbestos
building products are estimated to be able to meet the proposed
amendments with existing control equipment. Therefore, the proposed
amendments are expected to have no impact on these sources.
An estimated 20 large facilities fabricate asbestos friction
products and most of these already comply with the proposed amendments.
Approximately 100 of an estimated 380 friction product fabricators
of intermediate and small size will have to add controls. Most of these
sources will require control devices no larger than 28 am /min in
capacity. If a baghouse of this size is chosen, the installed capital cost
would be $420,000 for the entire asbestos friction product
fabrication industry and the annual operating cost would be $110,000.
Approximately 20 of the estimated 100 asbestos-cement or
asbestos-silicate board fabrication facilities subject to the
proposed amendments will be required to add or upgrade control
equipment. If one 28-am3/min fabric filtration device is added
at each facility, the estimated installed capital cost for the industry
would be $84,000 and the annual operating cost would be $21,000.
Asbestos Demolition and Renovation
The general economic impact of the demolition regulation,
discussed in the background information document for the promulgated
standard,1 is incrementally increased by the proposed amendments
to the standard. The only proposed amendments that are expected
to have a significant economic impact are the renovation provisions
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and the extension of demolition coverage to apparatus other than
pipes, boilers, and load-supporting structural members
(i.e., to tanks, reactors, turbines, furnaces, and non-load-
supporting structural members).
The stripping of friable asbestos materials from tanks,
reactors, turbines, furnaces and non-load-supporting structural
members, or the removal of such apparatus from buildings
with the asbestos materials intact, will increase the number
of sources subject to the demolition standard by an estimated
10 percent. Although the demolition standard was estimated
to increase demolition costs by $45 million annually
(based on the demolition of 26,000 buildings per year),1
experience in enforcing the standard since promulgation
indicates that the actual number of demolition operations and
the additional cost imposed by the demolition standard is
much less than previously predicted. Based on the number of
demolition operations reported to one Agency Regional Office in
the period since promulgation and adjusting this value to
reflect additional demolition operations covered by the promulgated
standard that were unreported, it is estimated that the number
of demolition operations performed in the United States and covered
by the standard is less than 3000 per year. The estimated cost of
complying with the demolition provisions is therefore only $5.2 million
per year instead of the $45 million that was previously estimated.
The impact of the additional coverage of the proposed amendments
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to the demolition standard is estimated to be 10 percent of
the total impact of the demolition standard or an annual
operating cost of $520,000.
The number of renovation operations subject to the proposed
amendment is large, but will probably be less than the number of
building demolitions. The additional cost required to comply
with the proposed regulation will be the cost of stripping friable
asbestos materials from pipes and other specified apparatus.
The amendment will apply only to relatively large residential
and non-residential building renovation operations (for example,
where heating systems are removed) since only operations involving
the removal of more than 80 meters of pipe or more than 15 square
meters of boiler, tank, reactor, turbine, furnace, or structural
member insulation are covered. The rebuilding of industrial plants
will in most cases involve the removal of pipes and apparatus
in sufficient quantities to be subject to the proposed amendment.
The replacement of apparatus in non-residential buildings and
chemical plants will also be covered by the proposed amendment
in certain cases. For a relatively small-scale renovation involving
removal of pipes and apparatus, the total renovation cost will
be about $50,000. The additional cost required to comply with
the proposed amendment for such a renovation operation would be
the cost of labor for wetting and stripping the friable asbestos
materials from the pipes and apparatus during this operation.
The stripping cost for such an operation is estimated to be $250.
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The cost required by the proposed amendment for stripping and
wetting should thus be no more than 0.5 percent of the cost of
the renovation operation. If 1,000 renovations per year are
subject to the proposed standard ..and the average total cost for each
renovation is $100,000, the total industry annual operating cost to
comply with the proposed standard is estimated to be $500,000.
Within a broad range of costs, the demand for demolition or
renovation services is inelastic because of the lack of feasible
alternatives. Even if old buildings and structures are abandoned,
local government agencies will eventually be forced to have them
demolished. Because the demand for these services is inelastic, the
increased cost of demolition or renovation will be borne by the consumers
of these services, rather than by the contractors, and any additional
renovation or demolition costs will be passed on.
Disposal of Asbestos Wastes
Several asbestos mills will have to adopt control methods for the
tailings disposal process to comply with the proposed amendments* The
Installed capital cost of a screw mixer and associated equipment for
wetting tailings prior to dumping is estimated to be approximately
$25,000 per mill and the annual operating cost is estimated to be $8000,
Six asbestos mills are currently operating. One mill uses a wet
milling process and therefore produces wet tailings, and two other mills
have already installed screw mixers and wetting systems. For the three
operating asbestos mills that may have to add screw mixers, the total
capital investment cost to the industry is estimated to be $75,000 and
the total annual operating cost Is estimated to be $24,000.
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A substantial number of asbestos manufacturing and fabricating operations
already comply with the proposed amendments and will therefore incur no
additional expenditure. It is estimated that 50 percent of these sources
may already comply with the asbestos waste disposal standard. The proposed
amendments will increase the trend of recycling wastes at manufacturing
operations and thus will not increase the amount of asbestos waste that
must be disposed of. However, some manufacturing and fabrication
operations will incur increased costs for wetting, packaging, and
labeling the waste. The average additional cost imposed by the
proposed amendments is estimated to be approximately $2000 annually
per source. This estimate does not include additional costs for
collection, transportation, or deposition on a disposal site,
since these operations are currently being performed. For a
few large manufacturing sources, the additional annual cost
may be significantly higher than $2000, but for many other sources
the additional waste disposal cost would be less. Approximately
500 fabrication sources and 750 manufacturing sources will be
subject to the proposed amendments, and 50 percent (625) are estimated to
already be in compliance. The total additional cost imposed on this indus-
try by the proposed amendments is estimated to be $1.25 million per year.
The amount of friable asbestos material that must be
disposed of to comply with the proposed amendments will be
relatively small for most demolition and renovation operations. While
pipes and other specified items covered with friable asbestos material may
be disposed of intact, the salvage value of the metal will probably
provide sufficient incentive to strip the insulation from such
items. The additional cost incurred in disposing of the stripped
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friable asbestos wastes is expected to be no more than $500 per
demolition or renovation source, even for large renovation and
demolition operations. This figure includes the cost of consolidating
the stripped materials, wetting the waste material, packaging the
material in Impermeable containers, and labeling the containers.
The annual cost of complying with the proposed waste disposal standard
is estimated to be $1,650,000. Other waste disposal disposal costs
such as transportation and deposition in a waste disposal site
are incurred even in the absence of the proposed amendments and
cannot logically be assessed as an additional cost imposed by
the proposed amendments. As previously explained, any additional
cost for disposal of renovation and demolition waste will probably
be borne by the owner of the building being demolished or renovated.
Since it appears that asbestos waste from spraying operations
is now being disposed of in accordance with the proposed waste
disposal amendments, it is expected that there will be no economic
impact on this source category.
Waste Disposal Sites
Asbestos wastes generated by sources subject to the proposed
amendments are deposited on large asbestos mill tailings piles
usually operated by the mill, waste disposal sites owned by
asbestos companies, and private and municipal solid waste disposal
sites. The proposed amendments require that there be no visible
emissions from the disposal sites, or optionally that the owners
or operators of the site comply with certain specified procedures.
In addition, the proposed amendments require the posting of
warning signs and the fencing of specified waste disposal operations.
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An estimated six asbestos mill tailings piles are in current
usage, and six are completely inactive. The Agency's investigation
indicated that completely inactive sites will probably be in compliance
with the no-visible-emission provision of the proposed amendments.
Warning signs and fencing must be installed where not already
in place. Assuming that the average-sized, completely inactive
tailings pile covers 200,000 m2 (ca. 50 acres), the cost of
installing fencing and warning signs is estimated to be $8000 per
site, or $48,000 for the six existing inactive tailings disposal
sites.
One, and perhaps two, of the six asbestos mill tailings piles
in current usage will probably be able to comply with the proposed
no-visible-emission provision without additional expenditures. The
average size of such tailings disposal sites is approximately
2
200,000 m (ca. 50 acres). The majority of this area is inactive,
with the recent working face and vehicle roads on the tailings pile
the only active portions. The Agency's observations during inspection;
of tailings piles indicated that many of the inactive portions of dis-
posal piles are unlikely to discharge visible emissions, and therefore
expenditures for dust-suppression agents or other control measures
would not be required to comply with the proposed amendments.
Where controls are needed on the inactive portions of a disposal
site, a dust-suppression agent will probably be applied. The annual
expenditure for application to a tailings disposal area would be
$15,000.
Since most asbestos mills will use the method of wetting
tailings with a dust-suppression agent to comply with the proposed
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tailings disposal provision, the active face of the disposal site
will probably meet the no-visible-emission provision without
additional expenditures. If dust-suppression agents must be applied
to the active portions of a disposal site, the annual operating
cost is estimated to be approximately $10,000. In some cases fencing
may already be installed, thus not requiring additional expenditures.
The capital costs for fencing and warning signs are estimated to be
approximately $8000 for a 200,000 m2 disposal site. While the actual
expenditures to be made by currently used tailings disposal sites
as a result of the proposed amendments are not known, a worst case
would require an annual operating cost of $25,000 for dust-suppression
agent application and also a capital cost of $8000 for fencing and
warning signs. On an industry-wide basis, six tailings disposal
operations would have to spend $150,000 in annual operating costs
for applying dust-suppression agents and $48,000 in capital costs
for installing fencing and signs.
An estimated 10 to 15 asbestos waste disposal sites are operated
by asbestos manufacturing and fabrication sources. Several
of these disposal sites will probably require additional control
methods to comply with the no-visible-emission provisions of
the proposed amendments. The optional compliance method requires
that inactive sections be covered with 60 cm (centimeters) of
non-asbestos-containing material, or with 15 cm of non-asbestos-
containing material and a vegetative cover. The average area of
such sites is estimated to be 12,140 m2 (ca. 3 acres). The most costly
method of compliance would be to cover the entire inactive section pf tne
disposal site with 60 cm of soil, which would cost approximately
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$20,000. The establishment of a vegetative cover, including
15 cm of covering soil, initial cultivating, seeding, and
fertilization, is estimated to cost $7000 for a 12,140-m2 site; the
annual vegetative maintenance would cost an estimated $1000 per
year for a 12,140-m2 (ca. 3 acres); sfte.
The optional compliance method for active sections requires
that either a dust-suppression agent or a 15-cm coyer of non-asbestos
material be applied at the end of each operating day. The estimated
annual operating cost for applying a dust-suppression agent at the
end of each operating day is $4000. The cost required to put on
15 cm of cover at the end of each operating day will probably be
more than the cost of applying a dust-suppression agent but will
not require the installation of a fence when used in conjunction
tfith an optional method for inactive sections of a disposal site.
The capital cost for fencing, where required, and warning sign
installation is estimated to be $2500 per site.
For a disposal site to comply with the standard, the capital
investment cost would be $9500 and operating costs would be $5000
per year. The choice of a 60-cm cover rather than the less costly
option of a vegetative cover would require a capital investment
of $22,500 and an annual operating cost of $5000. Only a few of
the disposal sites will have to expend such sums of money to
comply with the proposed standard. However, capital cost would be
$95,000 and annual operating cost would be $50,000 if as many as
10 disposal sites had to adopt the optional control methods of the
proposed standard.
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Many states have recently instituted permit systems for
solid waste disposal sites, and the operating status of many
sites is in a state of change. The current and future trend is
to the operation of such sites as sanitary landfill operations.
While the proposed standard for asbestos waste disposal sites
could require changes in operating practices at a large number
of private and municipally operated waste disposal sites,
these changes are consistent with the trend to operate as
sanitary landfills. The total number of private and municipally
operated waste disposal sites is not known, though various estimates
have been made. Based on a 1968 estimate that was updated in
1971 by the Agency, 1500 landfill sites in the United States use
some type of cover and 14,000 disposal sites do not use cover. The
Agency has recently made another estimate based on a survey of four
states, with results prorated on the basis of population to the
entire United States. This estimate indicates that there are 6000
disposal sites that do not meet the criteria of a sanitary landfill
site and 2000 sanitary landfill sites.
If a site that accepts asbestos-containing waste meets the
criteria for a sanitary landfill, it will comply with the provisions
of the proposed amendments except for the installation of warning
signs. The capital cost for installing signs around a landfill site covering
161,880 m2 (ca. 40 acres) is estimated to be $500. Disposal sites that
are not sanitary landfills but which accept asbestos wastes will probably
upgrade a section of the site to meet Federal sanitary landfill
guidelines and will have to add warning signs. The amount of
asbestos-containing waste deposited at a landfill will be rather small,
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in most cases, compared to the amounts of other solid wastes that are
landfilled. It is estimated that less than 1.8 metric tons/day of asbestos-
containing waste will be deposited at an average site. Based on an
estimated sanitary landfill operating cost of $3.30/metric ton,2
the annual operating cost for sanitary landfilling only asbestos-containing
waste would be approximately $2000. It is estimated that 500 sanitary
landfills and 300 open disposal sites will dispose of asbestos-
containing waste. The estimated total additional cost incurred on
waste disposal site operations by the propos-ed standard is estimated
to be capital costs of $400,000 for signs and fencing and an annual
operating cost of $600,000. The increased cost of disposing of
asbestos-containing waste would probably be passed on to the waste
generator, and the economic impact of the proposed amendment
on the operators of disposal sites would therefore be minimal.
MERCURY
The proposed standard for mercury emissions from sewage
sludge incineration and drying plants is based on maintaining
the ambient air guideline deemed safe by the Administrator
as required by section 112 of the Act and does not require that
economics be considered. The economic effect will, however, be
minimal for the following reasons: (1) no known affected facilities
will be required to make sludge handling adjustments; (2) even in
the few situations which conceivably could require the alternative
disposal of sludges, only a fraction of the sludge production would be
affected; and (3) for future plants or expansion of existing plants, the
emission limit will allow relatively large incineration plants to
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be operated. If the sludge mercury concentration is 5.0 ppm dry
solids basis and the collection efficiency is 50 percent, these
large installations can incinerate or dry up to 1,225,800 kg (ca.
2,700,000 pounds) of dry solids per day. The actual allowable burning
rate with respect to mercury will depend ultimately on the actual sludge
mercury concentration and removal efficiencies.
The cost impact of sludge mercury analysis is considered to be
relatively small (approximately $200 per compliance test), and
some treatment plants already routinely perform mercury sludge analysis.
The cost of a compliance stack test using Method 101 can exceed
$5000 and will be significant for small facilities. Most facilities,
however, will be able to use the less expensive sludge sampling
option to determine compliance.
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REFERENCES
1. Background Information on Development of National Emission
Standards for Hazardous Air Pollutants: Asbestos, Beryllium,
and Mercury, APTD-1503, U. S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle
Park, N. C. , March 1973.
2. Decision-Makers Guide in Solid Waste Management, U. S. Environmental
Protection Agency, Office of Solid Waste Management Programs, no date.
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APPENDIX A. OPTIONAL AIR-CLEANING METHODS FOR
COMPLIANCE WITH ASBESTOS STANDARD
As an alternative to meeting the no-visible-emission requirement
of the proposed amendment to the asbestos standard, a source owner
or operator may fulfill the following requirements:*
(a) Fabric filter collection devices must be used, except
as noted in paragraphs (b) and (c) of this section. Such devices
must be operated at a pressure drop of no more than 10 cm (ca. 4 inches)
water gauge, as measured across the filter fabric. The airflow
permeability, as determined by ASTM method D737-69, must not
exceed 30 ft3/min/ft2 for woven fabrics or 35 ft3/min/ft2 for felted
fabrics, except that 40 ft3/min/ft2 for woven and 45 ft3/min/ft2
for felted fabrics is allowed for filtering air from asbestos ore
dryers. Each square meter of felted fabric must weigh at least
475 grams (ca. 14 ounces per square yard) and be at least 1.6 mm
(ca. one-sixteenth inch) thick throughout. Synthetic fabrics must
not contain fill yarn other than that which is spun.
(b) If the use of fabric filters creates a fire or explosion
hazard, the Administrator may authorize the use of wet collectors
designed to operate with a unit contacting energy of at least
102 cm (ca. 40 inches) water gauge pressure.
(c) The Administrator may authorize the use of filtering
equipment other than that described in paragraphs (a) and (b) of
*These requirements are quoted from §61.23 of the standards promulgated
April 6, 1973 (38 FR 8820).
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this section if the owner or operator demonstrates to the satisfaction
of the Administrator that the filtering of particulate asbestos
material is equivalent to that of the described equipment.
(d) All air-cleaning equipment authorized by this section
must be properly installed, used, operated, and maintained. Bypass
devices may be used only during upset or emergency conditions and
then only for so long as it takes to shut down the operation
generating the particulate asbestos material.
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APPENDIX B. CHEMICAL STABILIZATION OF WASTE
DISPOSAL SITES
More than 1 billion tons of mineral-processing waste are
produced annually in the United States. Approximately 40 percent
of this is fine-sized material, and stabilization measures must
be taken to prevent air and water pollution problems from arising.
The initial step is the planning of waste disposal operations to
ensure that the wastes are not haphazardly deposited in piles
with dangerously steep banks, which could increase runoff or
windblown emission problems. Although establishing a vegetation
cover might be the preferred stabilization method for aesthetic
considerations, it is often not practical because of the high
cost. As a recourse, a vegetative-chemical or chemical method
of stabilization must be considered.
Chemical stabilization of waste piles involves the reaction
of a reagent with the waste to form a crust or layer resistant to
air and water erosion. There is a wide variety of dust-suppression
agents with different base materials. The majority of the reagents
have a bituminous, resinous adhesive, or elastomeric polymer base.
Although chemical stabilizers are not as durable as vegetation,
they are more versatile. For example, chemicals can be used
in very dry regions, where there is not enough moisture to support
appropriate vegetative growth. The application method is usually
determined by the size and topography of the pile. The most common
application methods are spraying the waste pile with either a
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tank truck or an airplane. It may be possible to employ different
spraying techniques at smaller waste disposal sites. For instance,
hand sprayers or trucks equipped with a high-pressure hose can
be used to apply the chemical agent.
Chemical stabilizers, or dust-suppression agents, have been
used successfully to control windblown emissions in a wide variety
of applications. At a uranium tailings pile in Arizona, vegetative
procedures were investigated and determined to be unsuitable
because of the extremely low annual precipitationJ The use of
a soil or rock covering was considered to be too expensive.
In May 1968, U.S. Bureau of Mines personnel applied dust-suppression
agents to two portions of the uranium tailings pile. The chemicals
were applied with a self-propelled, lightweight sprinkling device
because only a few acres were stabilized. The sprinkling device
is mounted on two wheels and as the spraying arm rotates to
distribute the chemicals, the device moves along a predetermined
route. The treated sections of the disposal pile were inspected
each year, and in 1972 the inspection indicated that approximately
40 percent of the dike area that had been stabilized with an
elastomeric polymer showed disruption of the surface layer. The
primary reason for the disruption was determined to be physical
disturbance rather than weathering of the stabilizing agent.
Although this test may reflect an extended durability of the agent
due to the lack of appreciable rainfall, it does indicate that
chemical stabilizers are effective in reducing windblown emissions
from tailings piles. The second stabilizing agent used was
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calcium lignosulfonate, which was applied to the pond area.
The 1972 inspection showed that the crust was still intact and
unbroken.
Another example of chemical stabilization is the control
p
of emissions from a copper mill tailings pond. An emulsion
of petroleum and water was sprayed on the pond at a rate of 2.7
liters per square meter (ca. 0.6 gallon per square yard). This
treatment demonstrated effective dust control in winds up to
27 mps (ca. 60 mph). The installed cost at this particular
facility was approximately $0.044 per square meter (ca. $178
per acre). Other techniques that were tested and proved unsatis-
factory for this application were water sprays, snow fences,
and plowing of the site.
Chemical stabilizers have reportedly been used successfully
to control dust emissions in many other situations. Amusement
parks, airfields, construction areas, playgrounds, roads, and
schools are just a few of the other applications. Effective
application rates have been determined for many of the promising
O
agents, and U.S. Bureau of Mines personnel have been involved
in most of these tests. By performing rate screening tests,
various application rates can be studied. Chemical stabilizers
are applied to samples at different application rates. Each
sample can then be tested under controlled wind velocities and
the amount of wind erosion loss can be measured. Durability of
the chemical stabilizer can be,tested by exposing samples to
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various weather factors and measuring the amount of sample
lost by wind erosion.3 The percent of sample lost can be used
to indicate the effectiveness and life expectancy of the chemical
stabilizer. The installed cost of dust-suppression agents
varies from approximately $0.016 per square meter to $0.235 per square
meter (ca. $65 per acre to $950 per acre).
The effectiveness of dust-suppressing agents is governed by
a number of factors, for example, the homogeneity, permeability,
reactivity, pH, and salt content of the surface. These parameters
frequently exhibit a wide range of variation over the surface of
a waste disposal pile. Each type of waste should be tested
by the manufacturer of the dust-suppressing agent so that
these factors are considered in determining the application
rates. Some waste disposal piles may have steep slopes and
special techniques such as high pressure spraying or airplane
and helicopter application may have to be employed. Chemical
stabilization can remain effective for a period of several
years provided: (1) the site is properly prepared by considering
the previously mentioned factors, (2) prior compacting or grading
is performed where necessary, and (3) annual maintenance is
performed.
Two manufacturers of dust-suppression agents were contacted
by the Agency^'5 to obtain information on whether the agents would
cause water pollution problems. Although no tests have been
performed on runoff water from chemically stabilized waste piles,
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the toxicity of several chemical stabilizers has been determined.
The products of the two manufacturers contacted had been shown
to have a very low level of toxicity. Both manufacturers stated
that after the agent has cured in place, the agent's adhesive
bond to the soil particles is very strong as evidenced by the
durability and long life of the products. Ample time should be
.allowed for a chemical stabilizer to cure before rainfall to
avoid dissolving the agent in water runoff. No concrete evidence
is available to show that dust-suppression agents do not create
a water pollution problem, but the lack of reported complaints
and problems concerning the reagents over a period of approximately
10 years of use indicates that they do not cause significant
land or water pollution problems. If the agent should get into
a river or stream, the low erosion rate of the material indicates
that it would be so dilute that it would be very unlikely to
cause problems.
Additional sources of published information on chemical
stabilization are listed at the conclusion to this Appendix.
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REFERENCES
1. Dean, Karl Clyde, et al . , Methods and Costs for Stabilizing
Fi ne-Sized Mineral Wastes, U.S. Bureau of Mines, Washington,
" -
2. Dean, Karl C. and Richard Havens, Stabilizing Mineral Wastes,
U.S. Bureau of Mines, Washington, D.C., 1971.
3. Armburst, D.V., and J.S. Dickerson, "Temporary Wind Erosion
Control: Cost and Effectiveness of 34 Commercial Materials,"
J. Soil and Water Cons. 26_(4) : 154-156, 1971.
4. Canessa, William (Manager, Products Engineering, Witco
Chemical Corporation), letters to Archie Lee (EPA), July 1
and September 6, 1974.
5. Parks, C.F. (Dowel! Division of the Dow Chemical Company),
letter to Archie Lee (EPA), September 13, 1974, enclosing
"An Evaluation of Stabilization of Active Tailing Ponds
with Water-Swell able Polymers," prepared for the Environ-
mental Quality Conference for the Extractive Industries of
the American Institute of Mining, Metallurgical, and Petroleum
Engineers, Inc., Washington, D.C., June 7-9, 1971.
ADDITIONAL SOURCES OF INFORMATION
Dean, Karl C., Richard Havens, and Kimball T. Harper, Chemical
and Vegetative Stabilization of a Nevada Copper Porphyry Mill
Tailing, Bureau of Mines RI 7261, Washington, D.C., May 1969.
Havens, Richard, 'and Karl C. Dean, Chemical Stabilization of the
Uranium Tailings at Tuba City, Arizona, Bureau of Mines RI 7288,
Washington, D.C., August 1969.
James, A.L., "Stabilizing Mine Dumps with Vegetation," Endeavor
(London), 25.(96): 154-157, 1966.
Chepil, W.S., et al . , "Vegetative and Nonvegetative Materials To
Control Wind and Water Erosion," Soil Sci. Soc. An. Proc. 27_:
86-89, 1963.
Lyles, Leon, et al., "Spray-on Adhesives for Temporary Wind Erosion
Control," J. Soil and Water Cons. 25_(5): 190-193, 1969.
Investigation of Fugitive Dust, Volume I, Sources, Emissions, and
Control, Publication No. EPA-450/3-74-036-a, Environmental
Protection Agency, Office of Air and Waste Management, Research
Triangle Park, N. Carolina, June 1974.
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APPENDIX C. ESTIMATION OF ALLOWABLE MERCURY EMISSIONS
FROM SEWAGE SLUDGE INCINERATION FACILITIES
A hypothetical sewage sludge incineration facility was modeled
to estimate maximum allowable 30-day average mercury emissions.
The basic restriction on emissions is that the ambient 30-day
ground-level concentration of mercury (1.0 yg/m3) must not be ex-
ceeded. The source characteristics assumed for this analysis are
presented in Table C-l.
Table C-l. SOURCE CHARACTERISTICS OF A HYPOTHETICAL
SEWAGE SLUDGE INCINERATION FACILITY
Building Height 20m (ca. 65 ft)
Height of Roof-Mounted Stack 23m (ca. 75 ft)
Above Ground Level
Stack Gas Exit Speed 305 m/min (ca. 1000 ft/min)
Stack Gas Flow Rate 57 am^/min* (ca. 2000 acfm)
Stack Gas Temperature 32°C (90°F)
Sewage sludge incineration facilities are usually located
adjacent to a river, and some are located in pronounced valleys.
Thus, the dispersion modeling techniques and relatively restrictive
meteorological assumption of a 30-day average wind speed of 2 mps
and maximum wind direction frequency of 40 percent used in EPA
document APTD-0753 are applicable to the present analysis.
*am3/min = actual cubic meters per minute.
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The only difference between the present analysis and that
in APTD-0753 is in the assumed 30-day average "effective" stack
height (plume height). In APTD-0753 an effective stack height of
10 meters (equal to the height of the facilities modeled in that
document) was assumed. In the present analysis, however, a 20-
meter average effective stack height is assumed because of the
greater building height and physical stack height at sewage sludge
incineration facilities (see Table C-l). That assumption is based
on the fact that over a 30-day period the net effect of modest
plume rise during light winds and aerodynamic downwash of the ef-
fluent during stronger winds will be an effective stack height ap-
proximately equal to the building height.
Using the methodology and assumptions in APTD-0753 (with the
exception of effective stack height), Figure C-l was developed. Note
that curves are presented for two atmospheric Pasquill stability
classes. In general, as noted in APTD-0753, stability C curves ap-
ply when large buildings or other major obstructions to the wind
cause significant mechanical atmospheric turbulence, such as occurs
in major urban areas. In small communities and rural areas, the
curves for D stability may be more representative.
There is an important caveat cgncerning Figure C-l. Close
to the source, the indicated allowable emissions curve sharply
upward. However, the methodology used in developing those curves
does not consider one particular aspect of the downwash phenomenon,
viz., downwash of the plume to ground level immediately to the lee
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100
200
300 400 500
DISTANCE FROM SOURCE, meters
600
700
Figure C-"L Calculated maximum allowable mercury_emissions from a sewage sludge incinerator under
applicable Pasquill stability classes (C and D) ancfwlnd speed of 2 mps.
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of the building. Thus, emissions will be limited close to the
source, even though that is not indicated in Figure C-l. Since
the causative factors involved in such a phenomenon (climatology
and source characteristics) vary so widely from one source to an-
other, it is impossible to generalize as to how the facilities in
the present analysis would be affected.
Designers of sewage sludge incinerators should carefully
2345
observe good engineering practices ' ' ' to ensure that the
effluent is emitted in such a manner that the frequency with which
it is entrapped in eddies and wakes of the structure itself is
minimized.
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REFERENCES
1. Background Information—Proposed National Emission Standards
for Hazardous Air Pollutants: Asbestos, Beryllium, Mercury.
Publication No. APTD-0753, Environmental Protection Agency,
Office of Air Programs, Research Triangle Park, North Carolina,
December 1971.
2. Turner, D.B., Workbook of Atmospheric Dispersion Estimates,
Publication No. AP-26, Environmental Protection Agency, Office
of Air Programs, Research Triangle Park, North Carolina,
Revised 1970.
3. Briggs, G.A., Plume Rise, AEC Critical Review Series, U.S.
Atomic Energy Commission, Division of Technical Information,
Oak Ridge, Tennessee, 1969.
4. Smith, M.E., Recommended Guide for the Prediction of the
Dispersion of Airborne Effluents, American Society of Mechanical
Engineers, United Engineering Center, New York, New York, 1968.
5. Slade, D.H., Meteorology and Atomic Energy, U.S. Atomic Energy
Commission, Division of Technical Information, Oak Ridge,
Tennessee, 1968.
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APPENDIX D. SOURCES CONSULTED DURING STANDARDS DEVELOPMENT
I. Plants Visited
A. Asbestos
1. Manufacturers
a. Johns-Manville Products Corp., N. Billerica, Mass., 8/1/73
(Asbestos board)
b. Remington Arms Co., Bridgeport, Conn., 8/2/73
(Shotgun shell)
c. Nicolet Industries, Ambler, Pa., 8/29/73
(Textiles, asbestos board)
d. Certain-Teed Industries, Ambler, Pa., 8/29/73
(Asbestos-cement pipe)
e. Nicolet Industries, Norristown, Pa., 8/30/73
(Asbestos paper)
f. Certain-Teed Industries, Riverside, Ca., 9/19/73
(Asbestos-cement pipe)
g. Johns-Manville Plant, Manville, N. J., 10/29/73
(Various asbestos products)
h. Washington Asphalt Co., Seattle, Wash., 9/73
(Asphalt concrete)
i. During the course of previously developing new
source performance standards for asphalt concrete
plants, 64 asphalt concrete plants were visited.
Fabricators and Distributors
a. Bird & Son Roofing, Norwood, Mass., 8/1/73
(Fabricator of asbestos paper (felt))
b. P. S. Thorsen Co., Boston, Mass., 8/3/73
(Distributor of asbestos board)
c. Johnson Construction Specialties, Houston, Texas, 8/16/73
(Distributor of asbestos cement products)
d. Kaiser Aluminum, Chalmette, La., 8/17/73
(Fabricator of asbestos board into molten
metal flow control device)
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e. Thomas L. Green & Co., Indianapolis, Ind., 8/28/73
(Fabricator of asbestos board for ovens)
f. Hopeman Brothers, Waynesboro, Ma., 8/28/73
(Distributor of asbestos board for marine industry)
g. Long Beach Naval Shipyard, Long Beach, Ca., 9/17/73
(Asbestos insulation products)
h. E. J. Bartells, Renton, Wash., 9/24/73
(Distributor of asbestos products)
i. Pacific Car and Foundry, Renton, Wash., 9/73
(Fabricator of asbestos textiles)
j. Sun Shipbuilding and Dry Dock, Chester, Pa., 10/26/73
(Fabricator of asbestos board)
k. Bendix, Auto and Electronic Division, Newport News, Va.,
11/7/73
(Fabricator of asbestos friction products)
1. Wilson & Emerson Construction Co., Cary, N. C., 12/7/73
(User of asbestos-cement pipe)
m. Sears, K-Mart, and Rigsbee Tire Sales, Durham, N. C.,
12/7/73
(Brake shoe installers)
3. Demolition Sites
a. Chicago, 111., 225 E. 35th St., 3/26/74
b. Chicago, 111., 36th & Michigan, 3/26/74
c. Chicago, 111., 43rd & Calumet, 3/26/74
d. Chicago, 111., 63rd & Kenwood, 3/26/74
e. Chicago, 111., 63rd & Harper, 3/26/74
f. Chicago, 111., 63rd & Stony Island, 3/26/74
g. Chicago, 111., 69th & Stony Island, 3/26/74
h. Chicago, 111., Taylor & Canal St., 3/26/74
i. Chicago, 111., Morgan St. & Fulton Ave., 3/26/74
j. Chicago, 111., Orleans St., 3/26/74
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k. Chicago, 111., Orleans St. (boiler plant), 3/26/74
1. Chicago, 111., E. Ernie, 3/26/74
m. Several other buildings located in and around
Chicago area, 2/13/74
4. Waste Disposal Sites
a. Lancing, 111., 3/26/73
(General landfill)
b. Nicolet Industries, Ambler, Pa., 8/30/73
(Asbestos waste disposal site)
c. Certain-Teed Industries, Ambler, Pa., 8/30/73
(Asbestos waste disposal site)
5. Asbestos Mill Tailings Piles
a. GAP Corp., Hyde Park, Vt., 9/10/73
b. Pacific Asbestos Co., Copperopolis, Ca., 3/26/74
c. Coalinga Asbestos Co., Coalinga, Ca., 3/27/74
d. Atlas Asbestos Co., Coalinga, Ca., 3/27/74
e. Calidria Asbestos Co., King City, Ca., 3/28/74
B. Mercury
1. Municipal Sewage Treatment Plants
a. N. W. Bergen Co., Waldwick, N. J., 11/12/73
b. Piscataway, Piscataway, Md., 2/27/74
c. Joint Meeting, Elizabeth, N. J., 11/13/73
d. Bergen County, Little Ferry, N. J., 11/13/73
e. Greensboro, N. C., 12/7/73
f. Pittsburgh, Pa., 12/73
g. Hartford, Conn., 12/73
h. New Haven, Conn., 12/73
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i. Detroit, Mich., 12/73
j. Chicago, 111., 12/73
k. Indianapolis, Ind., 12/73
II. Tests Conducted
A. Asbestos
1. Ambient Asbestos Samples
a. GAP Corp., Hyde Park, Vt., 10/9/73
(Asbestos tailings disposal site)
b. Nicolet Industries, Ambler, Pa., 10/16/73
(Asbestos waste disposal)
c. Certain-Teed Industries, Ambler, Pa., 10/16/73
(Asbestos waste disposal)
2. Asbestos Material Samples
a. GAP Corp., Hyde Park, Vt., 10/9/73
(Asbestos tailings disposal site)
b. Nicolet Industries, Ambler, Pa., 10/16/73
(Asbestos waste disposal site)
c. Certain-Teed Industries, Ambler, Pa., 10/16/73
(Asbestos waste disposal site)
B. Mercury
1. Municipal Sewage Treatment Plants
a. Stack tests
(i) N. W. Bergen Co., Waldwick, N. J., 11/12/73
(ii) Piscataway, Piscataway, Md., 2/27/74
b. Sludge Samples & Analysis
(i) N. W. Bergen Co., Waldwick, N. J., 11/12/73
(ii) Joint Meeting, Elizabeth, N. J., 11/13/73
(iii) Bergen County, Little Ferry, N. J., 11/13/73
(iv) Greensboro, N. C., 12/7/73
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(v) Pittsburgh, Pa., 12/73
(vi) Hartford, Conn., 12/73
(vii) New Haven, Conn., 12/73
(viii) Detroit, Mich., 12/73
(ix) Chicago, 111., 12/73
(x) Indianapolis, Ind., 12/73
III. Meetings
A. Asbestos
1. EPA/Department of Justice/Environmental Defense Fund, 7/9/73
2. EPA/National Association of Demolition Contractors, 9/24/73
3. EPA/National Association of Demolition Contractors, 11/16/73
4. EPA/National Association of Demolition Contractors, 2/11/74
5. EPA/Environmental Defense Fund/Department of Justice, 2/26/74
6. EPA/National Association of Demolition Contractors, 4/17/74
7. EPA/Asbestos Information Association of North America, 3/1/74
8. EPA/National Air Pollution Control Techniques Advisory
Committee, Chicago, 111., 5/22/74
9. EPA Working Group on NESHAP, 5/29/74
B. Mercury
1. EPA/National Air Pollution Control Techniques Advisory
Committee, Chicago, 111., 5/22/74
2. EPA Working Group on NESHAP, 5/29/74
3. EPA/Envirotech, 6/21/74
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing}
1. REPORT NO.
EPA-450/2-74-009
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Background Information on National Emission Standards
for Hazardous Air Pollutants, Proposed Amendments to
Standards for Asbestos and Mercury
5. REPORT DATE
October 1974
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Amendments have been proposed for the national emission standards for asbestos
and mercury that were promulgated April 6, 1973. This document presents the
rationale for these amendments and an evaluation of their economic and environ-
mental impacts.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
cos AT I Field/Group
Asbestos
Mercury
Hazardous pollutants
.Waste disposal
Sludge incinerators
Fabrication
Insulation
Renovation
Demolition
Air pollution
Pollution control
Air pollution
Pollution control
3. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)'
Unclassified
21. NO. OF PAGES
140
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (3-73)
142
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