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
                            vii

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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.
                         20

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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
                               21

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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

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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.

                               25

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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.
                             29

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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.
                                30

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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
                               31

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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.
                                33

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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.
                               34

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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

                            35

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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.
                                39

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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.
                               41

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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.
                             43

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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

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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.

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     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

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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

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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

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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

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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

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 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

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 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.

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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

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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

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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

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  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

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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

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  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

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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

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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

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                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

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         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

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      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

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                   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

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     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

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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

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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

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        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

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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

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     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

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     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

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      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.
                                 85

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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

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                    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

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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

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    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.

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     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.
                                102

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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.
                                105

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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.
                                106

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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.

                              107

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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
                               109

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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.
                                110

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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
                                 111

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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
                       112

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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.
                             113

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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
                    138

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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
                             140

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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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