oEPA
United
Environmental Protection
Agency
Office of
Toxic Substances
Washington D.C.
EPA 560/5-88-007
March 1990
Office of Toxic Substances
ASBESTOS CONTAINING THERMAL
SYSTEM INSULATION: FACTS AND
FIGURES
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EPA 560/5-88-007
March, 1990
FINAL REPORT
ASBESTOS-CONTAINING THERMAL SYSTEM INSULATION:
FACTS AND FIGURES
Prepared by:
Chesson Consulting, Inc.
1717 Massachusetts Ave., N.W.
Washington, DC 20036
Battelle
Arlington Office
2101 Wilson Boulevard, Suite 800
Arlington, VA 22201
Contract No. 68-02-4294
for the:
Exposure Evaluation Division
Office of Toxic Substances
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
Washington, DC 20460
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This document has been reviewed and approved for publication by
the Office Of Toxic Substances, Office of Pesticides and Toxic
Substances, U.S. Environmental Protection Agency. The use of
trade names or commercial products does not constitute Agency
endorsement or recommendation for use.
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AUTHORS AND CONTRIBUTORS
This report was prepared by Jean Chesson of Chesson Consulting,
Inc. under contract to Battelle. Amy Doll and David Lawrence of
Chesson Consulting prepared the illustrations. Mark Wright,
under contract to Battelle, designed the cover.
The EPA Work Assignment Manager was Bradley Schultz. Substantial
contributions were also made by Cindy Stroup, Betsy Dutrow, and
Joe Breen of the Exposure Evaluation Division in the EPA Office
of Toxic Substances.
ACKNOWLEDGMENTS
Al Unger and Barbara Leczynski, the Battelle Project Managers,
and Edie Sterrett and Mary Frankenberry, the EPA Project
Officers, provided managerial and administrative support.
Discussions with John Rogers of Westat, Inc. were invaluable in
interpreting the EPA survey data.
iii
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TABLE OF CONTENTS
SUMMARY Vll
1. INTRODUCTION 1
1.1 DESCRIPTION OF ASBESTOS-CONTAINING THERMAL SYSTEM
INSULATION 1
1.2 FEDERAL REGULATORY PROGRAMS 2
2. CHARACTERISTICS OF ASBESTOS-CONTAINING
THERMAL SYSTEM INSULATION 3
2.1 PREVALENCE 3
Building Type 5
Building Age 7
Building Height 7
Geographical Region 8
2.2 ASBESTOS CONTENT 8
2.3 CONDITION 10
Building Type 10
Building Age 10
Building Height 11
2.4 LOCATION 15
2.5 AIRBORNE ASBESTOS LEVELS 16
3. MANAGING ASBESTOS-CONTAINING THERMAL SYSTEM INSULATION 21
3.1 DETERMINING IF ASBESTOS-CONTAINING MATERIAL IS
PRESENT IN A BUILDING 21
3.2 ESTABLISHING AN OPERATIONS AND MAINTENANCE
PROGRAM 22
3.3 ASSESSING THE NEED FOR FURTHER ACTION 22
3.4 IMPLEMENTING RESPONSE ACTIONS 22
REFERENCES 25
APPENDIX A. EPA REGIONAL ASBESTOS COORDINATORS 29
APPENDIX B. SOURCES OF ADDITIONAL INFORMATION 33
IV
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LIST OF FIGURES
Figure 1. The estimated number of buildings (in thousands) with
asbestos-containing materials 4
Figure 2. The relationship between type of building and type of
ACM; a) estimated number of buildings, b) estimated percent of
buildings, c) estimated total floor area 6
Figure 3. The relationship between building construction date
and presence of asbestos-containing material 7
Figure 4. The relationship between building height and type of
ACM; a) estimated number of buildings, b) estimated percent of
buildings, c) estimated total floor area 9
Figure 5. The number of buildings (in thousands) that have no
asbestos-containing TSI, TSI with no damage, TSI with some
moderate damage only, and TSI with some significant damage. 11
Figure 6. The relationship between type of building and
condition of asbestos-containing TSI; a) estimated number of
buildings in each condition category, b) estimated percent of
buildings, c) estimated total floor area 12
Figure 7. The relationship between building construction date
and condition of asbestos-containing TSI; a) estimated number of
buildings in each condition category, b) estimated percent of
buildings, c) estimated total floor area 13
Figure 8. The relationship between building height and condition
of asbestos-containing TSI; a) estimated number of buildings in
each condition category, b) estimated percent of buildings, c)
estimated total floor area 14
Figure 9. The estimated number of buildings (in thousands) with
asbestos-containing material in fan and boiler rooms and in
public areas 16
Figure 10. In EPA's study of public buildings (USEPA 1988),
average airborne asbestos levels in 15 buildings with only TSI
followed a similar trend to that observed in all 49 buildings. 18
VI
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SUMMARY
Thermal system insulation (TSI) is material applied to
pipes, boilers, tanks, ducts, etc. to prevent heat loss, heat
gain, or water condensation. TSI that contains asbestos
represents a potential health hazard to custodial and maintenance
personnel working with and around the material. However,
compared to other types of building materials that contain
asbestos, TSI is often easier to repair, encapsulate, enclose, or
remove. This document provides information on the
characteristics of asbestos-containing TSI and lists resources
available to individuals who are responsible for making asbestos
management decisions.
The purpose of this report is to draw attention to
asbestos-containing TSI without diminishing the importance of
other types of asbestos-containing material. Information on the
characteristics of asbestos-containing TSI is provided. Research
on asbestos and guidance on its management have tended to
emphasize surfacing material at the expense of TSI. While each
building must be individually and thoroughly inspected for all
types of asbestos-containing materials by a qualified building
inspector, the information contained in this report will help
building owners and managers, especially those responsible for
large numbers of buildings, anticipate possible outcomes and plan
appropriate actions. Although this document is not an
instruction manual for inspecting buildings for asbestos-
containing material, or for the management or specific abatement
of these materials, a brief overview is provided to help readers
identify sources of additional information.
In 1984, the U.S. Environmental Protection Agency
conducted a national survey to determine how many buildings
contain asbestos (USEPA 1984). The survey found that of the
approximately 3.6 million buildings represented in the survey,
about 733,000 contain some type of asbestos material. The most
common forms of asbestos-containing material are thermal system
insulation as described above, and sprayed- or trowelled-on
surfacing material. Of the 733,000 buildings estimated to
contain asbestos, most (about 563,000) have asbestos-containing
TSI. Many fewer (about 192,000 buildings) have asbestos-
containing surfacing material. (A small number of buildings have
both asbestos-containing TSI and surfacing material.)
The EPA Survey showed that TSI is more likely to be
present in some types of building than in others. Of the
building categories covered by the survey, residential apartment
buildings, buildings built prior to 1944, and buildings of 8
floors or njpre are most likely to have asbestos-containing TSI.
This does not mean, of course, that all buildings in these
categories have asbestos-containing TSI.
vii
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Asbestos fibers are believed to be released from TSI
through disturbance of the material. Visible damage indicates
that disturbance has occurred. The EPA Survey found that over
half the buildings with asbestos-containing TSI have some
significantly damaged TSI and 80 percent have at least some
damaged TSI. TSI is more likely to be damaged in commercial non-
residential buildings, in buildings constructed prior to 1944,
and in buildings of 8 floors or more.
Although TSI is typically associated with restricted
areas such as fan and boiler rooms, a substantial number of
buildings (at least 262,000) have asbestos-containing TSI in
public areas. For instance, a pipe wrapped with asbestos-
containing TSI may run through office space. Limited information
indicates that elevated airborne asbestos concentrations can
occur during disturbance of the material.
Results from a recent study of asbestos in New York
City are in general agreement with the EPA findings (NYCDEP
1988). Overall, asbestos-containing TSI is more prevalent than
asbestos-containing surfacing material, and more of the TSI is in
poor condition. However, surfacing material is more prevalent in
some types of New York City buildings, especially tall office
buildings, hospitals, and theaters and places of public assembly.
Since asbestos is restricted to TSI in many buildings,
the majority of asbestos control programs will not have to
address asbestos-containing surfacing material. TSI is generally
easier and less costly to repair, remove or replace. EPA
recommends that building owners and managers obtain proper
training for their staff or hire specialists to inspect their
buildings and develop asbestos management plans. (Under the
Asbestos Hazard Emergency Response Act of 1986, this is mandatory
for schools.) A building owner or manager's approach to
controlling asbestos-containing material will generally involve
four basic steps. First, determine if asbestos-containing
material is present. Second, establish a special operations and
maintenance plan. Third, assess the need for further action.
Finally, take further action as appropriate. Documents produced
by EPA and other organizations provide guidance on implementing
each step.
Vlll
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IX
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1. INTRODUCTION
Thermal system insulation (TSI) is material .applied to
pipes, boilers, tanks, ducts, etc. to prevent heat loss, heat
gain, or water condensation. Asbestos-containing TSI represents
a potential health hazard, particularly to custodial and
maintenance personnel working with and around the material. In
February 1988, in response to the findings of a study mandated
by the 1986 Asbestos Hazard Emergency Response Act (AHERA), the
Administrator of the U.S. Environmental Protection Agency (EPA)
recommended that attention be focused on asbestos-containing TSI.
This recommendation was made because much is known about the
identification and control of asbestos-containing TSI and,
compared to other types of asbestos materials, TSI is often
easier to repair, encapsulate, enclose or remove.
This document provides information on the
characteristics of asbestos-containing TSI and lists resources
available to individuals responsible for making asbestos
management decisions. This document is not an instruction manual
for inspecting buildings for asbestos-containing TSI, or for the
management or specific abatement of these materials. EPA
recommends that building owners and managers obtain proper
training for their staff or hire specialists to inspect their
buildings and develop asbestos management plans. (Under AHERA
this is mandatory for schools.) Appendix A contains a list of
the EPA Regional Asbestos Coordinators who may be contacted for
information on approved training courses and other asbestos
related matters. Additional reference sources are given in
Appendix B.
1.1 DESCRIPTION OF ASBESTOS-CONTAINING THERMAL SYSTEM INSULATION
Asbestos-containing TSI is typically found on equipment
containing hot or cold air or liquid — pipes, boilers, chillers,
tanks, and sometimes ducts. The insulation may be a chalky
mixture of magnesia and asbestos, preformed fibrous asbestos
wrapping, asbestos fiber felt, corrugated paper, or insulating
cement, and is usually covered with a protective jacket of cloth,
tape, paper, metal, or cement. Boiler insulation may consist of
thermal bricks (refractory) or asbestos insulating blankets, and
is usually covered with finishing cement. Occasionally, asbestos
millboard is used as a stiff outside covering on removable boiler
insulation.
The data described in this report refer to asbestos-containing
TSI located within buildings. Asbestos-containing TSI may also
IMEPA Study of Asbestos-Containing Materials in Public
Buildings: A Report to Congress." U.S. Environmental Protection
Agency, Washington, D.C. February, 1988.
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be found on utility systems serving groups of buildings and in
many industrial settings.
1.2 FEDERAL REGULATORY PROGRAMS
Federal regulations pertaining to asbestos-containing
TSI include EPA's National Emission Standards for Hazardous Air
Pollutants (NESHAP)(40 CFR 61, Subpart M), the Friable Asbestos-
Containing Materials in Schools; Identification and Notification
Rule (47 FR 23360, May 27, 1982; 40 CFR Part 763), and the
Asbestos-Containing Materials in Schools; Final Rule and Notice
(52 FR 41826, October 30, 1987; 40 CFR Part 763) promulgated
under the Asbestos Hazard Emergency Response Act (AHERA). The
Occupational Safety and Health Administration (OSHA) regulates
occupational exposure to asbestos (51 FR 22612, June 20, 1986 and
53 FR 35610, September 14, 1988; 29 CFR Parts 1910 and 1926).
In 1975, NESHAP restricted the installation or
reinstallation of friable asbestos-containing TSI (40 FR 48292,
October 12, 1975). (Friable material is material that can be
crumbled, pulverized, or reduced to powder by hand pressure.)
NESHAP also specifies standards for demolition or renovation
involving at least 260 linear feet or 160 square feet of friable
asbestos materials.
The 1982 Identification and Notification Rule required
local educational agencies to inspect all school buildings for
friable materials (including TSI) applied to structural surfaces;
sample and analyze for asbestos or treat the material as
asbestos-containing; and inform employees and parent-teacher
groups. Under the AHERA rule, inspection is extended to non-
friable materials and must be performed by an accredited
inspector. If asbestos-containing materials are identified, the
local educational agency must implement an operations,
maintenance, and repair (O&M) program and submit a management
plan to the State Governor. Although AHERA applies only to
schools, some private building owners and managers are using the
regulation as a basis for their asbestos management programs.
The OSHA rules establish a permissible exposure limit
(PEL) of 0.2 fibers/cm3 as an eight hour time-weighted average
and an excursion limit of 1.0 fibers/cm3 as a 30 minute time-
weighted average measured by phase contrast microscopy (PCM).
Exposures at or above the action level of 0.1 fibers/cm3 trigger
various monitoring and medical surveillance requirements.
Through the EPA worker protection rule (40 CFR Part 763, Subpart
G) and the AHERA rule, OSHA provisions are extended to asbestos
abatement workers employed by State and local government
employees and operations and maintenance workers employed by
local educational agencies.
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2. CHARACTERISTICS OF ASBESTOS-CONTAINING
THERMAL SYSTEM INSULATION
Information on asbestos-containing TSI in public and
commercial buildings is available from a 1984 national survey
(USEPA 1984a). The target population consisted of Federal
government buildings, rental apartment buildings with 10 or more
dwelling units, and privately-owned buildings used primarily for
non-residential purposes. A total of 231 buildings were
inspected for surfacing materials (sprayed- or trowelled-on
friable material), TSI (pipe and boiler insulation), and ceiling
tile. Additional information collected during the survey, but
not included in the study report, is reported in Rogers (1988) .
The survey provides national estimates with a known degree of
accuracy. Only the estimates are discussed here, since the
objective is to illustrate general trends rather than emphasize
numerical values. Note, however that the estimates are not
precise and small differences between them are not significant.
Readers should consult the original reports for a measure of the
uncertainty associated with each estimate.
2.1 PREVALENCE
The 1984 national survey provides three measures of
prevalence with respect to asbestos-containing TSI: the number of
buildings with asbestos-containing TSI; the percentage of
buildings with asbestos-containing TSI; and the total floor area
of buildings with asbestos-containing TSI. The amount of
asbestos-containing TSI (e.g., linear or square feet) was not
measured in the survey. Therefore, buildings with a small amount
of asbestos-containing TSI are given the same weight as buildings
in which asbestos-containing TSI is present throughout the
building.
All three measures of prevalence — number of
buildings, percent, and total floor area — provide useful
information on asbestos-containing TSI. The number of buildings
with asbestos-containing TSI indicates the magnitude of the
problem in terms of the organizational effort involved. The
percentage of buildings in different categories (e.g.,
residential versus commercial) with asbestos-containing TSI may
be used to determine the most efficient use of limited resources.
For example, if two building categories contain the same number
of buildings, but the percentage of buildings with asbestos-
containing TSI in the first category is greater than the
percentage in the second category, inspection restricted to
buildings in the first category will identify a greater number of
buildings with asbestos-containing TSI per dollar spent, than the
same inspection applied to all buildings. The total floor area
of buildings with asbestos-containing TSI provides a rough
measure of the number of people potentially exposed, and,
possibly, the amount of asbestos-containing material present.
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Buildings with asbestos-containing TSI account for the
majority of public and commercial buildings with asbestos-
containing material (Figure 1) . Of the estimated 733,000
buildings with friable asbestos-containing material'; 192,000 have
asbestos-containing surfacing material and 563,000 have asbestos-
containing TSI. These results imply that only about 22,000
buildings have both asbestos-containing TSI and asbestos-
containing surfacing material. (Asbestos-containing ceiling
tile, which is too rare to significantly affect the estimates,' is
ignored.) Thus, the majority of buildings with asbestos-
containing TSI. could implement a management program for TSI
immediately with little chance of having to extend5'it later to
include surfacing-material.
xjxjx Surfacing Only (170)
TSI & Surfacing (22)
TSI Only (541)
No ACM (2,873)
Figure 1. The estimated number of buildings (in thousands)
with asbestos-containing materials.
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The corresponding estimated percentages are: 15
percent of all buildings have only asbestos-containing TSI; 1
percent have both asbestos-containing TSI and asbestos-containing
surfacing material; and 4 percent have only asbestos-containing
surfacing material. Buildings with only asbestos-containing TSI
have an estimated total floor area of 13 billion square feet;
buildings with both asbestos-containing TSI and asbestos-
containing surfacing material have an estimated total floor area
of 3.8 billion square feet; and buildings with only asbestos-
containing surfacing material have an estimated total floor area
of 1.8 billion square feet.
Asbestos-containing TSI is also the dominant form of
asbestos-containing material in schools. A national telephone
survey (USEPA 1984b) estimated that 71 percent of local
educational authorities have one or more schools with asbestos-
containing TSI, and 45 percent have only asbestos-containing TSI.
On-site inspections of a subset of the schools indicated that
these percentages may be underestimated. Some schools did not
realize that they were required to inspect TSI.
The City of New York Department of Environmental
Protection has recently completed a survey of New York City
buildings grouped into 18 categories according to use (NYCDEP
1988). TSI is present in an estimated 68 percent of the
buildings. Overall, fewer than 0.5 percent have asbestos-
containing surfacing material. However, surfacing material is
more prevalent in certain types of buildings. For example, 28
percent of tall office buildings, 15 percent of hospitals, and 12
percent of theaters and places of public assembly have asbestos-
containing surfacing material.
The sections below show how the incidence of asbestos-
containing TSI depends on building type, building age, and
building height.
Building Type. Figure 2a shows that the largest number
of buildings with asbestos-containing TSI are commercial, non-
residential buildings, followed by residential buildings of 10
units or more, and federal buildings. However, since commercial,
non-residential buildings are by far the most numerous of the
three types of building, the percentage of commercial, non-
residential buildings with asbestos-containing TSI is low
compared to federal and residential buildings (Figure 2b). Floor
area of buildings with asbestos-containing TSI follows a similar
pattern to number of buildings (Figure 2c).
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(a) Number of Buddings (1.000's)
800 '
600 -
400 -
200 -
ComrnwrcW Al
Type of Building
(b) Percent of Buildings
100
Fodsrsl RwtoertW' Cormrwrciai Al
Type of Building
(c) Floor area
(Billions of square feet)
10 -
5 -
CommcrcW Al
Type of Building
Surfacing only:
TSI & Surfacing
TSI only
| | Surfacing only
| j TSI & Surfacing
Fd TSI only
| | Surfacing only
fcff:l TSI & Surfacing
MM TSI only
Figure 2. The relationship between type of building and type of
ACM; a) estimated number of buildings; b) estimated percent of
buildings; c) estimated total floor area.
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eo
CO
o>
TJ
'5
"5
o>
|
Z
400
300
200
100
Up to 1944 1945-1959 1960-1969 1970-1978
Construction Date
Figure 3. The relationship between building construction date
and presence of asbestos-containing material.
Building Age. The majority of buildings with asbestos-
containing thermal system insulation were constructed prior to
1944 (Figure 3). The use of asbestos-containing TSI declined
during the 1950's and 60's. NESHAP further limited its use in
the mid 1970's. In contrast, use of surfacing asbestos-
containing material peaked in the 1960's. The total numbers of
buildings in each age category are roughly equal, thus the
percentage of buildings with asbestos-containing TSI as a
function of age follows the same pattern as the number of
buildings with asbestos-containing TSI.
Building Height. Buildings with three to seven floors
represent the greatest number of buildings with asbestos-
containing thermal system insulation (Figure 4a). Compared to
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shorter buildings (1-2 floors), few of these buildings contain
surfacing material. Figure 4b shows that although buildings of 8
floors or more are rare relative to shorter buildings, almost 100
percent of these tall buildings contain asbestos-containing TSI,
and an estimated 40 percent contain both asbestos-containing
surfacing material and asbestos-containing TSI. Due to their
size, the estimated floor area of buildings of 8 floors or more
with asbestos-containing TSI (5.3 billion square feet) represents
a significant proportion of the total estimated floor area of
buildings with asbestos-containing TSI (16.8 billion square
feet).
Geographical Region. Although the 1984 national survey
was not designed to provide estimates by region, some qualitative
trends were observed. Buildings in the east and midwest are more
likely to have central heating and hence TSI. Buildings in the
west, southwest, and southeast are less likely to have central
heating except in larger buildings.
2.2 ASBESTOS CONTENT
Asbestos-containing TSI has a higher estimated asbestos
content (70 percent) than surfacing material (14 percent) or
ceiling tile (3 percent). However, since asbestos-containing TSI
is generally protected by a non-asbestos cover or wrap, the
higher asbestos content does not necessarily imply a higher
exposure, particularly if the material remains undisturbed.
8
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(a) Number of BuNdlnga (1,000's)
400
300 -
1-2 3-7 8 or more
Height of Building (floors)
(b) Percent of Buildings
100
80
GO
40
20
(c) Floor area
(Billions of square feet)
B
1-2 3-7 8 or more
Height of Building (floors)
1-2 3-7 8 or more
Height of Building (floors)
| | Surfacing only
EH TSI & Surfacing
TSIonly
I | Surfacing only
HI TSI & Surfacing
TSI only
| | Surfacing only
["I TSI & Surfacing
n TSIonly
Figure 4. The relationship between building height and type of
ACM; a) estimated number of buildings; b) estimated percent of
buildings; c) estimated total floor area.
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2.3 CONDITION
Each area of TSI in the 1984 national survey was
classified into one of three categories: good condition, moderate
damage, and significant damage (Rogers 1988). An estimated
453,000 buildings have at least some damaged asbestos-containing
TSI and an estimated 317,000 buildings have at least some
significantly damaged asbestos-containing TSI (Figure 5). These
numbers correspond to 13 percent and 9 percent of all buildings,
respectively. Note that, since the amount of TSI was not
measured, the amount of damaged asbestos-containing TSI within a
building is not necessarily large. Nevertheless, the estimates
indicate that some action, such as repair, might be appropriate
in a majority of buildings with asbestos-containing TSI.
The City of New York Department of Environmental
Protection reached a similar conclusion based on the results of
its survey (NYCDEP 1988). Overall, 19 percent of TSI is in poor
condition, and another 68 percent is in fair condition. The city
has introduced legislation requiring inspection for asbestos-
containing materials (both TSI and surfacing) for all buildings
and, when asbestos is found, an operation and maintenance
program, management plan and response actions.
The sections below indicate how condition of asbestos-
containing TSI identified in the EPA national survey is related
to building type and building height.
Building Type. Commercial, non-residential buildings
constitute the majority of buildings with at least some damaged
asbestos-containing TSI and the majority of these contain at
least some significantly damaged asbestos-containing TSI (Figure
6a). Despite the smaller percentage of commercial, non-
residential buildings with asbestos relative to federal or
residential buildings, the percentage of commercial, non-
residential buildings with at least some significant damage is
greater than in either of the other two building types (Figure
6b). This suggests that although asbestos-containing thermal
system insulation is less common in commercial, non-residential
buildings, it is more likely to be damaged when it is present.
The floor area of buildings in the three condition categories
follows a similar pattern to the number of buildings (Figure 6c).
Building Age.2 The older the building, the more likely
it is to contain damaged asbestos-containing TSI (Figure 7).
Buildings constructed prior to 1944 account for the majority of
buildings with at least some significant damage.
Information on building age was obtained from a memo
written by John Rogers, Westat to Joan Blake and Cindy Stroup,
EPA dated March 9, 1987.
10
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No damage (110)
/// Some moderate
Some significant
damage (317)
No asbestos-containing
TSI (3,043)
Figure 5. The number of buildings (in thousands) that have no
asbestos-containing TSI, TST with no damage, TSI with some
moderate damage only; and TSI with some significant damage.
Building Height. The results for buildings of 8 floors
or more should be interpreted cautiously because they are based
on inspection of a small number of buildings. The number of
buildings that have at least some significantly damaged asbestos-
containing TSI appears to be greatest for buildings of 3 to 7
floors (209,000), and least for buildings 8 floors or more
(2,000) (Figure 8a). Although only a small percentage of
buildings of 8 floors or more have significantly damaged
asbestos-containing material, an estimated 78 percent have at
least some damaged material (Figure 8b). The floor area
represented by buildings in each of the three condition
classifications is roughly comparable across building height
(Figure 8c).
11
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(a) Number of Buildings (1,000's)
600
500
400
300
200
100
| | good condition
[::::::::::::| moderate damage
significant damage
F«d«r* Fta&tenW ComnwreW
Type of Building
(b) Percent of Buildings
100
80
60
40
20
RMfcfenW Commwtd*
(c) ROOT area Type of Building
(Billions of square feet)
20
| | good condition
[vXvX] moderate damage
significant damage
15
10
| | good condition
[^J moderate damage
E3 significant damage
Comrrwo*
Type of Building
Figure 6. The relationship between type of building and
condition of asbestos-containing TSI; a) estimated number of
buildings in each condition category, b) estimated percent of
buildings, c) estimated total floor area.
12
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(a) Number of Buildings (1,000's)
400
300
200
100
| | good condition
[XvXvj moderate damage
significant damage
Up to 1944 1945-1958 1080-1908 1870-1879
Construction Date
(b) Percent of Buildings
100
80
60
40
20
| | good condition
|: | moderate damage
fc: "j significant damage
(c) Floor area
(Billions of square feet)
10
Up to 1944 1945-1959 1980-1989 1970-1979
Construction Date
| | good condition
P:-:-Xv| moderate damage
significant damage
Up to 1944 1945-1858 1800-1969 1970-1879
Construction Date
Figure 7. The relationship between building construction date
and condition of asbestos-containing TSI; a) estimated number of
buildings in each condition category, b) estimated percent of
buildings, c) estimated total floor area.
13
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(a) Number at BufcNngs (1,000's)
400
300 -
200 -
100 -
| | good condition
' t::::::::::l moderate damage
significant damage
1-2 - 3-7 8 or more
Height of Building (floors)
(b) Percent of Buildings
100
| | good condition
|::::::>::::] moderate damage
significant damage
1-2 3-7 8 or more
(c) Floor area Height of Building (floors)
(Billions of square feet)
8
^.-
--»-«*-• !•:;•:•
good condition
moderate damage
significant damage
1-2 3-7 8 or more
Height of Building (floors)
Figure 8. The relationship between building height and condition
of asbestos-containing TSI; a) estimated number of buildings in
each condition category, b) estimated percent of buildings, c)
estimated total floor area.
14
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2.4 LOCATION
The 1984 national survey recorded the location of
asbestos-containing materials (surfacing, TSI, and ceiling tile)
as either in fan and boiler rooms or in public areas. A separate
analysis of the location of asbestos-containing TSI has not been
performed. Nevertheless, some inferences can be made from the
aggregated data. An estimated 462,000 buildings have asbestos-
containing material in fan and boiler rooms (Figure 9) and this
material is almost entirely TSI (J. Rogers, personal
communication). At least an estimated 262,000 buildings have
asbestos-containing TSI in public areas. (Some buildings have
asbestos-containing TSI in both fan and boiler rooms and in
public areas.) These results indicate that although asbestos-
containing TSI is typically associated with restricted areas such
as fan and boiler rooms, and the greatest amount of material is
probably located there, a substantial number of buildings have at
least some asbestos-containing TSI in public areas.
An estimated 360,000 buildings have some damaged
asbestos-containing TSI in fan and boiler rooms, and an estimated
282,000 have some significantly damaged asbestos-containing TSI
in fan and boiler rooms. At least 217,000 buildings have some
damaged asbestos-containing TSI in public areas, and at least
85,000 buildings have some significantly damaged asbestos-
containing TSI in public areas.
The location of asbestos-containing material in general
(surfacing, TSI, and ceiling tile) is related to building
height. Since asbestos-containing thermal system insulation is
the most prevalent type of asbestos-containing material, the
location of asbestos-containing TSI is likely to have a similar
relationship with building height. Buildings with 1 or 2 floors
are more likely to have asbestos-containing material only in
public areas. (These buildings account for most of the surfacing
material.) Buildings of 3 to 7 floors are more likely to have
asbestos-containing material restricted to fan and boiler rooms,
and buildings of 8 floors or more tend to have ACM in both public
areas and fan and boiler rooms.
The New York City survey (NYCDEP 1988) does provide
location information specifically for TSI. To the extent that
New York City buildings are representative of buildings in other
parts of the U.S., the data may provide additional insight into
where asbestos-containing TSI is likely to be found in buildings.
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m-:-\ Public Only (271)
F&BRoom&Public(183)
F&B Room Only (279)
No ACM (2,873)
Figure 9. The estimated number of buildings (in thousands)
with asbestos-containing material in fan and boiler rooms and
in public areas.
2.5 AIRBORNE ASBESTOS LEVELS
Research on_exposure to airborne asbestos in buildings
has focused on surfacing material (e.g., USEPA 1980, 1983, ,1985a,
1986, Tuckfield et al 1988). Consequently, information on
ambient airborne asbestos levels in buildings with asbestos-
containing TSI is restricted to two studies - a recent EPA study
(USEPA 1988) and Burdett and Jaffrey (1986). Neither study was
designed specifically to investigate TSI.
The EPA study measured airborne asbestos levels in 49
buildings in the United States using transmission electron
microscopy (TEN) and a direct transfer sample preparation
technique. The buildings, which were selected according to the
presence and condition of the asbestos-containing material,
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consisted of six buildings with no asbestos-containing material
(Category 1), six buildings with asbestos-containing material in
generally good condition (Category 2) , and 37 buildings with some
damaged material (Category 3). Forty of the buildings contained
asbestos-containing TSI and 15 contained only asbestos-containing
TSI. Although airborne asbestos levels were low in absolute
magnitude across all building categories, there is an increasing
trend in average airborne asbestos levels. Outdoor measurements
are lowest followed by building categories 1, 2 and 3 . Figure
10 shows that in this study, buildings with only asbestos-
containing TSI followed the same trend.
Burdett and Jaffrey (1986) included 24 buildings with
warm air heaters containing asbestos in a study of airborne
asbestos levels in 43 buildings in the United Kingdom. Samples
were analyzed by TEM using a direct preparation technique similar
to that used in USEPA (1988). The authors concluded that only in
one building were sufficient asbestos fibers collected to provide
an estimate of airborne asbestos concentration (0.002 f/cm ) .
All other samples were below the level of quantification.
Airborne fiber levels during disturbance of asbestos-
containing TSI have been measured by phase contrast microscopy
(PCM). PCM counts only fibers longer than 5 micrometers, does
not distinguish asbestos fibers from other types of fibers such
as cellulose and fiber glass, and cannot detect thin fibers
(fibers with diameters less than 0.25 micrometers). Therefore,
PCM results cannot be compared directly with TEM results.
Pinchin (1982) monitored airborne asbestos levels before, during,
and after removal of block-type boiler and pipe insulation from
equipment that was being dismantled. The removal proved
difficult because the material was not easily wetted. Airborne
fiber levels measured by PCM while work was in progress ranged
from over 5.0 f/cm3 at the beginning of the removal to 1.0 f/cm3
as work practices improved. Two air samples analyzed by TEM
before the work began measured an average airborne asbestos
concentration of 0.9 f/cm3. After clean-up the estimated
airborne asbestos concentration was 1.8 f/cm3. The author
implies that there was an unidentified, additional source of
asbestos fibers, but does not elaborate.
Note that methods for measuring and reporting airborne
asbestos vary and refinements are constantly being made. EPA
currently reports asbestos structures per cubic centimeter of air
to emphasize that other structures (bundles, clusters, matrices),
in addition to fibers, are included in the count. Some
researchers state their results as fibers per cubic centimeter of
air irrespective of the type of asbestos structures counted.
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Outdoor
Category 1
(No ACM)
Category 2
(Good Condition)
Category 3
(Damaged)
All Sites
Bldgs with TSI only
0 0.0002 0.0004 0.0006 0.0008
Median Average Airborne Asbestos Cone, (s/cc)
Figure 10. In EPA's study of public buildings (USEPA 1988),
average airborne asbestos levels in 15 buildings with only TSI
followed a similar trend to that observed in all 49 buildings.
Despite the use of glove bags to restrict fiber
movement, NIOSH (1987) recorded average fiber levels of 0.3, 0.3,
0.6, and 0.006 f/cm3 by PCM at four sites during removal of pipe
insulation. The low level measured at the fourth site may be
due, in part, to improved work practices as the workers became
more experienced.
In the supplementary information to the OSHA final
rules (51 FR 22612), estimated exposure during routine
maintenance in commercial and residential buildings (which
presumably includes maintenance involving TSI) is 0.29 f/cm
(mean 8 .hour/ time-weighted average measured by PCM) . The OSHA
rules also cite data indicating airborne fiber levels of 0.01 to
0.57 f/cm3 with a geometric mean of 0.09 f/cm3 during wet
removal of asbestos-containing pipe insulation.
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Although the data are not extensive, they indicate that
elevated airborne fiber levels can occur during disturbance of
asbestos-containing TSI, and strongly support the need for
special precautions when working with or near asbestos-containing
TSI. Note that many of the reported levels exceed current OSHA
standards and would trigger worker protection and surveillance
requirements.
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3. MANAGING ASBESTOS-CONTAINING THERMAL SYSTEM INSULATION
"Guidance for Controlling Asbestos-Containing Materials
in Buildings" (USEPA 1985b), popularly referred to as the "Purple
Book," describes the steps a building manager or owner should
follow to identify and manage asbestos-containing material4.
They are:
1. Determine if asbestos-containing material is
present;
2. Establish a special operations and maintenance
(O&M) program;
3. Assess the need for further action; and
4. Implement response actions as appropriate.
Readers should consult the Purple Book and other reference
sources before implementing these steps. This section provides
an overview of the material in the Purple Book, but is not
intended as a substitute for detailed guidance provided by EPA
and other organizations. Schools must comply with AHERA
requirements.
The building owner should appoint an asbestos program
manager to direct all asbestos-related activities. Depending on
the size and nature of the building, the asbestos program manager
may be supported by various in-house and external personnel.
Building owners with successful asbestos management programs
often emphasize the importance of communication and cooperation
with occupants, tenants, contractors, and others who visit or
work in the building.
3.1 DETERMINING IF ASBESTOS-CONTAINING MATERIAL IS PRESENT IN A
BUILDING
The building is inspected carefully to identify all
potential asbestos-containing material. EPA recommends that
undamaged TSI be left undisturbed and assumed to be asbestos-
containing until there is a need for maintenance or other
activities that are likely to disturb the material. When the
need arises, samples are collected and analyzed by a qualified
laboratory using polarized light microscopy (PLM) to determine
whether or not asbestos is present. (The National Institute of
Technology and Standards, formerly the National Bureau of
*The Purple Book may be obtained from your EPA Regional
Asbestos Coordinator, or by calling the Toxic Substances Control
Act Assistance Office at (202) 554-1404.
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Standards, maintains a list of accredited PLM laboratories.)
Damaged insulation should be sampled where the material is
exposed. (AHERA does not require schools to sample TSI
determined by an accredited inspector to be fiberglass, foam
glass, or rubber.)
Accurate labelling and record keeping are particularly
important for TSI because the nature of the material may vary
within a small area. For example, while pipe insulation on
straight runs may be asbestos free, material on joints and elbows
may contain asbestos. Clear labelling of sampling locations,
whether asbestos-containing or asbestos-free, prevents
unnecessary resampling at the time of maintenance or repair.
Warning labels attached to asbestos-containing material reduce
the likelihood of accidental disturbance, particularly by
individuals such as plumbing or heating contractors who may be
unfamiliar with the building.
3.2 ESTABLISHING AN OPERATIONS AND MAINTENANCE PROGRAM
A special O&M program is established whenever asbestos-
containing material is present or assumed to be present in a
building. The plan is designed to clean up asbestos fibers
previously released, prevent future release by minimizing
disturbance or damage, and monitor the condition of the material.
While details will vary from building to building, a key element
of an O&M program for asbestos-containing TSI is a job approval
system that ensures that work with or near asbestos-containing
TSI will not occur without appropriate precautions. EPA is
currently preparing a new guidance document on O&M programs.
3.3 ASSESSING THE NEED FOR FURTHER ACTION
The need for further action is based on an assessment
of the current condition of the material, the potential for
future fiber release, and building renovation and replacement
plans. The relative risks and costs of different options must be
carefully weighed. In many cases, the decision for asbestos-
containing TSI may Joe, a continuing O&M plan combined with repair
of any damaged material as soon as the damage is detected.
3.4 IMPLEMENTING RESPONSE ACTIONS
Response actions for asbestos-containing TSI include
repair (including encapsulation), enclosure, and, in extreme
cases, removal. Where possible, repair is the generally
recommended action for damaged asbestos-containing TSI.
Enclosure can be used to minimize future disturbance. For
example, pipes running through a public corridor may be enclosed
to prevent building occupants deliberately or accidentally
damaging the insulation. Removal is necessary when the material
is so badly damaged that it no longer performs its insulating
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function, or when system components must be repaired or replaced.
Response actions involving asbestos-containing TSI may be less
costly than those involving surfacing material because they often
take place in restricted areas with minimal disruption to
building occupants. Elaborate procedures may be needed, however,
if the asbestos-containing TSI is associated with the air
handling system and the building must remain operational during
performance of the work.
Procedures for response actions are described in the
Purple Book, in "Abatement of Asbestos-Containing Pipe
Insulation" (EPA Technical Bulletin 1986-2) and the National
Institute of Building Sciences Model Guide Specifications (NIBS
1986). Containment of the work area is generally required.
Response actions should be performed only by trained and
qualified individuals. For work involving a small amount of
asbestos-containing TSI, glove bags provide a practical
alternative to constructing containment barriers around the work
area. As with all forms of asbestos abatement, effective use of
glove bags requires training and experience (NIOSH 1987). EPA
recommends the wearing of respirators and protective clothing
while using glove bags.
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24
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REFERENCES
Burdett GJ, Jaffrey SAMT. 1986. Airborne asbestos concentrations
in buildings. Annals of Occupational Hygiene 30:185-199.
NIBS. 1986. National Institute of Building Sciences. Model Guide
Specifications: Asbestos Abatement in Buildings. Washington,
DC: National Institute of Building Sciences.
NIOSH. 1987. National Institute for Occupational Safety and
Health. An evaluation of glove bag containment in asbestos
removal. Cincinnati, OH: U.S. Department of Health and
Human Services.
NYCDEP. 1988. City of New York Department of Environmental
Protection. Final report on the assessment of the public's
risk of exposure to in-place asbestos. December 1, 1988.
Rogers J. 1988. Additional analysis of data collected in the
asbestos in buildings survey. Draft Final Report.
Washington, DC: Office of Toxic Substances, USEPA. Contract
68-02-4243.
Tuckfield RC, Tsay Y, Margeson DP et al. 1988. Evaluation of
asbestos abatement techniques, phase 3: removal. Draft
Final Report. Washington, DC: Office of Toxic Substances,
USEPA. Contract 68-02-4294.
USEPA. 1980. U.S. Environmental Protection Agency. Measurement
of asbestos air pollution inside buildings with sprayed
asbestos. Washington, DC: Office of Toxic Substances, USEPA.
EPA 560/13-80-026.
USEPA. 1983. U.S. Environmental Protection Agency. Airborne
asbestos levels in schools. Washington, DC: Office of Toxic
Substances, USEPA. EPA 560/5-83-003.
USEPA. 1984a. U.S. Environmental Protection Agency. Asbestos in
buildings: National survey of asbestos-containing friable
materials. Washington, DC: Office of Toxic Substances,
USEPA. EPA 560/5-84-006.
USEPA. 1984b. U.S. Environmental Protection Agency. Evaluation of
the asbestos-in-schools identification and notification
rule. Washington, DC: Office of Toxic Substances, USEPA. EPA
560/5-84-006.
USEPA. 1985a. U.S. Environmental Protection Agency. Evaluation of
asbestos abatement techniques, phase 1: removal. Washington,
DC: Office of Toxic Substances, USEPA. EPA 560/5-85-019.
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USEPA. 1985b. U.S. Environmental Protection Agency. Guidance for
controlling asbestos-containing materials in buildings.
Washington, DC: Office of Toxic Substances, USEPA. EPA
560/5-85-019.
USEPA. 1986. U.S. Environmental Protection Agency. Evaluation of
asbestos abatement techniques, phase 2: encapsulation with
latex paint. Washington, DC: Office of Toxic Substances,
USEPA. EPA 560/5-86-016.
USEPA. 1988. U.S. Environmental Protection Agency. Assessing
asbestos exposure in public buildings. Washington, DC:
Office of Toxic Substances, USEPA. EPA 560/5-88-002.
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APPENDIX A
27
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28
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APPENDIX A. EPA REGIONAL ASBESTOS COORDINATORS
EPA Region 1
JFK Federal Building
Boston, MA 02203
(617) 565-3273
(Connecticut, New Hampshire,
Rhode Island, and Vermont)
EPA Region 2
Woodbridge Avenue
Edison, NJ 08837
(201) 321-6668
(New Jersey, New York, Puerto
Rico, and Virgin Islands)
EPA Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9859
(Delaware, District of
Columbia, Maryland,
Pennsylvania, Virginia, and
West Virginia)
EPA Region 4
345 Cortland Street, N.E.
Atlanta, GA 30365
(404) 347-5053
(Alabama, Florida, Georgia,
Kentucky, Mississippi, North
Carolina, South Carolina, and
Tennessee)
EPA Region 5
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-6003
(Illinois, Indiana, Michigan,
Minnesota, Ohio, and
Wisconsin)
EPA Region 6
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202
(214) 655-7244
(Arkansas, Louisiana, New
Mexico, Oklahoma, and Texas)
EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2835
(Iowa, Kansas, Missouri, and
Nebraska)
EPA Region 8
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1744
(Colorado, Montana, North
Dakota, Utah, and Wyoming)
EPA Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 974-7290
(Arizona, California, Hawaii,
Nevada, American Samoa, and
Guam)
EPA Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-2870
(Alaska, Idaho, Oregon, and
Washington)
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30
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APPENDIX B
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APPENDIX B. SOURCES OF ADDITIONAL INFORMATION
General:
Guidance for controlling asbestos-containing materials in
buildings (Purple Book). U.S. Environmental Protection
Agency. 1985. Washington, DC: Office of Toxic Substances,
USEPA. EPA 560/5-85-019.
Toxic Substances Control Act Assistance Office: (202) 554-
1404.
Operations and Maintenance:
Asbestos in Buildings: Guidance for Service and Maintenance
Personnel. U.S. Environmental Protection Agency. 1985.
Washington, DC: Office of Toxic Substances, USEPA. EPA
560/5-85-018.
Abatement:
Abatement of Asbestos-Containing Pipe Insulation. U.S.
Environmental Protection Agency. 1986. Washington, DC:
Office of Toxic Substances, USEPA. Technical Bulletin
1986-2.
National Institute of Building Sciences. Asbestos Abatement
and Management in Buildings: Model Guide Specifications.
August 1988. Washington, DC: National Institute of Building
Sciences.
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50372-IQ1
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA 560/5-88-007
3. Recipient's Accession No.
4. Title and Subtitle
Asbestos Containing Thermal System Insulation: Facts and Figures
5. Report Date
[March. 1990
7. Authors)
Chesson, J.
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
Chesson Consulting, Inc., 1717 Massachusetts Ave, NW, Washington, DC 20036
Battelle, Arlington Office, 2101 Wilson Boulevard, Arlington, VA 22201
10. Preiect/Taf k/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)68-02-4294
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
Office of Toxic Substances
Exposure Evaluation Division (TS-798)
401 M Street, SW, Washington, DC 20460
13. Type of Report & Period Covered
Peer-reviewed report
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
This document provides information on the characteristics of asbestos-containing thermal system insulation (TSI)
and lists resources available to individuals who are responsible for making asbestos management decisions. The
primary source of information is an U.S. EPA national survey that was conducted in 1984 to determine how
many buildings contain asbestos. Recent analysis of data not included in the original study report provides
additional information on condition of the asbestos-containing material.
Of the 733,000 buildings estimated to contain asbestos, most (about 563,000) have asbestos-containing TSI.
Many fewer (about 192,000 buildings) have asbestos-containing surfacing material. Of the building categories
covered by the survey, residential apartment buildings, buildings built prior to 1944, and buildings of 8 floors or
more are most likely to have asbestos-containing TSI. Over half the buildings with asbestos-containing TSI have
some significantly damaged TSI and 80 percent have at least some damaged TSI. TSI is more likely to be
damaged in commercial non-residential buildings, in buildings constructed prior to 1944, and in buildings of 8
floors or more.
Since friable asbestos is restricted to TSI in many buildings, the majority of asbestos control programs will not
need to address asbestos-containing surfacing material.
17. Document Analysis «. Descriptors
Asbestos, thermal system insulation, surfacing material, damage, public buildings, commercial buidlings,
residential buildings
b. Identlfiers/Opcn-Ended Terms
c. COSATI field/Group
IB. Availability Statement
19. Security Class (This Report)
Unclassified
Class (This Page)
21. No. of Pages
37
22. Price
(See ANSI-Z39.18)
See instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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