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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- IX ------- 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. ------- 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. ------- 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. ------- 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. ------- 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). ------- (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. ------- 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 ------- 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 ------- (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. ------- 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 ------- 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 ------- (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 ------- (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 ------- (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 ------- 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. 15 ------- 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, 16 ------- 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. 17 ------- 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. 18 ------- 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. 19 ------- 20 ------- 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. 21 ------- 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 22 ------- 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. 23 ------- 24 ------- 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. 25 ------- 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. 26 ------- APPENDIX A 27 ------- 28 ------- 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) 29 ------- 30 ------- APPENDIX B 31 ------- 32 ------- 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. 33 ------- 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 ------- |