United States Office of Air Quality
Environmental Protection Planning and Standards
Agency Research Triangle Park, NC
EPA455/B-93-001d
July 1991
Revised .August 1997
Stationary Source Compliance Training Series
C>EPA COURSE* 350
Asbestos NESHAP
Inspection and Safety Procedures
Reference Materials - Volume I
Collection of Published Guides and Other Informational
Documents
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FOREWORD
This reference document contains additional background information
on the Asbestos NESHAP standards and compliance monitoring
methods. This document is intended to serve as reference material for
persons attending Course #350 on asbestos NESHAP inspection and
safety procedures. It is not being distributed as an EPA publication
and is used only as supplemental information to the training course
manual, Asbestos NESHAP Inspection and Safety Procedures: Student
Manual. EPA 455/B-93-001a, revised March 1994.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
S WASHINGTON, D.C. 20460
OFFICE OF
AIR AND RADIATION
ASBESTOS NESHAP GUIDANCE MATERIALS
The Asbestos National Emission Standards for Hazardous Air
Pollutants (NESHAP), 40 CFR 61, Subpart M, was amended on November 20,
1990 by the U.S. Environmental Protection Agency (EPA) to increase the
level of compliance with the demolition and renovation provisions.
In order to assist the public and regulated community to understand
the requirements under the Asbestos NESHAP, a series of guidance
documents were developed and are enclosed with this letter.
These documents are intended for information purposes ONLY, and
may not in any way be interpreted to alter or replace the coverage or
requirements of Subpart M.
If you have specific questions on any of these documents, please
contact the Asbestos NESHAP Coordinator for your State. A list of
coordinators can be found in the document entitled: Asbestos NESHAP
National Contact List.
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CONTENTS
ITEM 1 - Method for the Determination of Asbestos in Bulk Building
Materials
ITEM 2 - Asbestos/NESHAP Regulated Asbestos Containing Material
ITEM 3 - Asbestos/NESHAP Adequately Wet Guidance
ITEM 4 - Reporting and Recordkeeping Requirements for Waste Disposal (A Field Guide)
ITEM 5 - Common Questions on the Asbestos NESHAP
ITEM 6 - The Asbestos/NESHAP Demolition Decision Tree
ITEM 7 - Guidelines For Asbestos NESHAP Landfill Recodkeeping
ITEM 8 - A Guide to Normal Demolition Practices Under the Asbestos NESHAP
ITEM 9 - Guidelines For Catastrophic Emergency Situations Involving Asbestos
ITEM 10 - Asbestos Sampling Bulletin
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&EPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/600/R-93/116
July 1993
Test Method
Method for the
Determination of
Asbestos in Bulk
Building Materials
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ITEM1
Method for the Determination of Asbestos in Bulk Building Materials
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EPA/600/R-93/116
July 1993
TEST METHOD
METHOD FOR THE DETERMINATION OF ASBESTOS
IN BULK BUILDING MATERIALS
by
R. L. Perkins and B. W. Harvey
EPA Project Officer
Michael £. Beard
Atmospheric Research and Exposure Assessment Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27709
EPA Contracts Nos. 68024550 and 68D10009
RTI Project No. 91U-5960-181
June-1993
{go Printed on Recycled Paper
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DISCLAIMER
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under Contracts 68-02-4550 and 68D10009 to the Methods
Research and Development Division, Atmospheric Research and Exposure Assessment
Laboratory, Research Triangle Park, North Carolina. It has been subjected to the Agency's
peer and administrative review, and it has been approved for publication as an EPA
document. Mention of trade names or commercial products does not constitute endorsement
or recommendation for use.
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TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION 1
1.1 References 3
2.0 METHODS 3
2.1 Stereomicroscopic Examination 3
2.1.1 Applicability 4
2.1.2 Range 4
2.1.3 Interferences 4
2.1.4 Precision and Accuracy 4
2.1.5 Procedures 5
2.1.5.1 Sample Preparation 5
2.1.5.2 Analysis 6
2.1.6 Calibration Materials 8
2.1.7 References 8
2.2 Polarized Light Microscopy 9
2.2.1 Principle and Applicability 9
2.2.2 Range ' 10
2.2.3 Interferences 10
2.2.4 Precision and Accuracy 10
2.2.5 Procedures 11
2.2.5.1 Sample Preparation 11
2.2.5.1.1 Qualitative Analysis Preparation II
2.2.5.1.2 Quantitative Analysis Preparation ; . 12
2.2.5.2 Analysis 13
2.2.5.2.1 Identification 13
2.2.5.2.2 Quantitation of Asbestos Content 16
2.2.5.2.3 Microscope Alignment 22
2.2.6 References 22
2.3 Gravimetry 23
2.3.1 Principle and Applicability 23
2.3.2 Interferences 24
2.3.3 Quantitation 25
2.3.4 Preliminary Examination and Evaluation 25
2.3.5 Sample Preparation 26
2.3.5.1 Drying 26
2.3.5.2 Homogenization/Grain Size Reduction 26
2.3.6 Procedure for Ashing . . . 27
2.3.7 Use of Solvents for Removal of Organics 28
2.3.8 Procedure for Acid Dissolution 29
2.3.9 Determination of Optimal Precision and "Accuracy 31
2.3.10 References 31
2.4 X-Ray Powder Diffraction 32
2.4.1 Principle and Applicability 32
2.4.2 Range and Sensitivity 35
. 2.4.3 Limitations 35
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TABLE OF CONTENTS (confd)
SECTION
2.4.3. 1 Interferences ........................................... 35
2.4.3.2 Matrix Effects ................. . ........................ 38
2.4.3.3 Particle Size Dependence ................................... 3
2.4.3.4 Preferred Orientation Effects .................... ........... 39
2.4.3.5 Lack of Suitably Characterized Standard Materials ............... .... .39
2.4.4 Precision and Accuracy ......................................... 40
2.4.5 Procedure ........ . ........................................ 40
2.4.5.1 Sampling ............................................. 40
2.4.5.2 Analysis ................................... .......... 40
2.4.5.2.1 Sample Preparation ............................... 41
2.4.5.2.2 Milling ....................................... 41
2.4.5.2.3 Ashing ............ . .......................... 42
2.4.5.2.4 Acid Washing .............................. ..... 42
2.4.5.3 Qualitative Analysis ...................................... 42
2.4.5.3.1 Initial Screening of Bulk Material ....................... 42
2.4.5.3.2 Detection of Minor or Trace Constituents .................. 43
2.4.5.4 Quantitative Analysis ..................................... 44
2.4.6 Calibration .............................................. ... 46
2.4.6. 1 Preparation of Calibration Standards ............................ 46
2.4.6.2 Analysis of Calibration Standards .............................. 47
2.4.7 Calculations ............................................... . 49
2.4.8 References ................................ . ................ 51
2.5 Analytical Electron Microscopy ....................................... 51
2.5.1 Applicability ................................................ SI
2.5.2 Range ............................... . ................... 52
2.5.3 Interferences ....................... ........................ 52
2.5.4 Precision and Accuracy ......................................... 52
2.5.5 Procedures ................................................ 52
2.5.5.1 AEM Specimen Preparation for Semi-Quantitative Evaluation ............ 53
2.5.5.2 AEM Specimen Preparation for Quantitative Evaluation ................ 54
2.5.5.2.1 Identification .................................... 54
2.5.6 References ...................... ........................... 54
2.6 Other Methodologies ......................... . ....... . ............ 53
3.0 QUALITY CONTROL/QUALITY ASSURANCE OPERATIONS- PLM ............... 55
3.1 General Considerations ............................................ 56
3. 1. 1 Training ............... .................................... 56
3.1.2 Instrument Calibration and Maintenance ............................... 56
3.2 Quality Control of Asbestos Analysis .................................... 57
3.2. 1 Qualitative Analysis ........................................... 57
3.2.2 Quantitative Analysis .......................................... 58
3.3 Interlaboratory Quality Control ..... ". ................................. 59
3.4 Performance Audits .............................................. 60
3.5 Systems Audits .................................................. 60
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TABLE OF CONTENTS (cont'd)
APPENDIX A: GLOSSARY OF TERMS
APPENDIX B: APPARATUS FOR SAMPLE PREPARATION AND ANALYSIS
APPENDIX C: PREPARATION AND USE OF CALIBRATION STANDARDS FOR BULK ASBESTOS
APPENDIX D: SPECIAL-CASE BUILDING MATERIALS
in
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TABLES
TABLE
1-1 Simplified Flowchart for Analysis of Bulk Materials
2-1 Suggested Acceptable Errors For PLM Analysis ''
2-2 Optical Properties of Asbestos Fibers 19
2-3 Typical Central Stop Dispersion Staining Colors 20
2-4 Optical Properties of Man-Made Textile Fibers 20
2-5 Optical Properties of Selected Fibers 2'
2-6 The Asbestos Minerals and Their Nonasbestiform Analogs 34
2-7 Principal Lattice Spacings of Asbestiform Minerals 34
2-8 Common Constituents in Building Materials - 36
2-9 Interferences in XRD Analysis of Asbestiform Minerals 37
IV
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1.0 INTRODUCTION
Laboratories are now called upon to identify asbestos in a variety of bulk building
materials, including loose-fill insulations, acoustic and thermal sprays, pipe and boiler wraps,
plasters, paints, flooring products, roofing materials and cementitious products.
The diversity of bulk materials necessitates the use of several different methods of sample
preparation and analysis. An analysis with a simple stereomicroscope is always followed by
a polarized light microscopic (PLM) analysis. The results of these analyses are generally
sufficient for identification and quantitation of major concentrations of asbestos. However,
during these stereomicroscopic and PLM analyses, it may be found that additional techniques
are needed to: 1) attain a positive identification of asbestos; 2) attain a reasonable accuracy
for the quantity of asbestos in the sample; or 3) perform quality assurance activities to
characterize a laboratory's performance. The additional techniques include x-ray diffraction
(XRD), analytical electron microscopy (AEM), and gravimetry, for which there are sections
included in the method. Other techniques will be considered by the Environmental
Protection Agency (EPA) and may be added at some future time. Table 1-1 presents a
simplified flowchart for analysis of bulk materials.
This Method for the Determination of Asbestos in Bulk Building Materials outlines the
applicability of the various preparation and analysis methods to the broad spectrum of bulk
building materials now being analyzed. This method has been evaluated by the EPA
Atmospheric Research and Exposure Assessment Laboratory (EPA/AREAL) to determine if
it offers improvements to current analytical techniques for building materials. This method
demonstrated a capability for improving the precision and accuracy of analytical results. It
contains significant revisions to procedures outlined in the Interim Method.1 along with the
addition of several new procedures. Each technique may reduce or introduce bias, or have
some effect on the precision of the measurement, therefore results need to be interpreted
judiciously. Data on each technique, especially, those new to asbestos analysis, will be
collected over time and carefully evaluated, with resulting recommendations for changes to
Method to be passed on to the appropriate program office within EPA.
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TABLE 1-1. SIMPLIFIED FLOWCHART FOR ANALYSIS OF BULK MATERIALS
Mandatory
STEREOMICROSCOPIC EXAMINATION
Qualitative (classification, fiber ID) and
Quantitative (calibrated volume estimate)
Section 2.1
Mandatory
POLARIZED LIGHT MICROSCOPY
Qualitative (classification, fiber ID) and
Quantitative (calibrated area estimate
and/or point count)
Section 2.2
Continue when problems are encountered with PLM
and/or for Quality Assurance purposes
Qualitative Problems
(Fiber ID problems)
Quantitative Problems
(?ACM?)
Matrix removal
Section 2.3
PLM
XRD
Sec. 2.4
AEM
Sec. 2.5
Gravimetry
Sec. 2.3
XRD
AEM
PLM
XRD
AEM
(fiber identification)
(amount of asbestos in residue)
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This is an analytical method. It is not intended to cover bulk material sampling, an area
addressed previously2-3-4-5 by the EPA. However, subsampling or sample splitting as it
pertains to laboratory analysis procedures in this method, is discussed throughout.
1.1 References
1. Interim Method for the Determination of Asbestos in Bulk Insulation Samples,
U.S. E.P.A. 600/M4-82-020, 1982.
2. Asbestos-Containing Materials in School Buildings: A Guidance Document, Part
1 and 2, U.S. E.P.A./O.T.S NO. C00090, 1979.
3. Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing
Materials, U.S. E.P.A. 560/5-85-030a, 1985.
4. Guidance for Controlling Asbestos-Containing Materials in Buildings, U.S.
E.P.A. 560/5-85-024, 1985.
5. Asbestos-Containing Materials in Schools: Final Rule and Notice, 40 CFR Part
763, October, 1987.
2.0 METHODS
2.1 Stereomicroscopic Examination
A preliminary visual examination using a simple.stereomicroscope is mandatory for all
samples. A sample should be of sufficient size to provide for an adequate examination. For
many samples, observations on homogeneity, preliminary fiber identification and semi-
quantitation of constituents can be made at this point. Another method of identification and
semi-quantitation of asbestos must be used in conjunction with the Stereomicroscopic
examination. A description of the suggested apparatus needed for Stereomicroscopic
examination is given in Appendix B.
The laboratory should note any samples of insufficient volume. A sufficient sample
volume is sample-type dependent. For samples such as floor tiles, roofing felts, paper
insulation, etc., three to four square inches of the layered material would be a preferred
sample size. For materials such as ceiling tiles, loose-fill insulation, pipe insulation, etc., a
sample size of approximately one cubic inch (- 15cc) would be preferred. For samples of
hin-coating materials such as paints, mastics, spray plasters, tapes, etc., a smaller sample
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size may be suitable for analysis. Generally, samples of insufficient volume should be
rejected, and further analysis curtailed until the client is contacted. The quantity of sample
affects the sensitivity of the analysis and reliability of the quantitation steps. If there is a
question whether the sample is representative due to inhomogeneity, the sample should be
rejected, at least until contacting the client to see if: 1) the client can provide more material
or 2) the client wishes the laboratory to go ahead with the analysis, but with the laboratory
including a statement on the limited sensitivity and reliability of quantitation. If the latter is
the case, the report of analysis should state that the client was contacted, that the client
decided that the lab should use less material than recommended by the method, and that the
client acknowledges that this may have limited the sensitivity and quantitation of the method.
At the time the client is contacted about the material, he or she should be informed that a
statement reflecting these facts will be placed in the report.
2.1.1 Applicability
Stereomicroscopic analysis is applicable to all samples, although its use with vinyl floor
tile, asphaltic products, etc., may be limited because of small asbestos fiber size and/or the
presence of interfering components. It does not provide positive identification of asbestos.
.2.1.2 Range
Asbestos may be detected at concentrations less than one percent by volume, but this
detection is highly material dependent.
2.1.3 Interferences
Detection of possible asbestos fibers may be made more difficult by the presence of other
nonasbestos fibrous components such as cellulose, fiber glass, etc., by binder/matrix
materials which may mask or obscure fibrous components, and/or by exposure to conditions
(acid environment, high temperature, etc.) capable of altering or transforming asbestos.
2.1.4 Precision and Accuracy
v * The precision and accuracy of these estimations are material dependent and must be
determined by the individual laboratory for the percent range involved. These values may be
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determined for an individual analyst by the in-house preparation and analysis of standards
and the use of error bars, control charts, etc.
The labs should also compare to National Voluntary Laboratory Accreditation Program
(NVLAP) proficiency testing samples, if the lab participates in the Bulk Asbestos NVLAP,
or to external quality assurance system consensus results such as from proficiency testing
programs using characterized materials. However, at this time, consensus values for the
quantity of asbestos have been shown to be unreliable. Only proficiency testing materials
characterized by multiple techniques should be used to determine accuracy and precision.
2.1.5 Procedures
NOTE: Exposure to airborne asbestos fibers is a health hazard. Bulk samples
submitted for analysis are oftentimes friable and may release fibers during handling or
matrix reduction steps. All sample handling and examination must be carried out in a
HEPA-filtered hood, a class 1 biohazard hood or a glove box with continuous airflow
(negative pressure). Handling of samples without these precautions may result in
exposure of the analyst to and contamination of samples by airborne fibers.
2.1.5.1 Sample Preparation
No sample preparation should be undertaken before initial stereomicroscopic examination.
Distinct changes in texture or color on a stereomicroscopic scale that might denote an uneven
distribution of components should be noted. When a sample consists of two or more distinct
layers or building materials, each should be treated as a separate sample, when possible.
Thin coatings of paint, rust, mastic, etc., that cannot be separated from the sample without
compromising the layer are an exception to this case and may be included with the layer to
which they are attached. Drying (by heat lamp, warm plate, etc.) of wet or damp samples is
recommended before further stereomicroscopic examination and is mandatory before PLM
examination. Drying must be done in a safety hood.
For nonlayered materials that are heterogeneous, homogenization by some means (mill,
blender, mortar and pestle) may provide a more even distribution of sample components. It
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may also facilitate disaggregation of clumps and removal of binder from fibers (rarely
however, it may mask fibers that were originally discernable).
For materials such as cementitious products and floor tiles, breaking, pulverizing, or
grinding may improve the likelihood of exposing fibrous components.
It may be appropriate to treat some materials by dissolution with hydrochloric acid to
remove binder/matrix materials. Components such as calcite, gypsum, magnesite, etc., may
be removed by this method. For materials found to possess a high organic content
(cellulose, organic binders), ashing by means of a muffle furnace or plasma asher (for small,
cellulosic samples), or dissolution by solvents may be used to remove interfering material.
In either case, it is recommended that matrix removal be tracked gravimetrically.
Additional information concerning homogenization, ashing and acid dissolution may be
found in Sections 2.2.5.1 and 2.3.
2.1.5.2 Analysis
Samples should be examined with a simple stereomicroscope by viewing multiple fields
of view over the entire sample. The whole sample should be observed after placement in a
suitable container (watchglass, weigh boat, etc.) substrate. Samples that are very large
should be subsampled. The sample should be probed, by turning pieces over and breaking
open large clumps. The purpose of the stereomicroscopic analysis is to determine
homogeneity, texture, friability, color, and the extent of fibrous components of the sample.
This information should then be used as a guide to the selection of further, more definitive
qualitative and quantitative asbestos analysis methods. Homogeneity refers to whether each
subsample made for other analytical techniques (e.g. the "pinch" mount used for the PLM
analysis), is likely to be similar or dissimilar. Color can be used to help determine
homogeneity, whether the sample has become wet (rust color), and to help identify or clarify
sample labelling confusion between the building material sampler and the laboratory.
Texture refers to size, shape and arrangement of sample components. Friability may be
indicated by the ease with which the sample is disaggregated (see definitions in Appendix A)
as received by the analyst. This does not necessarily represent the friability of the material
as determined by the assessor at the collection site. The relative proportion of fibrous
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components to binder/matrix material may be determined by comparison to similar materials
of known fibrous content. For materials composed of distinct layers or two or more distinct
building materials, each layer or distinct building material should be treated as a discrete
sample. The relative proportion of each in the sample should be recorded. The layers or
materials should then be separated and analyzed individually. Analysis results for each layer
or distinct building material should be reported. If monitoring requirements call for one
reported value, the results for the individual layers or materials should always be reported
along with the combined value. Each layer or material should be checked for homogeneity
during the stereomicroscopic analysis to determine the extent of sample preparation and
homogenization necessary for successful PLM or other analysis. Fibers and other
components should be removed for further qualitative PLM examination.
Using the information from the stereomicroscopic examination, selection of additional
preparation and analytical procedures should be made. Stereomicroscopic examination
should typically be performed again after any change or major preparation (ashing, acid
dissolution, milling, etc.) to the sample. Stereomicroscopic examination for estimation of
asbestos content may also be performed again after the qualitative techniques have clarified
the identities of the various fibrous components to assist in resolving differences between the
initial quantitative estimates made during the stereomicroscopic analysis and those of
subsequent techniques. Calibration of analysts by use of materials of known asbestos content
is essential.
The stereomicroscopic examination is often an iterative process. Initial examination and
estimates of asbestos concentration should be made. The sample should then be analyzed by
PLM and possibly other techniques. These results should be compared to the initial
stereomicroscopic results. Where necessary, disagreements between results of the techniques
should be resolved by reanalyzing the sample stereomicroscopically.
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2.1.6 Calibration Materials
Calibration materials fall into several categories, including internal laboratory standards
and other materials that have known asbestos weight percent content. These calibration
materials could include:
Actual bulk samples: asbestos-containing materials that have been characterized by
other analytical methods such as XRD, AEM and/or gravimetry. (e.g. NVLAP test
samples).
Generated samples: in-house standards that can be prepared by mixing known
quantities of asbestos and known quantities of asbestos-free matrix materials (by
weight), and mixing (using blender, mill, etc.) thoroughly to achieve homogeneity;
matrix materials such as vermiculite, perlite, sand, fiberglass, calcium carbonate,
etc. may be used. A range of asbestos concentrations should be prepared (e.g. 1, 3,
5, 10, 20%, etc.). The relationship between specific gravities of the components
used in standards should be considered so that weight/volume relationships may be
determined.
Photographs, drawings: photomicrographs of standards, computer-generated
drawings, etc.
Suggested techniques for the preparation and use of in-house calibration standards are
presented in Appendix C, and at greater length by Harvey et al.1 The use of synthesized
standards for analyst calibration and internal laboratory quality control is not new however,
having been outlined by Webber et al.2 in 1982.
2.1.7 References
1. Harvey, B. W., R. L. Perkins, J. G. Nickerson, A. J. Newland and M. E. Beard,
"Formulating Bulk Asbestos Standards", Asbestos Issues, April 1991, pp. 22-29.
2. Webber, J. S., A. Pupons and J. M. Fleser, "Quality-Control Testing for Asbestos
Analysis with Synthetic Bulk Materials". American Industrial Hygiene Associations
Journal, 43, 1982, pp. 427-431.
8
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2.2 Polarized Light Microscopy
2.2.1 Principle and Applicability
Samples of bulk building materials taken for asbestos identification should first be
examined with the simple stereomicroscope to determine homogeneity and preliminary fiber
identification. Subsamples should then be examined using PLM to determine optical
properties of constituents and to provide positive identification of suspect fibers.
The principles of optical mineralogy are well-established.'-2-M A light microscope
equipped with two polarizing filters is used to observe specific optical characteristics of a
sample. The use of plane polarized light allows for the determination of refractive indices
relative to specific crystallographic orientations. Morphology and color are also observed
while viewing under plane polarized light. Observation of particles or fibers while oriented
between polarizing filters whose privileged vibration directions are perpendicular (crossed
polars) allows for determination of isotropism/anisotropism, extinction characteristics of
anisotropic particles, and calculation of birefringence. A retardation plate may be placed in
the polarized light path for verification of the sign of elongation. If subsamples are prepared
in such a way as to represent all sample components and not just suspect fibers, semi-
quantitative analysis may also be performed. Semi-quantitative analysis involves the use of
calibrated visual area estimation and/or point counting. Visual area estimation is a semi-
quantitative method that must relate back to calibration materials. Point counting, also semi-
quantitative, is a standard technique used in petrography for determining the relative areas
occupied by separate minerals in thin sections of rock. Background information on the use
of point counting3 and the interpretation of point count data5 is available.
Although PLM analysis is the primary technique used for asbestos determination, it can
show significant bias leading to false negatives and false positives for certain types of
materials. PLM is limited by the visibility of the asbestos fibers. In some samples the fibers
may be reduced to a diameter so small or masked by coatings to such an extent that they
cannot be reliably observed or identified using PLM.
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2.2.2 Range
The detection limit for visual estimation is a function of the quantity of sample analyzed,
the nature of matrix interference, sample preparation, and fiber size and distribution.
Asbestos may be detected in concentrations of less than one percent by area if sufficient
material is analyzed. Since floor tiles may contain fibers too small to be resolved by PLM
(< 0.25 /xm in diameter), detection of those fibers by this method may not be possible.
When point counting is used, the detection limit is directly proportional to the amount of
sample analyzed, but is also limited by fiber visibility. Quantitation by area estimation, both
visual and by point counting, should yield similar results if based on calibration standards.
2.2.3 Interferences
Fibrous and nonfibrous, organic and inorganic constituents of bulk samples may interfere
with the identification and quantitation of the asbestos mineral content. Binder/matrix
materials may coat fibers, affect color, or obscure optical characteristics to the extent of
masking fiber identity. Many organic mastics are soluble in refractive index liquids and,
unless removed prior to PLM examination, may affect the refractive index measurement of
constituent materials. Fine particles of other materials may also adhere to fibers to an extent
sufficient to cause confusion in identification. Gravimetric procedures for the removal of
interfering materials are presented in Section 2.3.
2.2.4 Precision and Accuracy
Data obtained for samples containing a single asbestos type in a sample matrix have been
reported previously by Brantley et al.6 Data for establishing the accuracy and precision of
the method for samples with various matrices have recently become available. Perkins,7
Webber et al.* and Harvey et al.9 have each documented the tendency for visual estimates
to be high when compared to point-count data. Precision and accuracy must be determined
by the individual laboratory for the percent-range involved. If point counting and/or visual
estimates are used, a table of reasonably expanded errors, such as those shown in Table 2-1
should be generated for different concentrations of asbestos.
10
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If the laboratory cannot demonstrate adequate precision and accuracy (documented by
control charts, etc), quantitation by additional methods, such as gravimetry, may be required.
Refer to the Handbook for SRM Users10 for additional information concerning the concepts
of precision and accuracy.
TABLE 2-1. SUGGESTED ACCEPTABLE ERRORS FOR PLM ANALYSIS
(Based on 400 point counts of a reasonably homogeneous sample
or 100 fields of view for visual estimate)
% Area Asbestos
1
5
10
20
30
40
Acceptable Mean
Result
>0-3%
>l-9%
5-15%
10-30%
20-40%
30-50%
% Area Asbestos
50
60
70
80
90
100
Acceptable Mean
Result
40-60%
50-70%
60-80%
70-90%
80-100%
90-100%
2.2.5 Procedures
NOTE: Exposure to airborne asbestos fibers is a health hazard. Bulk samples
submitted for analysis are oftentimes friable and may release fibers during handling or
matrix reduction steps. All sample and slide preparations must be carried out in a
HEPA-filtered, a class 1 biohazard hood, or a glove box with continuous airflow
(negative pressure). Handling of samples without these precautions may result in
exposure of the analyst to and contamination of samples by airborne fibers.
2.2.5.1 Sample Preparation
Slide mounts are prepared for the identification and quantitation of asbestos in the
sample.
2.2.5.1.1 Qualitative Analysis Preparation .
The qualitative preparation must allow the PLM analysis to classify the fibrous
components of the sample as asbestos or nonasbestos. The major goal of the qualitative
11
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preparation is to mount easily visible fibers in appropriate refractive index liquids for
complete optical characterization. Often this can be accomplished by making immersion
grain mounts of random subsamples of the homogeneous material. Immersion liquids with
refractive indices close to the suspected (see stereomicroscopic analysis) asbestos mineral
should be used for the qualitative analysis so that nD can be determined. Problem samples
include those with inhomogeneities, coatings, small fibers, and interfering compounds.
Additional qualitative preparations are often necessary for these types of samples. All
samples, but especially those lacking homogeneity, may require picking of fibers from
specific sample areas during the stereomicroscopic examination. Coatings on the fibers often
need to be removed by mechanical or chemical means. Teasing the particles apart or use of
a mortar and pestle or similar mechanical method often is sufficient to free fibers from
coatings. Chemical means of removing some coatings and interfering compounds are
discussed in Section 2.3, Gravimetry.
2.2.5.1.2 Quantitative Analysis Preparation
The major purpose of the quantitative preparation is to provide the analyst with a
representative grain mount of the sample in which the asbestos can be observed and
distinguished from the nonasbestos matrix. This is typically performed by using randomly
selected subsamples from a homogeneous sample (see stereomicroscopic analysis). Particles
should be mounted in a refractive index (RI) liquid that allows the asbestos to be visible and
distinguished from nonasbestos components. Care should be taken to ensure proper loading
and even distribution of particles. Both the qualitative and quantitative sample preparations
are often iterative processes. Initial samples are prepared and analyzed. The PLM analysis
may disclose problems or raise questions that can only be resolved by further preparations
(e.g. through the use of different RI immersion liquids, elimination of interfering
compounds, sample homogenization, etc.)
For layered materials, subsamples should be taken from each individual or discrete layer.
Each of these subsamples should be treated as a discrete sample, but as stated in Section
2.1.5.2, the results for the individual layers or materials may be combined if called for by
monitoring requirements.
12
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Homogenization involves the use of any of a variety of devices, such as a mortar and
pestle, mill, or blender to pulverize, disaggregate and mix heterogeneous, friable bulk
materials. Selection of the appropriate device is dependent upon personal preference and the
nature of the materials encountered. A blender or mortar and pestle may be adequate for
homogenizing materials that lack appreciable amounts of tacky matrix/binder, and for
separating interfering components from the fibers. For materials which are unusually sticky
or tacky, or contain unusually long asbestos fibers, milling (especially freezer milling) may
be more efficient. However, milling should be discontinued as soon as the material being
milled appears homogeneous, in order to reduce the potential for mechanically reducing fiber
size below the resolving power of the polarizing microscope. Hammer mills or cutting mills
may also be used on these materials; however, the same precaution regarding reduction of
fiber size should be taken. Blending /milling devices should be disassembled (to the extent
possible) and thoroughly cleaned after each use to minimize contamination.
2.2.5.2 Analysis
Analysis of bulk building materials consists of the identification and semi-quantitation of
the asbestos type(s) present, along with the identification, where possible, of fibrous
nonasbestos materials, mineral components and matrix materials. If the sample is
heterogeneous due to the presence of discrete layers or two or more distinct building
materials, each layer or distinct material should be analyzed, and results reported. Total
asbestos content may also be stated in terms of a relative percentage of the total sample.
2.2.5.2.1 Identification
Positive identification of asbestos requires the determination of the following optical
properties:
Morphology Birefringence
Color and, if present, pleochroism Extinction characteristics
Refractive indices (± .005) Sign of elongation
13
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Descriptions of the optical properties listed above for asbestos fibers may hft found in
Appendix A. nin^ry of Terms. Table 2-2 lists the above properties for the six types of
asbestos and Table 2-3 presents the central stop dispersion staining colors for the asbestos
minerals with selected high-dispersion index liquids. Tables 2-4 and 2-5 list selected optical
properties of several mineral and man-made fibers. All fibrous materials in amounts greater
than trace should be identified as asbestos or nonasbestos, with all optical properties
measured for asbestos and at least one optical property measured for each nonasbestos
fibrous component that will distinguish each from asbestos. Small fiber size and/or binder
may necessitate viewing the sample at higher magnification (400-500x) than routinely used
(lOOx).
Although it is not the purpose of this section to explain the principles of optical
mineralogy, some discussion of the determination of refractive indices is warranted due to its
importance to the proper identification of the asbestos minerals. Following is a brief
discussion of refractive index determination for the asbestos minerals.
All asbestos minerals are anisotropic, meaning that they exhibit different optical
properties (including indices of refraction) in different directions. All asbestos minerals are
biaxial, meaning that they have one principal refractive index parallel (or nearly parallel) to
the length of the fiber and two principal refractive indices (plus all intermediate indices
between these two) in the plane perpendicular (or nearly so) to the length of the fiber.
Although chrysotile (serpentine) is classified as a biaxial mineral, it behaves as a uniaxial
mineral (two principal refractive indices) due to its scrolled structure. Amosite and
crocidolite, although also biaxial, exhibit uniaxial properties due to twinning of the crystal
structure and/or random orientation of fibrils in a bundle around the long axis of the bundle.
For all of the asbestos minerals except crocidolite, the highest refractive index (7) is aligned
with the fiber length (positive sign of elongation). For crocidolite, the lowest refractive
index (a) is aligned with the fiber length (negative sign of elongation). A more complete.
explanation of the relationship of refractive indices to the crystallographic directions of the
asbestos minerals may be found in References 1, 2, 4, 11 and 12. It should be noted that for
the measurement of refractive indices in an anisotropic particle (e.g. asbestos fibers), the
orientation of the particle is quite critical. Orientation with respect to rotation about the axis
14
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of the microscope (and thus with respect to the vibration directions of the polarizer and
analyzer) and also to the horizontal plane (plane of the microscope stage) will affect the
determination 'of'the correct values for refractive indices. The refractive index that is
measured will always correspond to a direction perpendicular to the axis of the microscope
(i.e., lying in the plane of the stage) and is the direction in that horizontal plane parallel to
the vibration direction of the polarizer, by convention E-W.
To determine 7(n ||) for chrysotile, anthophyllite and amosite, the index is measured
when the length of the fiber is aligned parallel to the vibration direction of the polarizer (E-
W). Under crossed polars, the fiber should be at extinction in this orientation. To
determine the lowest refractive index, a (nl), for chrysotile and amosite, the fiber should
be oriented N-S (extinction position under crossed polars). The determination of n || and n 1
with crocidolite is accomplished in the same manner as with amosite and chrysotile with the
exception that the a and 7 directions are reversed. For crocidolite, a is measured at the E-
W position (parallel to the polarizer) and 7 is measured at the N-S orientation (perpendicular
to the polarizer). For anthophyllite, the fiber should be oriented N-S and the lowest and
highest indices for this orientation should be measured. These correspond to a and /3
respectively.
The extinction behavior of tremolite-actinolite is anomalous compared to that of most
monoclinic minerals due to the orientation of the optic axes relative to the crystallographic
axes. This relationship is such that the refractive indices of the principal axes a and 7 are
not measured when the fiber is exhibiting the maximum extinction angle. The values
measured at these positions are a' and y1. The fiber exhibits an extinction angle within a few
degrees of the maximum throughout most of its rotation. A wide range of refractive indices
from a' to a, and from y to 7, are observed. For tremolite-actinolite, /S is measured on
those fibers displaying parallel extinction when oriented in the N-S position. The refractive
index for a is also measured when the fiber is oriented generally in the N-S position and
exhibits the true extinction angle; true a will be the minimum index. To determine the
refractive index for 7, the fibers should be oriented E-W and exhibit the true extinction
angle; true 7 will be the maximum value for this orientation.
15
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When viewing single fibers, the analyst may often be able to manipulate the microscope
slide cover slip and "roll" the fibers to positions that facilitate measuring the true values of
refractive indices. When viewing a large population of fibers with the microscope in the'
dispersion staining mode, the analyst can easily detect fibers that exhibit the highest and
lowest indices (/3 and a) in the N-S position and the highest indices (7) in the E-W position.
Since individual asbestos fibrils cannot generally be resolved using polarized light
microscopy, refractive indices are most commonly measured on fiber bundles. Such
measurements would not result in true values for the indices and therefore by convention
should be reported as a' and /.
Asbestos types chrysotile, amosite and crocidolite are currently available as SRM 1866
and actinolite, tremolite and anthophyllite as SRM 1867 from the Office of Standard
Reference Materials, National Institute of Standards and Technology.
2.2.5.2.2 Quantitation of Asbestos Content
As described in Sections 2.1.5 and 2.1.6, a calibrated visual volume estimation of the
relative concentrations of asbestos and nonasbestos components should be made during the
stereomicroscopic examination. In addition, quantitation of asbestos content should be
performed on subsample slide mounts using calibrated visual area estimates and/or a point
counting procedure. Section 2.1.6 and Appendix C discuss the procedures for preparation
and use of calibration standards. After thorough PLM analysis in which the asbestos and
other components of the bulk material are identified, several slides should be carefully
prepared from randomly selected subsamples. If the sample is not homogeneous, some
homogenization procedure should be performed to ensure that slide preparations made from
small pinch samples are representative of the total sample. Homogenization may range from
gentle mixing using a mortar and pestle to a brief period of mixing using a blender equipped
with a mini-sample container. The homogenization should be of short duration (15
seconds) if using the blender technique so as to preclude a significant reduction in fiber size.
The use of large cover slips (22x30mm) allows for large subsamples to be analyzed. Each
slide should be checked to ensure that the subsample is representative, uniformly dispersed
and loaded in a way so as not to be dominated by superimposed (overlapping) particles.
16
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During the qualitative analysis of the sample, the analyst should decide on the appropriate
optical system (including magnification) to maximize the visibility of the asbestos in the
sample while still allowing the asbestos to be uniquely distinguished from the matrix
materials. The analyst may choose to alter the mounting medium or the optical system to
enhance contrast. During the quantitative analysis, slides should be scanned using an optical
setup that yields the best visibility of the asbestos. Upon finding asbestos, the parameters
that were selected in the qualitative analysis for uniquely distinguishing it from the matrix
should be used for identification. These properties will vary with the sample but include any
or all of the parameters required for the qualitative analysis. For instance, low magnification
allows for concurrent use of dispersion staining (focal screening), but compromises resolution
of extremely small diameter fibers; use of a compensator plate and crossed polarizers
frequently enhances the contrast between asbestos fibers and matrix material.
Visual area estimates should be made by comparison of the sample to calibration
materials that have similar textures and fiber abundance (see Section 2.1.6 and Appendix C).
A minimum of three slide mounts should be examined to determine the asbestos content by
visual area estimation. Each slide should be scanned in its entirety and the relative
proportions of asbestos and nonasbestos noted. It is suggested that the ratio of asbestos to
nonasbestos material be recorded for several fields for each slide and the results be compared
to data derived from the analysis of calibration materials having similar textures and asbestos
content.
For point counting, an ocular reticle (cross-line or point array) should be used to visually
superimpose a point or points on the microscope field of view. The cross-line reticle is
preferred. Its use requires the scanning of most, if not all, of the slide area, thereby
minimizing bias that might result from lack of homogeneity in the slide preparation. In
conjunction with this reticle, a click-stop counting stage can be used to preclude introducing
bias during slide advancement. Magnification used will be dictated by fiber visibility. The
slide should be examined along multiple parallel traverses that adequately cover the sample
area. The analyst should score (count) only points directly over occupied (nonempty) areas.
Empty points should not be scored on the basis of the closest panicle. If an asbestos fiber
and a nonasbestos particle overlap so that a point is superimposed on their visual intersection,
17
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a point should be scored for both categories. If the point(s) is/are superimposed on an area
which has several overlapping particles, the slide should be moved to another field. While
not including them in the total asbestos points counted, the analyst should record the presence
of any asbestos detected but not lying under the reticle cross-line or array points. A
minimum of 400 counts (maximum of eight slides with 50 counts each to minimum of two
slides with 200 counts each) per sample is suggested, but it should be noted that accuracy
and precision improve with number of counts. Point counting provides a determination of
the projected area percent asbestos. Conversion of area percent to dry weight percent is not
feasible unless the specific gravities and relative volumes of the different materials are
known. It should be noted that the total amount of material to be analyzed is dependent on
the asbestos concentration, i.e. the lower the concentration of asbestos, the larger the amount
of sample that should be analyzed, in both the visual estimation and point counting methods.
Quantitation by either method is made more difficult by low asbestos concentration, small
fiber size, and presence of interfering materials.
It is suggested that asbestos concentration be reported as volume percent, weight percent
or area percent depending on the method of quantitation used. A weight concentration
cannot be determined without knowing the relative specific gravities and volumes of the
sample components.
18
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Mineral '
Chrysolite
(asbestiform
serpentine)
AmosJte
(asbestiform
grunerite)
Crocidolite
(asbestiform
riebeckite)
Anthophyllite-
asbestos
Tremolrte-
Actinolite-
asbestos
Morphology and Color'
Wavy libers. Rber bundles have splayed
ends and "kinks". Aspect ratio typically
>10:1. Colorless1
Straight to curved, rigid fibers.
Aspect ratio typically >10:1.
Colorless to brown, nonpleochroic or weakly
so.4 Opaque inclusions may be present
Straight to curved, rigid fibers. Aspect ratio
typically > 10:1. Thick fibers and bundles
common, blue to dark-blue in color.
Pleochroic.
Straight to curved fibers and bundles.
Aspect ratio typically > 10:1. Anthophyllite
cleavage fragments may be present with
' aspect ratios <10:1. Colorless to light
brown.
Straight to curved fibers and bundles.
Aspect ratio typically > 10:1. Cleavage
fragments may be present with aspect ratios
<10:1. Colorless to pale green
Refractive Indices'
/
1.493-1.546 1.517-1.557
1.532-1.549 1.545-1.556
1.529-1.559 1.537-1.567
1.544-1.553 1.552-1.561
1.657-1.663 1.699-1.717
1.663-1.686 1.696-1.729
1.663-1.686 1.696-1.729
1.676-1.683 1.697-1.704
1.693 1.697
1.654-1.701 1.668-1.717
1.680-1.698 1.685-1.706
1.598-1.652 1.623-1.676
1.596-1.694 1.615-1.722
1.598-1.674 1.615-1.697
1.61487 . 1.63627
Tremolite
1.600-1.628 1.625-1.655
1.604-1.612 1.627-1.635
1.599-1.612 1.625-1.637
1.6063' 1,6343'
Actinolite
1.600-1.628 1.625-1.655
1.612-1.668 1.635-1.688
1.613-1.628 1.638-1.655
1.61 26' 1.6393'
Birefringence*
0.004-0.017
0.021-0.054
0.003-0.022
0.013-0.028
0.017-0.028
0.017-0.028
Extinction
Parallel
Usually
parallel
Usually
parallel
Parallel
Parallel and
oblique (up to
21°); Composite
fibers show
parallel extinction.
Sign of Elongation
f
(length slow)
+
(length slow)
(length fast)
+
(length slow)
+
(length slow)
'Colors cited are seen by observation with plane polarized light.
'From references 2.11,12, and 18. respectively. Refractive indices for n, at 589.3nm.
'Fibers subjected to heating may be brownish, (references 13,14, and 15)
'Fibers subjected to heating may be dark brown and pleochroic. (references 13.14, and 15)
5| to fiber length, except J. to fiber length for crocidolite only.
'Maximum and minimum values from references 2. 11. 12, and 18 given.
7± 0.0007
-------
TABLE 2-3. TYPICAL CENTRAL STOP DISPERSION STAINING COLORS'
Mineral
Chrysotile
Amosite
Crocidolite
Anthophyllite-
asbestos
Tremolite-
asbestos
Actinolite-
asbestos
Cargille*
RI Liquid
I.550HD
1.680
1.680
1.605HD
1.605HD
1.605HD
1.630HD
nB
Magenta to light blue-green
Vs ca. 520-620nm
Yellow to magenta
Vs ca. 420-520nm
Yellow to magenta
Vs ca. 420-520nm
Pale yellow to yellow
Vs ca. 330-430nm
Pale yellow to yellow
Vs ca. 330-430nm
Pale yellow
Vs ca. 260-360nm
Yellow to magenta
Vs ca. 420-520nm
nl
Blue-green to pale blue
Vs ca. 600-700nm
Blue magenta to light blue
Vs ca. 560-660nm
Pale yellow to golden yellow
Vs ca. 360-460nm
Golden yellow to light blue green
Vs ca. 460-700nm
Golden yellow to light blue green
V» ca. 460-700nm
Pale yellow to golden yellow
Vs ca. 360-460nm
Golden yellow to blue
Vs ca. 450-600nm
'Modified from reference 16
TABLE 2-4. OPTICAL PROPERTIES OF MAN-MADE TEXTILE FIBERS'-2
Fiber Type
Polyester (Dacron*)
Polyamide (Nylon*)
Aramid (Kevlar*)
Olefm (Polyethylene)
Olefin (Polypropylene)
Viscose Rayon
Acetate
Acrylic (Orion*)
Modacrylic (Dynel*)
n|
1.710
1.582
=*2.37
1.556
1.520
1.535-1.555
1.478-1.480
1.505-1.515
1.535
nl
1.535
1.514
1.641
1.512
1.495
1.515-1.535
1.473-1.476
1.507-1.517
1.532
nl - nl
0.175
0.063
0.729
0.044
0.025
0.020
0.004-0.005
0.004-0.002
0.002
Sign of
Elongation
+
+
-t-
+
+
+
+
-
-I-
'Modified from reference 17
^Refractive indices for specific fibers; other fibers may vary
20
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FIBER
TYPE
Piper (Cellulote)
Olefin
(polyethylene)
Brucile (nemalile)
Healed tmosile
Glass flben,
Mineral wool
Wollastonile
Fibrous (ale
MORPHOLOGY
Tapered, flit ribboni
FiltmeiH* or ihredded
like chryaotile
Straight fiber*
Similar lo unheated,
(bridle and ihorter)
pleochroic: n|-dark brown
nl yellow
Exotic shapes, tear dropi,
iingle filamenta
Straight needlei and bladei
Thin cleavage ribboni and
wavy fibers
TABLE 1-5. OPTICAL PROPERTIES OF SELECTED FIBERS'
REFRACTIVE
INDICES
n| - 1.580
nl - 1.530
n| - 1.556
nl - 1.512
n| - 1.560-1.590
nl - 1.580-1.600
n| andnl >l.7001
I.SI 5- 1.700
n| - I.6JO
nl - 1.637
nl alio 1.610
n| - 1 60
ni - 1.54
BIREFRINGENCE
0.05)
Isoiropic
Moderate to low
(0.018 to 0.002)
High (0.06)
EXTINCTION
ANGLE
Parallel and
incomplete
Parallel
Uiually parallel
Uiually parallel
Parallel and oblique
Parallel and oblique
SIGN OF
ELONGATION
+
+
occasionally +
+
+ and -
+
DISPERSION STAINING
COLORS
in I.550HD
n | : yellow
(Vs < 400nm)
n 1 : pale blue
(V» > 700nm)
in I.550HD
n | : yellow to magenta
(Vs = 440-540nm)
n 1 : pale blue
(Vs > 700nm)
in 1.550HD
n | : golden yellow
(V» 440-460nm)
n 1 : yellow
(Xo's 400-440nm)
in I.680HD
n| & ni : both pale
yellow to while
700nm)
in 1 60.SHD
n | & n 1 : yellow lo pale
yellow
(V* < 4nOnm)
in I.150HD
n| : pale yellow
(X,,'s <400nm)
n 1 : pale blue
(V >660nm)
'From reference 19
'From referencei 13. 14. and 15
-------
2.2.5.2.3 Microscope Alignment
In order to accurately measure the required optical properties, a properly aligned
polarized light microscope must be utilized. The microscope is aligned when:
1) the privileged directions of the substage polarizer and the analyzer are at 90° to one
another and are represented by the ocular cross-lines;
2) the compensator plate's privileged vibration directions are 45° to the privileged
directions of the polarizer and analyzer;
3) the objectives are centered with respect to stage rotation; and,
4) the substage condenser and iris diaphragm are centered in the optic axis.
Additionally, the accurate measurement of the refractive index of a substance requires the
use of calibrated refractive index liquids. These liquids should be calibrated regularly to an
accuracy of 0.004, with a temperature accuracy of 2°C using a refractometer or R.I. glass
beads.
2.2.6 References
1. Bloss, F. Donald, An Introduction to the Methods of Optical Crystallography,
Philadelphia: Saunders College Publishing, 1989.
2. Kerr, Paul F., Optical Mineralogy, 4th Edition, New York: McGraw Hill, 1977.
3. Chamot, £. M. and C. W. Mason, Handbook of Chemical Microscopy, Volume
One, 3rd edition, New York: John Wiley & Sons, 1958.
4. Ehlers, Ernest G., Optical Mineralogy, Vols. 1 and 2, Palo Alto, CA: Blackwell
Scientific Publications, 1987.
5. Chayes, F., Petrographic Modal Analysis: An Elementary Statistical Appraisal,
New York: John Wiley & Sons, 1956.
6. Brantley, E. P., Jr., K. W. Gold, L. E. Myers, and D. E. Lentzen, Bulk Sample
Analysis for Asbestos Content: Evaluation of the Tentative Method, EPA-
600/S4-82-021, 1982.
7. Perkins, R.L., "Point-Counting Technique for Friable Asbestos-Containing
Materials", The Microscope, 38, 1990, pp.29-39.
22
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8. Webber, J.S., R. J. Janulis, L. J. Carhart and M.B. Gillespie, "Quantitating
Asbestos Content in Friable Bulk Samples: Development of a Stratified Point-
Counting Method", American Industrial Hygiene Association Journal, 51, 1990,
pp. 447-452.
9. Harvey, B. W., R. L. Perkins, J. G. Nickerson, A. J. Newland and M. E. Beard,
"Formulating Bulk Asbestos Standards", Asbestos Issues, April 1991, pp. 22-29.
10. Handbook for SRM Users, NIST (formerly NBS) Special Publication 260-100,
U.S. Department of Commerce, 1985.
11. Deer, W.A., R. A. Howie, and J. Zussman, An Introduction to the Rock Forming
Minerals, Longman, 1966.
12. Heinrich, E. W., Microscopic Identification of Minerals, McGraw Hill, 1965.
13. Kressler, J. R., "Changes in Optical Properties of Chrysotile During Acid
Leaching", The Microscope, 31, 1983, pp. 165-172.
14. Prentice, J. and M. Keech, "Alteration of Asbestos with Heat", Microscopy and
Analysis, 10, 1989, pp. 7-12.
15. Laughh'n, G. and W. C. McCrone, "The Effect of Heat on the Microscopical
Properties of Asbestos", The Microscope, 37, 1989, pp. 8-15.
16. Interim Method for the Determination of Asbestos in Bulk Insulation Samples,
U.S. E.P.A. 600/M4-82-020, 1982.
17. McCrone, Walter C., "Routine Detection and Identification of Asbestos", The
Microscope, 33, 1985, pp. 273-284
18. Reports of Analysis, SRM 1866 and 1867, National Institute of Standards &
Technology.
19. McCrone, Walter C., Asbestos Identification, McCrone Research Institute, 1987.
2.3 Gravimetry
2.3.1 Principle and Applicability
Many components of bulk building materials, specifically binder components, can be
x *
selectively removed using appropriate solvents or, in the case of some organics, by ashing.
Hie removal of these components serves the following purposes:
23
-------
1) to isolate asbestos from the sample, allowing its weight to be determined;
2) to concentrate asbestos and therefore lower the detection limit in the total sample;
3) to aid in the detection and identification of fibrous components; and,
4) to remove organic (ashable) fibers which are optically similar to asbestos.
Common binder materials which are removed easily using the techniques described
include: 1) calcite, gypsum, magnesite, brucite, bassanite, portlandite, and dolomite, using
hydrochloric acid, and 2) vinyl, cellulose, and other organic components, by ashing. The
removal of the binder components results in a residue containing asbestos, if initially present,
and any other non-soluble or non-ashable components which were present in the original
sample. Unless the procedures employed result in the loss of some asbestos, the weight
percent of the residue is the upper limit for the weight percent of asbestos in the sample.
This section describes the procedure for removing acid-soluble and ashable components,
and for determining the weight percent of the residue. However, the acid dissolution and
ashing techniques can be used without the accompanying weight measurements to either
liberate or clean fibers to aid in qualitative PLM or AEM analyses.
This technique is not an identification technique. Other methods, such as PLM, XRD, or
AEM must be used to determine the identity of the components. A description of the
suggested apparatus, reagents, etc. needed for the techniques described is included in
Appendix B.
2.3.2 Interferences
Any components which cannot by removed from the sample by selective dissolution or
ashing interfere with asbestos quantitation. These components include, but are not limited to,
many silicates (micas, glass fibers, etc.) and oxides (TiOj, magnetite, etc.). When interfering
phases are present (the residue contains other phases in addition to asbestos), other
techniques such as PLM, AEM, or XRD must be used to determine the percent of asbestos
in the residue.
24
-------
Care must be taken to prevent loss of or chemical/structural changes in the critical
components (asbestos). Prolonged exposure to acids or excessive heating (above 500°C) can
cause changes in the asbestos components in the sample and affect the optical properties.'"u
2.3.3 Quantitation
The weight of the residue remaining after solvent dissolution/ashing should be compared
with the original weight of the material. Presuming no insoluble material is lost, the weight
percent of the residue is the upper .limit for the amount of asbestos in the sample. If the
residue is comprised only of asbestos, then the weight percent of residue equals the weight
percent of asbestos in the sample. If the residue contains other phases, then techniques such
as PLM, XRD, or AEM must be employed to determine the relative abundance of asbestos
in the residue.
The precision and accuracy of the technique are dependent upon the homogeneity of the
material, the accuracy of the weight measurements, and the effectiveness of the sample
reduction and filtering procedures. In practice, the precision can be equal to ±1%, and the
accuracy at 1 wt% asbestos can be less than or equal to +.10% relative.
The incomplete solution of components and the presence of other nonasbestos components
in the residue contribute to producing a positive bias for the technique (falsely high
percentages of asbestos).
2.3.4 Preliminary Examination and Evaluation
Stereomicroscopic and PLM examinations of the sample should already have been
conducted prior to initiating this procedure. These examinations should have provided
information about: 1) whether the sample contains components which can be removed by
acid-washing, solvent dissolution, or ashing, and 2) whether the sample contains asbestos, or
fibers that might be asbestos, or whether no asbestos was detected.
If the sample is friable and contains organic (ashable) components, the ashing procedure
should be followed. If the sample is friable and contains HCl-soluble components, the acid
dissolution procedure should be followed. If the sample is friable and contains both types of
25
-------
components, the two procedures can be applied, preferably with acid dissolution following
ashing.
If the sample is nonfriable (e.g. floor tiles), it is also recommended that the ashing
procedure be used first, followed by the acid dissolution procedure. The ashing procedure
reduces floor tiles to a material which is easily powdered, simplifying the sample preparation
for acid dissolution.
2.3.5 Sample Preparation
2.3.5.1 Drying
Any moisture in the sample will affect the weight measurements, producing falsely low
percentages of residue. If the sample is obviously wet, it should be dried at low temperature
(using a heat lamp, or simply by exposure at ambient conditions, prior to starting the
weighing procedure). If an oven is used, the drying temperature should not exceed 60°C.
Drying by means of heat lamp or ambient air must be performed within a safety-filtered
hood. Even if the sample appears dry, it can contain enough moisture to affect the precision
and accuracy of the technique. The test for sample moisture involves placing the amount of
sample to be used on the weighing pan; if the weight remains stable with time, then the
sample is dry enough. If the weight decreases as the sample sits on the weighing pan, then
the sample should be dried. Where conditions of moderate to high humidity are known to
exist, all materials to be weighed should be allowed time to stabilize to these ambient
conditions.
2.3.5.2 Homogenization/Grain Size Reduction
To increase the accuracy and precision of the acid dissolution technique, the sample
should be homogenized prior to analysis. This reduces the grain size of the binder material
and releases it from fiber bundles so that it may be dissolved in a shorter time period.
Leaving the sample in the acid for a longer period of time to complete the dissolution process
can adversely affect the asbestos components, and is not recommended. Homogenization of
the sample also ensures that any material removed for analysis will more likely be
representative of the entire sample.
26
-------
Homogenization of friable samples prior to ashing may also accelerate the ashing process;
however, the ashing time can simply be increased without affecting the asbestos in the
sample. Nonfriable samples, such as vinyl floor tiles, can be broken or shaved into pieces to
increase surface area and accelerate the ashing process.
Homogenization and grain size reduction can be accomplished in a variety of ways: 1)
hand grinding in a mortar and pestle; 2) crushing with pliers or similar instrument; 3) mixing
in a blender; 4) milling (i.e. Wylie mill, cryomill, etc.); or 5) any other technique which
seems suitable. If the fibers are extremely long, a pair of scissors or similar implement can
be used to reduce the fiber length.
2.3.6 Procedure for Ashing
1) Weigh appropriate amount of material.
There is no restriction on the maximum weight of material used; however, a large
amount of material may take longer to ash. Enough material should be used to avoid
a significant contribution of weighing errors to the total accuracy and precision.
2) Place material in crucible, weigh, and cover with lid.
Placing a lid on the crucible both minimizes the amount of oxygen available, slowing
the rate of combustion of the sample, and prevents any foreign material from falling
into the crucible during ashing.
3) Place crucible into furnace, and ash for at least 6 hours.
The furnace temperature at the sample position should be at least 300 °C but should
not exceed 500°C. If the sample combusts (bums), the temperature of the sample
may exceed 500°C. Chrysotile will decompose above approximately 500°C.
The furnace area should be well-ventilated and the fumes produced by ashing should
be exhausted outside the building.
The ashing time is dependent on the furnace temperature, the amount of sample, and
the surface area (grain size). Six hours at 450°C is usually sufficient.
4) Remove crucible from furnace, allow contents to adjust to room temperature
and humidity, and weigh.
27
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5) Divide residue weight by starting weight and multiply by 100 to determine
weight% residue.
6) Analyze residue and/or proceed to acid dissolution procedure.
If the objective was to remove organic fibers that may be confused optically with
asbestos, examine residue with PLM to determine whether any fibers remain.
If the sample is a floor tile, the acid dissolution procedure must now be performed.
The residue does not have to be analyzed at this stage.
2.3.7 Use of Solvents for Removal of Organics
Solvent dissolution may be used as a substitute for low temperature ashing for the
purpose of removing organic interferences from bulk building materials. However, solvent
dissolution, because of the involvement of potentially hazardous reagents such as
tetrahydrofuran, amyl acetate, 1-1-1, trichlorethane, etc., requires that all work be
performed with extreme caution inside a biohazard hood. Material Safety Data Sheets
should be reviewed before using any solvent. Solvent dissolution involves more apparatus
than does ashing, and requires more time, mainly due to set-up and slow filtration resulting
from viscous solvent/residue mixtures.
The following is a brief description of the solvent dissolution process.
1) Weigh starting material.
Place approximately 15-25ml of solvent in a 100ml beaker. Add 2.5-3.0 grams
(carefully weighed for continued gravimetric tracking) of powdered sample.
2) Untrasonicate sample.
Place the beaker in an ultrasonic bath (or ultrasonic stirrer) for approximately 0.5
hours. The sample containers should be covered to preclude escape of an aerosol
spray.
3) Centrifuge sample.
Weigh centrifuge vial before adding beaker ingredients. Wash beaker with an
additional 10-15ml of solvent to remove any remaining concentrate. Then centrifuge
28
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at approximately 2000-2500 rpm for 0.5 hour. Use solvent-resistant centrifuge
tubes.
4) Decant sample, reweigh.
After separation by centrifuging, decant solvent by pipetting. Leave a small amount
of solvent in the centrifuge vial to minimize the risk of decanting solid concentrate.
Allow solid concentrate to dry in vial, then reweigh.
2.3.8 Procedure for Acid Dissolution
1) Weigh starting material, transfer to acid resistant container.
Small, dry sample weights between O.lg and 0.5g are recommended (determined for
47mm filters - adjust amount if different diameter filters are used). If too much
material is left after acid dissolution the filter can get clogged and prevent complete
filtration. Very small samples are also to be avoided, as the weighing errors will
have a large effect on the total accuracy and precision of the technique.
2) Weigh filter.
3) Add HC1 to sample in container, stir, allow to sit for 2-10 minutes.
Either concentrated or dilute HC1 can be used. If concentrated HC1 is used, add
enough acid to completely soak the material, allow the reaction to proceed to
completion, and then dilute with distilled water. Alternatively, a dilute solution,
made by adding concentrated HC1 to distilled water, can be used in the place of
concentrated HC1. A solution of 1 pan concentrated HC1 to 3 parts distilled water
(approximately 3N solution) has been found to be quite effective in removing
components within 5 minutes. For a sample size less than 0.5g, 20-30 ml of a 3N
HC1 solution is appropriate. In either case (using concentrated or dilute HC1), the
reaction will be more effective if the sample has been homogenized first. All
obvious signs of reaction (bubbling) should cease before the sample is filtered. Add
fresh acid, a ml or two at a time, to ensure complete reaction. It should be noted
that if dolomite is present, a 15-20 minute exposure to concentrated HC1 may be
required to completely dissolve the carbonate materials.
NOTE: Other solvents may be useful for selective dissolution of nonasbestos
components. For example, acetic acid will dissolve calcite, and will not dissolve
asbestos minerals. If any solvent other than hydrochloric acid is used for the
dissolution of inorganic components, the laboratory must be able to demonstrate that
the solvent does not remove asbestos from the sample.
29
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4) Filter solution.
Use the pre-weighed filter. Pour the solution into the vacuum filter assembly, then
rinse all material from container into filter assembly. Rinse down the inside walls of
the glass filter basin and check for particles clinging to the basin after removal.
5) Weigh dried filter + residue, subtract weight of filter from total.
6) Divide residue weight by starting weight and multiply by 100 to determine
weight % residue.
7) Analyze residue.
Perform stereomicroscopic examination of residue (can be performed without
removing the residue from the filter). Note in particular whether any binder material
is still present.
Perform PLM, AEM, or XRD analysis of residue to identify fibers and determine
concentration as described in the appropriate sections of this method.
8) Modify procedure if necessary.
If removal of the acid soluble components was not complete, start with a new
subsample of material and try any of the following:
a) Decrease grain size of material (by grinding, milling, etc.)
b) Put solutions on hot plate - warm slightly
c) Increase soak time (exercise caution)
9) Calculate relative weight % asbestos in sample.
wt% asbestos in sample = % asbestos in residue x wt% residue -r 100
For floor tiles, if the ashing procedure was used first, multiply the weight % of
asbestos in the sample, as determined above, by the weight percent of the residue
from the ashing procedure, then divide by 100.
Example:
A = wt% residue from ashing = 70%
B = wt% residue from HC1 = 20%
C = wt% of asbestos in HC1 residue = 50%
wt% asbestos after HC1 dissolution = B x C + 100 = 20 x 50 + 100= 10%
30
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wt% asbestos in floor tile = (B x C -s- 100) x A -s- 100 = 10 x 70 -s- 100 = 7%
If weights are expressed in decimal form, multiply the weight % of asbestos in the
sample by the weight % of the residue from the ashing procedure, then multiply by
100.
wt% asbestos after HC1 dissolution = B x C = 0.2 x 0.5 = 0.1 (x 100 = 10%)
wt% asbestos in floor tile = (B x C) x A = 0.1 x 0.7 = 0.07 (x 100 = 7%)
2.3.9 Determination of Optimal Precision and Accuracy
The precision of the technique can be determined by extracting multiple subsamples from
the original sample and applying the same procedure to each. The optimal accuracy of the
technique can be determined by applying gravimetric standards. Mixtures of calcite and
asbestos (chrysotile, amosite, etc.) in the following proportions are recommended for testing
the accuracy of the acid dissolution technique: 0.1 wt% asbestos/99.9 wt% calcite, 1.0 wt%
asbestos/99.0 wt% calcite, and 10 wt% asbestos/90 wt% calcite. Mixtures of cellulose and
asbestos are useful for testing the accuracy of the ashing technique.
Mixtures of only two components, as described above, are simplifications of "real-world"
samples. The accuracy determined by analyzing these mixtures is considered optimal and
may not apply directly to the measurement of each unknown sample. However, analyzing
replicates and standards using the full laboratory procedure, including homogenization,
ashing, acid dissolution, filtration, and weighing, may uncover steps that introduce significant
bias or variation that the laboratory may then correct.
2.3.10 References
1. Kressler, J. R., "Changes in Optical Properties of Chrysotile During Acid
Leaching", The Microscope, 31, 1983, pp. 165-172.
2. Prentice, J. and M. Keech, "Alteration of Asbestos with Heat", Microscopy and
Analysis, March 1989.
3. Laughlin, G. and W. C. McCrone, "The Effect of Heat on the Microscopical
Properties of Asbestos", The Microscope, 37, 1989, pp. 8-15.
31
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2.4 X-Ray Powder Diffraction
2.4.1 Principle and Applicability
The principle of x-ray powder diffraction (XRD) analysis is well established.1-2 Any
solid crystalline material will diffract an incident beam of parallel, monochromatic x-rays
whenever Bragg's Law,
X = 2d sin 6,
is satisfied for a particular set of planes in the crystal lattice, where
X = the x-ray wavelength, A;
d = the interplanar spacings of the set of reflecting lattice planes, A and
0 = the angle of incidence between the x-ray beam and the reflecting lattice planes.
By appropriate orientation of a sample relative to the incident x-ray beam, a diffraction
pattern can be generated that will be uniquely characteristic of the structure of the crystalline
phases present.
Unlike optical methods of analysis, however, XRD cannot determine crystal morphology.
Therefore, in asbestos analysis, XRD does not distinguish between fibrous and nonfibrous
forms of the serpentine and amphibole minerals (Table 2-6). However, when used in
conjunction with methods such as PLM or AEM, XRD techniques can provide a reliable
analytical method for the identification and characterization of asbestiform minerals in bulk
materials.
For qualitative analysis by XRD methods, samples should initially be scanned over
limited diagnostic peak regions for the serpentine (- 7.4 A) and amphibole (8.2-8.5 A)
minerals (Table 2-7). Standard slow-scanning methods for bulk sample analysis may be used
for materials shown by PLM to contain significant amounts of asbestos (>5 percent).
Detection of minor or trace amounts of asbestos may require special sample preparation and
step-scanning analysis. All samples that exhibit diffraction peaks in the diagnostic regions
for asbestiform minerals should be submitted to a full (5°-60° 26; 1° 20/min) qualitative
XRD scan, and their diffraction patterns should be compared with standard reference powder
32
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diffraction patterns3 to verify initial peak assignments and to identify possible matrix
interferences when subsequent quantitative analysis will be performed.
Accurate quantitative analysis of asbestos in bulk samples by XRD is critically
dependent on particle size distribution, crystallite size, preferred orientation and matrix
absorption effects, and comparability of standard reference and sample materials. The most
intense diffraction peak that has been shown to be free from interference by prior qualitative
XRD analysis should be selected for quantitation of each asbestiform mineral. A "thin-layer"
method of analysis5-6 can be used in which, subsequent to comminution of the bulk material
to ~ 10 fim by suitable cryogenic milling techniques, an accurately known amount of the
sample is deposited on a silver membrane filter. The mass of asbestiform material is
determined by measuring the integrated area of the selected diffraction peak using a step-
scanning mode, correcting for matrix absorption effects, and comparing with suitable
calibration standards. Alternative "thick-layer" or bulk methods7," are commonly used for
semi-quantitative analysis.
33
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TABLE 2-6. THE ASBESTOS MINERALS AND THEIR
NONASBESTIFORM ANALOGS
Asbestiform
Serpentine
Chrysotile
Amphibole
AiUhophyllite asbestos
Cummingtonite-grunerite
asbestos (Amosite)
Crocidolite
Tremolite asbestos
Actinolite asbestos
Nonasbestiform
Antigorite, lizardite
Anthophyllite
Cummingtonite-
grunerite
Riebeckite
Tremolite
Actinolite
Chemical Abstract
Service No.
12001-29-5
77536-67-5
12172-73-5
12001-28-4
77536-68-6
77536-66-4
TABLE 2-7. PRINCIPAL LATTICE SPACINCS OF ASBESTIFORM MINERALS1
Minerals
Chrysotile (Serpentine)
Amosite (Grunerile)
Anthophyllite
Crocidolite (Riebeckite)
Actinolite
Tremolite
Principal d-spacings (A)
and relative intensities
7.31..0
7-36loo
7.10,00
8.33,00
8.22,00
3.05180
3.06,00
8.3SI80
8.40,00
2.721CO
838,00
2.706,00
3.13..0
3-65w
3.66»
2.33.0
3-06,0
3.060M
3.24«o
8.33^
310«
3-1255
2.54IOO
3.12,00
3.14W
2.706M
4-57,0
2.45.,
3.55-0
2.756,
3.25,,
8.26.,
3.23*
2-720M
2.726,
3.40tt
2.705,0
8.43«
8.44^
JCPDS
Powder diffraction file1
number
21-543'
25-645
22-1162 (theoretical)
17-745 (nonfibrous)
27-1 170 (UICC)
9*455
16-401 (synthetic)
27-1415 (UICC)
19-1061
25-157
13-437*
20-13 10* (synthetic)
23-666 (synthetic mixture
w/richterite)
1. This information is intended as a guide only. Complete powder diffraction data, including
mineral type and source, should be referred to ensure comparability of sample and reference
materials where possible. Additional precision XRD data on amosite, crocidolite. tremolile and
chrysotile are available from the U.S. Bureau of Mines. Reference 4.
2. From Reference 3
3. Fibrosity questionable
34
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This XRD method is applicable as a confirmatory method for identification and
quantitation of asbestos in bulk material samples that have undergone prior analysis by PLM
or other optical methods.
2.4.2 Range and Sensitivity
The range and sensitivity of the method have not been determined. They will be variable
and dependent upon many factors, including matrix effects (absorption and interferences),
diagnostic reflections selected and their relative intensities, preferred orientation, and
instrumental limitations. A detection limit of one percent is feasible given certain sample
characteristics.
2.4.3 Limitations
2.4.3.1 Interferences
Since the asbestiform and nonasbestiform analogs of the serpentine and amphibole
minerals (Table 2-7) are indistinguishable by XRD techniques unless special sample
preparation techniques and instrumentation are used,' the presence of nonasbestiform
serpentines and amphiboles in a sample will pose severe interference problems in the
identification and quantitative analysis of their asbestiform analogs.
The use of XRD for identification and quantitation of asbestiform minerals in bulk
samples may also be limited by the presence of other interfering materials in the sample.
For naturally-occurring materials, the commonly associated asbestos-related mineral
interferences can usually be anticipated. However, for fabricated materials, the nature of the
interferences may vary greatly (Table 2-8) and present more serious problems in
identification and quantitation.10 Potential interferences are summarized in Table 2-9 and
include the following:
Chlorite has major peaks at 7.19 A and 3.58 A that interfere with both the primary
(7.31 A) and secondary (3.65 A) peaks for serpentine (chrysotile). Resolution of the
primary peak to give good quantitative results may be possible when a step-scanning
mode of operation is employed.
Vermiculite has secondary peaks at 7.14 A and 3.56 A that could interfere with the
primary peak (7.31 A) and a secondary peak (3.65 A) of serpentine (chrysotile).
35
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TABLE 2-8. COMMON CONSTITUENTS IN BUILDING MATERIAL
(From Ref. 10)
co
cr>
A. Insulation Materials
Chrysolilc
Ainosite
Crocidolitc
*Rock wool
Slag wool
* Fiber glass
Gypsum (CaSO4 2H20)
Vermiculiic (micas)
*Pcrlilc
Clays (kaolin)
Wood pulp
Paper fibers (talc, clay
carbonate fillers)
Calcium silicates (synthetic)
Opaques (chromite, magnetite
inclusions in serpentine)
Hematite (inclusions in "amosite")
Magnesite
Diatomaceous earth
B. Flooring Materials
Calcite
Dolomite
Titanium Oxide
Quartz
Anligoritc
Chrysotile
Anlbophyllite
Tremolite
Organic binders
Talc
Wollastonite
C. Spray Finishes or Paints
Bassanite
Carbonate minerals (calcitc,
dolomite, vatcrite)
Talc
Trcmolilc
Anthophyllite
Serpentine (including cbrysotile)
Amosite
Crocidolite
Mineral wool
*Rock wool
*Slag wool
'Fiber glass
Clays (kaolin)
Micas
Chlorite
Gypsum
Quartz
Organic binders and thickeners
Hydromagnesite
Wollastonite
Opaques (cbromitc, magnetite
inclusion in serpentine)
llcmnlile (inclusions in "amosite")
D. Cemcntitious Materials
Chrysotile
Amosite
Crocidolilc
Micas
Fiber glass
Cellulose
Animal hair
Quartz
Gypsum
Calcite
Dolomite
Calcium silicates
E. Roofing Materials
Chrysotilc
Cellulose
Fiber glass
Mineral Wool
Asphalt
Quartz
Talc
Micas
Amorphous materials-contribute only to overall scattered radiation and increased background radiation.
-------
TABLE 2-9 INTERFERENCES IN XRD ANALYSIS OF
ASBESTIFORM MINERALS
Asbestiform
Mineral
Primary diagnostic
peaks (approximate
d spacings in A)
Interference
Serpentine
Chrysotile
7.3
3.7
Nonasbestiform serpentines, (antigorite,
lizardite), chlorite, vermiculite, sepiolite,
kaolinite, gypsum
Nonasbestiform serpentines (antigorite,
lizardite), chlorite, vermiculite, halloysite,
cellulose
Amphibole
Amosite (Grunerite)
Anthophyllite
Crocidolite
(Riebeckite)
Tremolite
Actinolite
3.1
8.3
Nonasbestiform amphiboles (grunerite-
cummingtonite, anthophyllite, riebeckite,
tremolite), mutual interferences, talc,
carbonates
Nonasbestiform amphiboles (grunerite-
cummingtonite, anthophyllite, riebeckite,
tremolite), mutual interferences
Sepiolite produces a peak at 7.47 A which could interfere with the primary peak
(7.31 A) of serpentine (chrysotile).
Halloysite has a peak at 3.63 A that interferes with the secondary (3.65 A) peak for
serpentine (chrysotile).
Kaolinite has a major peak at 7.15 A that may interfere with the primary peak of
serpentine (chrysotile) at 7.31 A when present at concentrations of > 10 percent.
However, the secondary serpentine (chrysotile) peak at 3.65 A may be used for
quantitation.
Gypsum has a major peak at 7.5 A that overlaps the 7.31 A peak of serpentine
(chrysotile) when present as a major sample constituent. This may be removed by
careful washing with distilled water, or by heating to 300°C to convert gypsum to
plaster of pans (bassanite).
Cellulose has a broad peak thai partially overlaps the secondary (3.65 A) serpentine
(chrysotile) peak.* .
37
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Overlap of major diagnostic peaks of the amphibole minerals, grunerite (anosite),
anthophyllite, riebeckite (crocidolite), and tremolite, at approximately 8.3 A and 3.1
A causes mutual interference when these minerals occur in the presence of one
another. In some instances adequate resolution may be attained by using step-
scanning methods and/or by decreasing the collimator slit width at the x-ray port.
Carbonates may also interfere with quantitative analysis of the amphibole minerals
grunerite (amosite), anthophyllite, riebeckite (crocidolite), and tremolite-actinolite.
Calcium carbonate (CaC03) has a peak at 3.035 A that overlaps major amphibole
peaks at approximately 3.1 A when present in concentrations of >5 percent.
Removal of carbonates with a dilute acid wash is possible; however, the time in acid
should be no more than 20 minutes to preclude any loss of chrysotile."
A major talc peak at 3.12 A interferes with the primary tremolite peak at this same
position and with secondary peaks of actinolite (3.14 A), riebeckite (crocidolite) (3.10
A), grunerite (amosite) (3.06 A), and anthophyllite (3.05 A). In the presence of talc,
the major diagnostic peak at approximately 8.3 A should be used for quantitation of
these asbestiform minerals.
The problem of intraspecies and matrix interference is further aggravated by the
variability of the silicate mineral powder diffraction patterns themselves, which often makes
definitive identification of the asbestos minerals by comparison with standard reference
diffraction patterns difficult. This variability results from alterations in the crystal lattice
associated with differences in isomorphous substitution and degree of crystallinity. This is
especially true for the amphiboles. These minerals exhibit a wide variety of very similar
chemical compositions, resulting in diffraction patterns characterized by having major (110)
reflections of the monoclinic amphiboles and (210) reflections of orthorhombic anthophyllite
separated by less than 0.2 A.12
2.4.3.2 Matrix Effects
If a copper x-ray source is used, the presence of iron at high concentrations in a sample
will result in significant x-ray fluorescence, leading to loss of peak intensity, increased
background intensity, and an overall decrease in sensitivity. This situation may be corrected
by use of an x-ray source other than copper; however, this is often accompanied both by loss
of intensity and by decreased resolution of closely spaced reflections. Alternatively, use of a
38
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diffracted beam monochromator will reduce background fluorescent radiation, enabling
weaker diffraction peaks to be detected.
X-ray absorption by the sample matrix will result in overall attenuation of the diffracted
beam and may seriously interfere with quantitative analysis. Absorption effects may be
minimized by using sufficiently "thin" samples for analysis.5-13-14 However, unless absorption
effects are known to be the same for both samples and standards, appropriate corrections
should be made by referencing diagnostic peak areas to an internal standard7'8 or filter
substrate (Ag) peak.5-6
2.4.3.3 Particle Size Dependence
Because the intensity of diffracted x-radiation is particle-size dependent, it is essential for
accurate quantitative analysis that both sample and standard reference materials have similar
particle size distributions. The optimum particle size (i.e., fiber length) range for
quantitative analysis of asbestos by XRD has been reported to be 1 to 10 jtm.'5
Comparability of sample and standard reference material particle size distributions should be
verified by optical microscopy (or another suitable method) prior to analysis.
2.4.3.4 Preferred Orientation Effects
Preferred orientation of asbestiform minerals during sample preparation often poses a
serious problem in quantitative analysis by XRD. A number of techniques have been
developed for reducing preferred orientation effects in "thick layer" samples.7-*-15 For "thin"
samples on membrane filters, the preferred orientation effects seem to be both reproducible
and favorable to enhancement of the principal diagnostic reflections of asbestos minerals,
actually increasing the overall sensitivity of the method.12-14 However, further investigation
.into preferred orientation effects in both thin layer and bulk samples is required.
2.4.3.5 Lack of Suitably Characterized Standard Materials
The problem of obtaining and characterizing suitable reference materials for asbestos
analysis is clearly recognized. The National Institute of Standards and Technology can
39
-------
provide standard reference materials for chrysotile, amosite and crocidolite (SRM 1866) and
anthophyllite, tremolite and actinolite (SRM 1867).
In addition, the problem of ensuring the comparability of standard reference and sample
materials, particularly regarding crystallite size, panicle size distribution, and degree of
crystallinity, has yet to be adequately addressed. For example, Langer et al.1* have observed
that in insulating matrices, chrysotile tends to break open into bundles more frequently than
amphiboles. This results in a line-broadening effect with a resultant decrease in sensitivity.
Unless this effect is the same for both standard and sample materials, the amount of
chrysotile in the sample will be under-estimated by XRD analysis. To minimize this
problem, it is recommended that standardized matrix reduction procedures be used for both
sample and standard materials.
2.4.4 Precision and Accuracy
Neither the precision nor accuracy of this method has been determined. The individual
laboratory should obtain or prepare a set of calibration materials containing a range of
asbestos weight percent concentrations in combination with a variety of matrix/binder
materials. Calibration curves may be constructed for use in semi-quantitative analysis of
bulk materials.
2.4.5 Procedure
2.4.5.1 Sampling
Samples taken for analysis of asbestos content should be collected as specified by EPA"
2.4.5.2 Analysis
All samples must be analyzed initially for asbestos content by PLM. XRD may be used
as an additional technique, both for identification and quantitation of sample components.
Note: Asbestos is a toxic substance. All handling of dry materials should be performed
in a safety-hood.
40
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2.4.5.2.1 Sample Preparation
The method of sample preparation required for XRD analysis will depend on: (1) the
condition of the sample received (sample size, homogeneity, particle size distribution, and
overall composition as determined by PLM); and (2) the type of XRD analysis to be
performed (qualitative or quantitative; thin-layer or bulk).
Bulk materials are usually received as heterogeneous mixtures of complex composition
with very wide particle size distributions. Preparation of a homogeneous,, representative
sample from asbestos-containing materials is particularly difficult because the fibrous nature
of the asbestos minerals inhibits mechanical mixing and stirring, and because milling
procedures may cause adverse lattice alterations.
A discussion of specific matrix reduction procedures is given below. Complete methods
of sample preparation are detailed in Sections 2.4.5.3 and 2.4.5.4. Note: AH samples
should be examined microscopically before and after each matrix reduction step to
monitor changes in sample particle size distribution, composition, and crystallinity, and
to ensure sample representativeness and homogeneity for analysis.
2.4.5.2.2 Milling
Mechanical milling of asbestos materials has been shown to decrease fiber crystallinity,
with a resultant decrease in diffraction intensity of the specimen; the degree of lattice
alteration is related to the duration and type of milling process.20"23 Therefore, all milling
times should be kept to a minimum.
For qualitative analysis, particle size is not usually of critical importance and initial
characterization of the material with a minimum of matrix reduction is often desirable to
document the composition of the sample as received. Bulk samples of very large particle
size (>2-3 mm) should be comminuted to - 100 /*m. A mortar and pestle can sometimes be
used in size reduction of soft or loosely bound materials though this may cause matting of
some samples. Such samples may be reduced by cutting with a razor blade in a mortar, or
by grinding in a suitable mill (e.g., a microhammer mill or equivalent). When using a
mortar for grinding or cutting, the sample should be moistened with ethanol, or some other
41
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suitable wetting agent, to minimize exposure, and the procedure should be performed in a
HEPA-filtered hood.
For accurate, reproducible quantitative analysis, the particle size of both sample and
standard materials should be reduced to ~ 10 /xm . Dry ball milling at liquid nitrogen
temperatures (e.g., Spex Freezer Mill*, or equivalent) for a maximum time of 10 minutes
(some samples may require much shorter milling time) is recommended to obtain satisfactory
particle size distributions while protecting the integrity of the crystal lattice.5 Bulk samples
of very large particle size may require grinding in two stages for full matrix reduction to
<10/zm.8-16
Final particle size distributions should always be verified by optical microscopy or
another suitable method.
2.4.5.2.3 Ashing
For materials shown by PLM to contain large amounts of cellulose or other organic
materials, it may be desirable to ash prior to analysis to reduce background radiation or
matrix interference. Since chrysotile undergoes dehydroxylation at temperatures between
550°C and 650°C, with subsequent transformation to forsterite,24-25 ashing temperatures
should be kept below 500°C. Use of a muffle furnace is recommended. In all cases,
calibration of the furnace is essential to ensure that a. maximum ashing temperature of 500°C
is not exceeded (see Section 2.3).
2.4.5.2.4 Acid Washing
Because of the interference caused by gypsum and some carbonates in the detection of
asbestiform minerals by XRD (see Section 2,4.3.1), it may be necessary to remove these
interferences by a simple acid washing procedure prior to analysis (see Section 2.3).
2.4.5.3 Qualitative Analysis
2.4.5.3.1 Initial Screening of Bulk Material
Qualitative analysis should be performed on a representative, homogeneous portion of the
sample, with a minimum of sample treatment, using the following procedure:
42
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1. Grind and mix the sample with a mortar and pestle (or equivalent method, see Section
2.4.5.2.2) to a final particle size sufficiently small (- 100 urn) to allow adequate
packing into a sample holder.
2. Pack sample into a standard bulk sample holder. Care should be taken to ensure that
a representative portion of the milled sample is selected for analysis. Particular care
should be taken to avoid possible size segregation of the sample. (Note: Use of
back-packing method26 for bulk sample preparation may reduce preferred
orientation effects.)
3. Mount the sample on the diffractometer and scan over the diagnostic peak regions for
the serpentine (-7.4 A) and amphibole (8.2-8.5 A) minerals (see Table 2-7). The x-
ray diffraction equipment should be optimized for intensity. A slow scanning speed
of 1" 20/min is recommended for adequate resolution. Use of a sample spinner is
recommended.
4. Submit all samples that exhibit diffraction peaks in the diagnostic regions for
asbestiform minerals to a full qualitative XRD scan (5°-60° 20; 1° 20/min) to verify
initial peak assignments and to identify potential matrix interferences when subsequent
quantitative analysis is to be performed.
5. Compare the sample XRD pattern with standard reference powder diffraction patterns
(i.e., JCPDS powder diffraction data3 or those of other well-characterized reference
materials). Principal lattice spacings of asbestiform minerals are given in Table 2-7;
common constituents of bulk insulation and wall materials are listed in Table 2-8.
2.4.5.3.2 Detection of Minor or Trace Constituents
Routine screening of bulk materials by XRD may fail to detect small concentrations
(< 1%) of asbestos. The limits of detection will, in general, be improved if matrix
absorption effects are minimized, and if the sample particle size is reduced to the optimal 1
to 10 fim range, provided that the crystal lattice is not degraded in the milling process.
Therefore, in those instances when confirmation of the presence of an asbestiform mineral at
very low levels is required, or where a negative result from initial screening of the bulk
material by XRD (see Section 2.4.5.3.1) is in conflict with previous PLM results, it may be
desirable to prepare the sample as described for quantitative analysis (see Section 2.4.5.4)
step-scan over appropriate 26 ranges of selected diagnostic peaks (Table 2-7). Accurate
43
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transfer of the sample to the silver membrane filter is not necessary unless subsequent
quantitative analysis is to be performed.
2.4.5.4 Quantitative Analysis
The proposed method for quantitation of asbestos in bulk samples is a modification of the
NIOSH-recommended thin-layer method for chrysotile in air.6 A thick-layer bulk method
involving pelletizing the sample may be used for semi-quantitative analysis;7-* however, this
method requires the addition of an internal standard, use of a specially fabricated sample
press, and relatively large amounts of standard reference materials. Additional research is
required to evaluate the comparability of thin- and thick-layer methods for quantitative
asbestos analysis.
For quantitative analysis by thin-layer methods, the following procedure is recommended:
1. Mill and size all or a substantial representative portion of the sample as outlined in
Section 2.4.5.2.2.
2. Dry at 60°C for 2 hours; cool in a desiccator.
3. Weigh accurately to the nearest 0.01 mg.
4. Samples shown by PLM to contain large amounts of cellulosic or other organic
materials, gypsum, or carbonates, should be submitted to appropriate matrix
reduction procedures described in Sections 2.4.5.2.3 and 2.4.5.2.4. After ashing
and/or acid treatment, repeat the drying and weighing procedures described above,
and determine the percent weight loss, L.
5. Quantitatively transfer an accurately weighed amount (50-100 mg) of the sample to a
1-L volumetric flask containing approximately 200 mL isopropanol to which 3 to 4
drops of surfactant have been added.
6. Ultrasonicate for 10 minutes at a power density of approximately 0.1 W/mL to
disperse the sample material.
7. Dilute to volume with isopropanol.
8. Place flask on a magnetic-stirring plate. Stir.
9. Place silver membrane filter on the filtration apparatus, apply a vacuum, and attach
the reservoir. Release the vacuum and add several milliliters of isopropanol to the
reservoir. Vigorously hand shake the asbestos suspension and immediately withdraw
44
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an aliquot from the center of the suspension so that total sample weight, WT, on the
filter will be approximately 1 mg. Do not adjust the volume in the pipet by
expelling part of the suspension; if more than the desired aliquot is withdrawn,
discard the aliquot and repeat the procedure with a clean pipet. Transfer the aliquot
to the reservoir. Filter rapidly under vacuum. Do not wash the reservoir walls.
Leave the filter apparatus under vacuum until dry. Remove the reservoir, release
the vacuum, and remove the filter with forceps. (Note: Water-soluble matrix
interferences such as gypsum may be removed at this time by careful washing of the
filtrate with distilled water. Extreme care should be taken not to disturb the sample.)
10. Attach the filter to a flat holder with a suitable adhesive and place on the
diffractometer. Use of a sample spinner is recommended.
11. For each asbestos mineral to be quantitated, select a reflection (or reflections) that
has (have) been shown to be free from interferences by prior PLM or qualitative
XRD analysis and that can be used unambiguously as an index of the amount of
material present in the sample (see Table 2-7).
12. Analyze the selected diagnostic reflection(s) by step-scanning in increments of 0.02°
26 for an appropriate fixed time and integrating the counts. (A fixed count scan may
be used alternatively; however, the method chosen should be used consistently for all
samples and standards.) An appropriate scanning interval should be selected for
each peak, and background corrections made. For a fixed time scan, measure the
background on each side of the peak for one-half the peak-scanning time. The net
intensity, I,, is the difference between the peak integrated count and the total
background count.
13. Determine the net count, I*,, of the filter 2.36 A silver peak following the
procedure in step 12. Remove the filter from the holder, reverse it, and reattach
it to the holder. Determine the net count for the unattenuated silver peak, I ^,
Scan times may be less for measurement of silver peaks than for sample peaks';
however, they should be constant throughout the analysis.
14. Normalize all raw, net intensities (to correct for instrument instabilities) by
referencing them to an external standard (e.g., the 3.34 A peak of an o-quartz
reference crystal). After each unknown is scanned, determine the net count,
I°n of the reference specimen following the procedure in step 12. Determine
the normalized intensities by dividing the peak intensities by I°r:
45
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2.4.6 Calibration
2.4.6.1 Preparation of Calibration Standards
1. Mill and size standard asbestos materials according to the procedure outlined in
Section 2.4.5.2.2. Equivalent standardized matrix reduction and sizing
techniques should be used for both standard and sample materials.
2. Dry at 100°C for 2 hours; cool in a desiccator.
3. Prepare two suspensions of each standard in isopropanol by weighing approximately
10 and 50 mg of the dry material to the nearest 0.01 mg. Transfer each to a 1-L
volumetric flask containing approximately 200 mL isopropanol to which a few drops
of surfactant have been added.
4. Ultrasonicate for 10 minutes at a power density of approximately 0.1 W/mL, to
disperse the asbestos material.
S. Dilute to volume with isopropanol.
6. Place the flask on a magnetic stirring plate. Stir.
7. Prepare, in triplicate, a series of at least five standard filters to cover the desired
analytical range, using appropriate aliquots of the 10 and 50 mg/L suspensions. For
each standard, mount a silver membrane filter on the filtration apparatus. Place a
few mL of isopropanol in the reservoir. Vigorously hand shake the asbestos
suspension and immediately withdraw an aliquot from the center of the suspension.
Do not adjust the volume in the pipet by expelling part of the suspension; if more
than the desired aliquot is withdrawn, discard the aliquot and resume the procedure
with a clean pipet. Transfer the aliquot to the reservoir. Keep the tip of the pipet
near the surface of the isopropanol. Filter rapidly under vacuum. Do not wash the
sides of the reservoir. Leave the vacuum on for a time sufficient to dry the filter;
Release the vacuum and remove the filter with forceps.
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2.4.6.2 Analysis of Calibration Standards
1. Mount each filter on a flat holder. Perform step scans on selected diagnostic
reflections of the standards and reference specimen using the procedure outlined in
Section 2.4.5.4, step 12, and the same conditions as those used for the samples.
2. Determine the normalized intensity for each peak measured, 1° ,, as outlined in
Section 2.4.5.4, step 14. std
2.4.7 Calculations
For each asbestos reference material, calculate the exact weight deposited on each
standard filter from the concentrations of the standard suspensions and aliquot volumes.
Record the weight, w, of each standard. Prepare a calibration curve by regressing 1° on
w. Poor reproducibility (±15 percent RSD) at any given level indicates problems in the
sample preparation technique, and a need for new standards. The data should fit a straight-
line equation.
Determine the slope, m, of the calibration curve in counts/microgram. The intercept,
b, of the line with the I" axis should be approximately zero. A large negative intercept
indicates an error in determining the background. This may arise from incorrectly measuring
the baseline or from interference by another phase at the angle of background measurement.
A large positive intercept indicates an error in determining the baseline or that an impurity is
included in the measured peak.
Using the normalized intensity, 1 ., for the attenuated silver peak of a sample, and
* »
the corresponding normalized intensity from the unattenuated silver peak I* , of the sample
filter, calculate the transmittance, T, for each sample as follows:27-21
Determine the correction factor, f(T), for each sample according to the formula:
47
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_ rp»/V
where
sin 9a
0A, = angular position of the measured silver peak (from Bragg's Law), and
0. = angular position of the diagnostic asbestos peak.
Calculate the weight, W,, in micrograms, of the asbestos material analyzed for in each
sample, using the absorption corrections:
J^f(t) - b
m
Calculate the percent composition, Pa, of each asbestos mineral analyzed for in the parent
material, from the total sample weight, WT, on the filter:
Ws(1 - .OIL)
P = 2 x 100
WT
where
P. = percent asbestos mineral in parent material;
W, = mass of asbestos mineral on filter, in /ig;
WT = total sample weight on filter, in /ig;
L = percent weight loss of parent material on ashing and/or acid treatment (see Section
2.4.5.4).
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2.4.8 References
1. Klug, H. P. and L. E. Alexander, X-Ray Diffraction Procedures for
Polycrystalline and Amorphous Materials, 2nd ed., New York: John Wiley and
Sons, 1979.
2. Azaroff, L. V. and M. J. Buerger, The Powder Method of X-Ray
Crystallography, New York: McGraw-Hill, 1958.
3. JCPDS-International Center for Diffraction Data Powder Diffraction Studies,
1601 Park Lane, Swarthmore, PA.
4. Campbell, W. J., C. W. Huggins, and A. G. Wylie, Chemical and Physical
Characterization of Amosite, Chrysotile, Crocidolite, and Nonfibrous Tremolite
for National Institute of Environmental Health Sciences Oral Ingestion Studies,
U.S. Bureau of Mines Report of Investigation R18452, 1980.
5. Lange, B. A. and J. C. Haartz, Determination of microgram quantities of asbestos
by x-ray diffraction: . Chrysotile in thin dust layers of matrix material, Anal.
Chem., 51(4):529-525, 1979.
6. NIOSH Manual of Analytical Methods, Volume 5, U.S. Dept. HEW, August
1979, pp. 309-1 to 309-9.
7. Dunn, H.W. and J. H. Stewart, Jr., Determination of Chrysotile in building
materials by x-ray diffractometry, Analytical Chemistry, 54 (7); 1122-1125, 1982.
8. Taylor, A., Methods for the quantitative determination of asbestos and quartz in
bulk samples using x-ray diffraction. The Analyst, I 03(1231): 1009-1020, 1978.
9. Birks, L., M. Fatemi, J. V. Gilfrich, and E. T. Johnson, Quantitative Analysis of
Airborne Asbestos by X-Ray Diffraction, Naval Research Laboratory Report 7879,
Naval Research Laboratory, Washington, DC, 1975.
10. Asbestos-Containing Materials in School Buildings: A Guidance Document, U.
S. Environmental Protection Agency. EPA/OTS No. C00090, March 1979.
11. Krause, J. B. and-W. H. Ashton, Misidentification of asbestos in talc, pp. 339-353,
In: Proceedings of Workshops on Asbestos: Definitions and Measurement
Methods (NBS Special Publication 506), C. C. Gravatt, P. D. LaFleur, and K. F.
Heinrich (eds.), Washington, DC: National Measurement Laboratory, National
Bureau of Standards, 1977 (issued 1978).
49
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12. Stanley, H. D., The detection and identification of asbestos and asbestiform minerals
in talc, pp. 325-337, In: Proceedings of Workshop on Asbestos: Definitions and
Measurement Methods (NBS Special Publication 506), C. C. Gravatt, P. D.
LaFleur, and K. F. Heinrich (eds.), Washington, DC: National Measurement
Laboratory, National Bureau of Standards, 1977 (issued 1978).
13. Rickards, A. L., Estimation of trace amounts of chrysotile asbestos by x-ray
diffraction, Anal. Chem., 44(11): 1872-3, 1972.
14. Cook, P. M., P. L. Smith, and D. G. Wilson, Amphibole fiber concentration and
determination for a series of community air samples: use of x-ray diffraction to
supplement electron microscope analysis, In: Electron Microscopy and X-Ray
Applications to Environmental and Occupation Health Analysis, P. A. Russell
and A. E. Hutchings (eds.), Ann Arbor: Ann Arbor Science Publications, 1977.
15. Rohl, A. N. and A. M. Langer, Identification and quantitation of asbestos in talc,
Environ. Health Perspectives, 9:95-109, 1974.
16. Graf, J. L., P. K. Ase, and R. G. Draftz, Preparation and Characterization of
Analytical Reference Materials, DREW (NIOSH) Publication No. 79-139, June
1979.
17. Haartz, J. C., B. A. Lange, R. G. Draftz, and R. F. Scholl, Selection and
characterization of fibrous and nonfibrous amphiboles for analytical methods
development, pp. 295-312, In: Proceedings of Workshop on Asbestos:
Definitions and Measurement Methods (NBS special Publication 506), C. C.
Gravatt, P. D. LaFleur, and K. F. Heinrich (eds.), Washington, DC: National
Measurement Laboratory, National Bureau of Standards, 1977 (issued 1978).
18. Personal Communication, A. M. Langer, formerly of Environmental Sciences
Laboratory, Mount Sinai School of Medicine of the City University of New York,
New York, NY, now of Brooklyn College, Brooklyn, N.Y.
19. Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing
Materials, U.S. Environmental Protection Agency. EPA 560/5-85-030a, October
1985.
20. Langer, A. M., M. S. Wolff, A. N. Rohl, and I. J. Selikoff, Variation of properties
of chrysotile asbestos subjected to-milling, J. Toxicql. and Environ. Health,
4:173-188, 1978.
21. Langer, A. M., A. D. Madder, and F. D. Pooley, Electron microscopical
investigation of asbestos fibers, Environ. Health Perspect., 9:63-80, 1974.
50
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22. Occella, E. and G. Maddalon, X-ray diffraction characteristics of some types of
asbestos in relation to different techniques of comminution, Med. Lavoro
54(10):628-636, 1963.
23. Spumy, K. R., W. Stober, H. Opiela, and G. Weiss, On the problem of milling and
ultrasonic treatment of asbestos and glass fibers in biological and analytical
applications, Am. Ind. Hyg. Assoc. J., 41:198-203, 1980.
24. Berry, L. G. and B. Mason, Mineralogy, San Francisco: W. H. Greeman & Co
1959.
25. Schelz, J. P., The detection of chrysotile asbestos at low levels in talc by differential
thermal analysis, Thermochimica Acta, 8:197-204, 1974.
26. Reference 1, pp. 372-374.
27. Leroux, J., Staub-Reinhalt Luft, 29:26 (English), 1969.
28. Leroux, J. A., B. C. Davey, and A. Paillard, Proposed standard methodology for
the evaluation of silicosis hazards, Am. Ind. Hyg. Assoc. J., 34:409, 1973.
2.5 Analytical Electron Microscopy
2.5.1 Applicability
Analytical electron microscopy (AEM) can often be a reliable method for the detection
and positive identification of asbestos in some bulk building materials, both friable and
nonfriable. The method is particularly applicable to bulk materials that contain a large
amount of interfering materials that can be removed by ashing and/or dissolution and contain
asbestos fibers that are not resolved by PLM techniques. Many floor tiles and plasters would
be included in this type of sample. In combination with suitable specimen preparation
techniques, the AEM method can also be used to quantify asbestos concentrations.
2.5.2 Range
The range is dependent on the type of bulk material being analyzed. The upper detection
limit is 100%, and the lower detection limit can be as low as 0.0001 % depending on the
<*tent to which interfering materials can be separated during the preparation of AEM
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specimens, the sophistication of the AEM preparation, and the amount of labor expended on
AEM examination.
2.5.3 Interferences
The presence of a large amount of binder/matrix materials associated with fibers can
make it difficult to positively identify fibers as asbestos. The portion of the fiber examined
by either electron diffraction or energy dispersive x-ray analysis (EDXA) must be free of
binder/matrix materials.
2.5.4 Precision and Accuracy
The precision and accuracy of the method have not been determined.
2.5.5 Procedures
The procedures for AEM specimen preparation depend on the data required. In analysis
of floor tiles, the weighed residue after removal of the matrix components (see Section 2.3,
Gravimetry) is often mostly asbestos, and the task is primarily to identify the fibers. In this
situation the proportion of asbestos in the residue can be estimated by AEM and this estimate
can be used to refine the gravimetric result. For many floor tiles, the final result is not very
sensitive to errors in this estimation because the proportion of asbestos in the residue is very
high. For samples in which this is not the case, precise measurements can be made using a
quantitative AEM preparation, in which each grid opening of the specimen grid corresponds
to a known weight of the original sample or of a concentrate derived from the original
sample. Asbestos fibers on these grids are then identified and measured, using a fiber
counting protocol which is directed towards a precise determination of mass concentration.
This latter procedure is suitable for samples of low asbestos concentration, or for those in
which it is not possible to remove a large proportion of the matrix material.
2.5.5.1 AEM Specimen Preparation for Semi-Quantitative Evaluation
The residual material from any ashing or dissolution procedures (see Section 2.3) used
(usually trapped on a membrane filter) should be placed in a small volume of ethanol or
another solvent such as acetone or isopropyl alcohol, in a disposable beaker, and dispersed
52
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by treatment in an ultrasonic bath. A small volume of this suspension (approximately 3/xl)
should be pipetted onto the top of a carbon-coated TEM grid. The suspension should be
allowed to dry under a heat lamp. The grid is then ready for examination.
Samples that are not conducive to ashing or dissolution may also be prepared in this way
for AEM analysis. A few milligrams of the sample may be ground in a mortar and pestle or
milled, dispersed in ethanol or another solvent using an ultrasonic bath, and pipetted onto a
grid as described previously.
2.5.5.2 AEM Specimen Preparation for Quantitative Evaluation
The objective of this preparation is to obtain a TEM grid on which a known weight of
the bulk sample is represented by a known area of the TEM grid. A known weight of the
bulk sample, or of the residue after extraction, should be dispersed in a known volume of
distilled water. Aliquots of this dispersion should then be filtered through 0.22 /xm pore-size
MCE or 0.2 ttm pore-size PC filters, using filtration techniques as described for analysis of
water samples.' In order to obtain filters of appropriate paniculate loading for AEM
analysis, it may be necessary to perform serial dilutions of the initial dispersion. TEM grids
should then be prepared from appropriately-loaded filters, using the standard methods.2
Determination of the mass concentration of asbestos on the TEM grids requires a
different fiber counting protocol than that usually used for determination of numerical fiber
concentrations. Initially, the grids should be scanned to determine the dimensions of the
largest asbestos fiber or fiber bundle on the specimens. The volume of this fiber or bundle
should be calculated. The magnification of the AEM should be set at a value for which the
length of this fiber or bundle just fills the fluorescent screen. Asbestos fiber counting should
then be continued at this magnification. The count should be terminated when the volume of
the initial large fiber or bundle represents less than about 5% of the integrated volume of all
asbestos fibers detected. This counting strategy ensures that the fiber counting effort is
directed toward those fibers which contribute most to the mass, and permits a precise mass
concentration value to be obtained.
53
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2.5.5.2.1 Identification
To document the positive identification of asbestos in a sample, the analyst should record
the following physical properties: morphology data, electron diffraction data, EDXA data,
and any other distinguishing characteristics observed. For fibrous structures identified as
nonasbestos, the unique physical property or properties that differentiate the material from
asbestos should be recorded.
The purpose of the identification data collected is to prevent or limit false negatives and
false positives. This can be accomplished by having a system for measuring and recording
the d-spacings and symmetry of the diffraction patterns, determining the relative abundance
of the elements detected by EDXA, and comparing these results to reference data. The
laboratory should have a set of reference asbestos materials from which a set of reference
diffraction patterns and x-ray spectra have been developed. Also, the laboratory should have
available reference data on the crystallography and chemical composition of minerals that
might analytically interfere with asbestos.
2.5.6 References
1. Chatfield, E.J., and M. J. Dillon, Analytical Method for Determination of
Asbestos Fibers in Water, EPA-600/4-83-043. U.S. Environmental Protection
Agency Environmental Research Laboratory, 1983.
2. Environmental Protection Agency's Interim Transmission Electron Microscopy
Analytical MethodsMandatory and Noiunandatory~and Mandatory Section to
Determine Completion of Response Actions, Appendix A to subpart E, 40 CFR
part 763.
2.6 Other Methodologies.
Additional analytical methods (e.g. Scanning Electron Microscopy) may be applicable for
some bulk materials. However, the analyst should take care to recognize the limitations of
any analytical method chosen. Conventional SEM, for example, cannot detect small
diameter fibers (- < 0.2fim), and cannot determine crystal structure. It is, however, very
useful for observing surface features in complex particle matrices, and for determining
elemental compositions.
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3.0 QUALITY CONTROL/QUALITY ASSURANCE OPERATIONS- PLM
A program to routinely assess the quality of the results produced by the PLM laboratory
must be developed and implemented. Quality Control (QC) is a system of activities whose
purpose is to control the quality of the product or service so that it meets the need of the
users. This also includes Quality Assessment, whose purpose is to provide assurance that
the overall quality control is being done effectively. While the essential elements of a quality
control system are described in detail elsewhere,'-2-3-4-5-6 only several of the elements will be
discussed here. Quality Assurance (QA) is comprised of Quality Control and Quality
Assessment and is a system of activities designed to provide assurance that a product or
service meets defined standards of quality.
The purpose of the Quality Assurance program is to minimize failures in the analysis of
materials prior to submitting the results to the client. Failures in the analysis of asbestos
materials include false positives, false negatives, and misidentification of asbestos types.
False positives result from identification or quantitation errors. False negatives result from
identification, detection, or quantitation errors.
For the stereomicroscopic and PLM techniques, the quality .control procedures should
characterize the accuracy and precision of both individual analysts and the techniques.
Analysts should demonstrate their abilities on calibration materials, and also be checked
routinely on the analysis of unknowns by comparison with results of a second analyst. The
limitations of the stereomicroscopic and PLM techniques can be determined by using a
second analytical technique, such as gravimetry, XRD, or AEM. For example,
stereomicroscopic and PLM techniques can fail in the analysis of floor tiles because the
asbestos fibers in the sample may be too small to be resolved by light microscopy. An XRD
or AEM analysis is not subject to the same limitations, and may indicate the presence of
asbestos in the sample.
The accuracy, precision, and detection limits of all analytical techniques described in this
method are dependent on the type of sample (matrix components, texture, etc.), on the
"'preparation of the sample (homogeneity, grain size, etc.), and the specifics of the method
(number of point counts for PLM, mass of sample for gravimetry, counting time for XRD,
55
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etc.). These should be kept in mind when designing quality control procedures and
characterizing performance, and are variables that must be tracked in the quality assurance
system.
3.1 General Considerations
3.1.1 Training
Of paramount importance in the successful use of this or any other analytical method is
the well-trained analyst. It is highly recommended that the analyst have completed course
work in optical mineralogy on the collegiate level. That is not to say that others cannot
successfully use this method, but the classification error rate7 may, in some cases, be directly
attributable to level of training. In addition to completed course work in optical mineralogy,
specialized course work in PLM and asbestos identification by PLM is desirable. Experience
is as important as education. A good laboratory training program can be used in place of
course work. Analysts that are in training and not yet fully qualified should have all
analyses checked by a qualified analyst before results are released. A QC Plan for asbestos
identification would be considered incomplete without a detailed description of the analyst
training program, together with detailed records of training for each analyst.
3.1.2 Instrument Calibration and Maintenance
Microscope alignment checks (alignment of the polarizer at 90" with respect to the
analyzer, and coincident with the cross-lines, proper orientation of the slow vibration
direction of the Red I compensator plate, image of the field diaphragm focussed in the plane
of the specimen, centering of the central dispersion staining stop, etc.) should be performed
with sufficient frequency to ensure proper operations. Liquids used for refractive index
determination and those optionally used for dispersion staining should have periodic
refractive index checks using a refractometer or known refractive index solids. These
calibrations must be documented.
Microscopes and ancillary equipment should be maintained daily. It is recommended that
at least once per year each microscope be thoroughly cleaned and re-aligned by a
professional microscope service technician. Adequate inventories of replaceable parts
56
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(illumination lamps, etc.) should be established and maintained. All maintenance must be
documented.
3.2 Quality Control of Asbestos Analysis
3.2.1 Qualitative Analysis
All analysts must be able to correctly identify the six regulated asbestos types (chrysotile,
amosite, crocidolite, anthophyllite, actinolite, and tremolite) using combined
stereomicroscopic and PLM techniques. Standards for the six asbestos types listed are
available from MIST, and should be used to train analysts in the measurement of optical
properties and identification of asbestos. These materials can also be used as identification
standards for XRD and AEM.
Identification errors between asbestos types (e.g. reporting amosite when tremolite is
present) implies that the analyst cannot properly determine optical properties and is relying
on morphology as the identification criteria. This is not acceptable. Each analyst in the lab
should prove his or her proficiency in identifying the asbestos types; this can be checked
through use of calibration materials (NVLAP proficiency testing materials, materials
characterized by an independent technique, and synthesized materials) and by comparing
results with another analyst. The identification of all parameters (e.g. refractive indices,
birefringence, sign of elongation, etc.) leading to the identification should fall within control
limits determined by the laboratory. In addition, a subset of materials should be analyzed
using another technique to confirm the analysis.
As discussed earlier, the qualitative analysis is dependent upon matrix and asbestos type
and texture. Therefore, the quality assurance system should monitor for samples that are
difficult to analyze and develop additional or special steps to ensure accurate characterization
of these materials. When an analyst is found to be out of the control limits defined by the
laboratory, he or she should undergo additional training and have confirmatory analyses
performed on all samples until the problem has been corrected.
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3.2.2 Quantitative Analysis
The determination of the amount of asbestos in a sample can be accomplished using the
various techniques outlined in this method. The mandatory stereomicroscopic and PLM
examinations provide concentrations in terms of volume, area, or weight, depending upon the
calibration procedure. Gravimetric and quantitative XRD techniques result in concentrations
in units of weight percent. Specific guidelines for determining accuracy and precision using
these techniques are provided in the appropriate sections of this method. In general,
however, the accuracy of any technique is determined through analysis of calibration
materials which are characterized by multiple independent techniques in order to provide an
unbiased value for the analyte (asbestos) in question. The precision of any technique is
determined by multiple analyses of the sample. The analyst is the detector for
stereomicroscopic and PLM techniques, as opposed to gravimetric and XRD techniques, and
therefore must be calibrated as an integral pan of the procedure.
As in the qualitative analysis, the laboratory should determine its accuracy and precision
for quantitative asbestos analysis according to the type of material analyzed and the technique
used for analysis. For example, the laboratory may determine that its analysts have a
problem with calibrated area estimates of samples containing cellulose and chrysotile and
therefore needs to make or find special calibration materials for this class of sample.
Calibration materials for quantitative analysis of asbestos are available through the Bulk
Asbestos NVLAP as proficiency testing materials for those laboratories enrolled in NVLAP.
In a report provided following a test round, the concentration of asbestos in each sample is
given in weight percent with 95%/95% tolerance limits, along with a description of the
major matrix components. 'Materials from other round robin and quality assurance programs
for asbestos analysis may not have been analyzed by independent techniques; the
concentrations may represent consensus PLM results that could be significantly biased.
Therefore, values from these programs should floj be used as calibration materials for
quantitative analysis.
Calibration materials for quantitative analysis can also be synthesized by mixing asbestos
and appropriate matrix materials, as described in Appendix C of this method. These
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materials are usually simplifications of "real world" samples; therefore the accuracy and
precision determined from analysis of these materials are probably ideal.
Limits on permissible analytical variability must be established by the laboratory prior to
QC implementation. It is recommended that a laboratory initially be at 100% quality control
(all samples reanalyzed.) The proportion of quality control samples can later be lowered
gradually, as control indicates, to'a minimum of 10%. Quantitative results for standards
including the mean and error estimate (typically 95% confidence or tolerance intervals)
should be recorded. Over time these data can be used to help determine control limits for
quality control charts.
The establishment and use of control charts is extensively discussed elsewhere in the
literature. u-3-0 Several cautions are in order:
Control charts are based on the assumption that the data are distributed normally.
Using rational subgrouping, the means of the subgroups are approximately normally
distributed, irrespective of the distribution of the individual values in the subgroups.
Control charts for asbestos analysis are probably going to be based on individual
measurements, not rational subgroups. Check the data for normality before
proceeding with the use of control charts. Ryan* suggests a minimum of 50 analyses
before an attempt is made to establish control limits. However, for this analysis,
consider setting "temporary" limits after accumulating 20-30 analyses of the sample.
Include both prepared slides as well as bulk samples in your reference inventory.
Make certain that sample quantities are sufficient to last, and that the act of sampling
will not alter the composition of the reference sample.
Data on analytical variability can be obtained by having analysts repeat their analyses of
samples and also by having different analysts analyze the same samples.
3.3 Intel-laboratory Quality Control
The establishment and maintenance of an interlaboratory QC program is fundamental to
continued assurance that the data produced within the laboratory are of consistent high
quality. Intralaboratory programs may not be-as sensitive to accuracy and precision error,
.especially if the control charts (see Section 3.2.2) for all analysts in the laboratory indicate
small percent differences. A routine interlaboratory testing program will assist in the
detection of internal bias and analyses may be performed more frequently than proficiency
59
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testing. Arrangements should be made with at least two (preferably more) other laboratories
that conduct asbestos identification by PLM. Samples (the number of which is left to the
participating laboratories, but at least 4-10) representing the types of samples and matrices
routinely submitted to the lab for analysis should be exchanged with sufficient frequency to
determine intralaboratory bias. Both reference slides and bulk samples should be used.
Results of the interlaboratory testing program should be evaluated by each of the
participating laboratories and corrective actions, if needed, identified and .implemented.
Since quantitation problems are more pronounced at low concentrations (< 5%), it would be
prudent to include approximately 30-50% from this concentration range in the sample
selection process.
3.4 Performance Audits
Performance audits are independent quantitative assessments of laboratory performance.
These audits are similar to the interlaboratory QC programs established between several
laboratories, but with a much larger cohort (the EPA Asbestos Bulk Sample Analysis Quality
Assurance Program had as many as 1100 participating laboratories). Participation in this
type of program permitted assessment of performance through the use of "consensus" test
materials, and served to assist in assessing the bias relative to individual interlaboratory, as
well as intralaboratory programs. Caution should be exercised in the use of "consensus"
quantitation results, as they are likely to be significantly responsible for the propagation of
high bias in visual estimates. The current NIST/NVLAP9 for bulk asbestos laboratories
(PLM) does not use concensus quantitation results. Results are reported in weight percent
with a 95% tolerance interval. The American Industrial Hygiene Association (AIHA)10 also
conducts a proficiency testing program for bulk asbestos laboratories. Quantitation results
for this program are derived from analyses by two reference laboratories and PLM, XRD
and gravimetric analysis performed by Research Triangle Institute.
3.5 Systems Audits
Where performance audits are quantitative in nature, systems audits are qualitative.
Systems audits are assessments of the laboratory quality system as specified in the Laboratory
60
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Quality Assurance Manual. Such an audit might consist of an evaluation of some facet of the
QA Manual, or the audit may be larger in scope. For example, the auditor might request
specific laboratory data sheets which will be evaluated against written procedures for data
recording in the laboratory. Or, the auditor might request air monitoring or contamination
control data to review for frequency of sampling, analysis methodology, and/or corrective
actions taken when problems were discovered. The audit report should reflect the nature of
the audit as well as the audit results. Any recommendations for improvement should also be
reflected in such a report.
3.6 References
1. Quality Assurance for Air Pollution Measurement Systems. Volume I,
Principles. EPA-600/9-76-005, March, 1976.
2. Juran, J. and F. Gryna, Quality Planning Analysis, 2nd edition, McGraw-Hill,
Inc., 1980.
3. Taylor, J.R., Quality Control Systems, McGraw Hill, Inc., 1989.
4. Ratliff, T.A., The Laboratory Quality Assurance System, Van Nostrand Reinhold,
1990.
5. Taylor, J.K., Quality Assurance of Chemical Measurements, Lewis Publishers,
1987.
6. Bulk Asbestos Handbook, National Institute of Standards and Technology, National
Voluntary Laboratory Accreditation Program, NISTIR 88-3879. October 1988.
7. Harvey, B.W., "Classification and Identification Error Tendencies in Bulk Insulation
Proficiency Testing Materials," American Environmental Laboratory, 2(2), 4/90,
pp. 8-14.
8. Ryan, T.P., Statistical Techniques for Quality Improvement, John Wiley & Sons,
Inc., New York, 1989.
9. National Institute of Standards & Technology (NIST) National Voluntary Laboratory
Accreditation Program (NVLAP), Building 411, Room A124, Gaithersburg, MD
20899, telephone (301) 975-4016.
10 American Industrial Hygiene Association (AIHA), 2700 Prosperity Avenue, Suite
250, Fairfax, VA 22031, (703) 849-P"
61
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APPENDIX A
Glossary Of Terms
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APPENDIX A. GLOSSARY OF TERMS
Accuracy - The degree of agreement of a measured value with the true or expected value.
Anisotropic - Refers to substances that have more than one refractive index (e.g. are
birefringent), such as nonisometric crystals, oriented polymers, or strained isotropic
substances.
Asbestiform (morphology) - Said of a mineral that is like asbestos, i.e., crystallized with the
habit of asbestos. Some asbestiform minerals may lack the properties which make
asbestos commercially valuable, such as long fiber length and high tensile strength.
With the light microscope, the asbestiform habit is generally recognized by the
following characteristics:
Mean aspect ratios ranging from 20:1 to 100:1 or higher for fibers longer than
5/im. Aspect ratios should be determined for fibers, not bundles.
Very thin fibrils, usually less than 0.5 micrometers in width, and
Two or more of the following:
- Parallel fibers occurring in bundles,
- Fiber bundles displaying splayed ends,
- Matted masses of individual fibers, and/or
- Fibers showing curvature
These characteristics refer to the population of fibers as observed in a bulk sample.
It is not unusual to observe occasional particles having aspect ratios of 10:1 or less,
but it is unlikely that the asbestos component(s) would be dominated by particles
(individual fibers) having aspect ratios of <20:1 for fibers longer than 5/tm. If a
sample contains a fibrous component of which most of the fibers have aspect ratios of
< 20:1 and that do not display the additional asbestiform characteristics, by definition
the component should not be considered asbestos.
Asbestos - A commercial term applied to the asbestiform varieties of six different minerals.
The asbestos types are chrysotile (asbestiform serpentine), amosite (asbestiform
grunerite), crocidolite (asbestiform riebeckite), and asbestiform anthophyllite,
asbestiform tremolite, and asbestiform actinolite. The properties of asbestos that
caused it to be widely used commercially are: 1) its ability to be separated into long,
thin flexible fibers; 2) high tensile strength; 3) low thermal and electrical
conductivity; 4) high mechanical and chemical durability, and 5) high heat resistance.
A-l
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Becke Line - A band of light seen at the periphery of a specimen when the refractive indices
of the specimen and the mounting medium are different; it is used 'to determine
refractive index.
Bias - A systematic error characterized by a consistent (non-random) measurement error.
Binder - With reference to a bulk sample, a component added for cohesiveness (e.g.
plaster, cement, glue, etc.).
Birefringence - The numerical difference between the maximum and minimum refractive
indices of an anisotropic substance. Birefringence may be estimated, using a
Michel-Levy chart, from the interference colors observed under crossed polarizers.
Interference colors are also dependent on the orientation and thickness of the grain,
and therefore are used qualitatively to determine placement in one of the four
categories listed below.
Qualitative OuantitativefN-n)
none 0.00 or isotropic
low < 0.010
moderate 0.011-0.050
high > 0.050
Bulk Sample - A sample of building material taken for identification and quantitation of
asbestos. Bulk building materials may include a wide variety of friable and
nonfriable materials.
Bundle - Asbestos structure consisting of several fibers having a common axis of elongation.
Calibration Materials - Materials, such as known weight % standards, that assist in the
calibration of microscopists in terms of ability to quantitate the asbestos content of
bulk materials.
Color - The color of a particle or fiber when observed in plane polarized light.
Compensator - A device with known, fixed or variable retardation and vibration direction
used for determining the degree of retardation (hence the thickness or value of
birefringence) in an anisotropic specimen. It is also used to determine the sign of
elongation of elongated materials. The most common compensator is the first-order
red plate (530-550nm retardation). -
Control Chart - A graphical plot of test results with respect to time or sequence of
measurement, together with limits within which they are expected to lie when the
system is in a state of statistical control.
A-2
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Detection Limit - The smallest concentration/amount of some component of interest that
can be measured by a single measurement with a stated level of confidence.
Dispersion Staining (focal masking) - An optical means of imparting apparent or virtual
color to transparent substances by the use of stops in the objective back focal plane; ir
it is used to determine refractive indices.
Error - Difference between the true or expected value and the measured value of a quantity
or parameter.
Extinction - The condition in which an anisotropic substance appears dark when observed
between crossed polars. This occurs when the vibration directions in the specimen
are parallel to the vibration directions in the polarizer and analyzer. Extinction may
be complete or incomplete; common types include parallel, oblique, symmetrical and
undulose.
Extinction Angle - For fibers, the angle between the extinction position and the position at
which the fiber is parallel to the polarizer or analyzer privileged directions.
Fiber - With reference to asbestiform morphology, a structure consisting of one or more
fibrils.
Fibril - The individual unit structure of fibers.
Friable - Refers to the cohesiveness of a bulk material, indicating that it may be crumbled
or disaggregated by hand pressure.
Gravimetry - Any technique in which the concentration of a component is determined by
weighing. As used in this document, it refers to measurement of asbestos-containing
residues after sample treatment by ashing, dissolution, etc.
Homogeneous - Uniform in composition and distribution of all components of a material,
such that multiple subsamples taken for analysis will contain the same components in
approximately the same relative concentrations.
Heterogeneous - Lacking uniformity in composition and/or distribution of material;
components not uniform. Does not satisfy the conditions stated for homogenous;
e.g., layered or in clnmps, very coarse grained, etc.
Isotropic - Refers to substances that have a single refractive index such as unstrained
glass, un-oriented polymers and unstrained substances in the isometric crystal system.
A-3
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Lamda Zero (XJ - The wavelength (X«) of the dispersion staining color shown by a
specimen in a medium; both the specimen and medium have the same refractive index
at that wavelength.
Matrix - Nonasbestos, nonbinder components of a bulk material. Includes such
components as cellulose, fiberglass, mineral wool, mica, etc.
Michel-Levy Scale of Retardation colors - A chart plotting the relationship between
birefringence, retardation and thickness of anisotropic substances. Any one of the
three variables can be determined if the other two are known.
Morphology - The structure and shape of a particle. Characterization may be descriptive
(platy, rod-like, acicular, etc) or in terms of dimensions such as length and diameter
(see asbestiform).
Pleochroism - The change in color or hue of colored anisotropic substance when rotated
relative to the vibration direction of plane polarized light.
Point Counting - A technique used to determine the relative projected areas occupied by
separate components in a microscope slide preparation of a sample. For asbestos
analysis, this technique is used to determine the relative concentrations of asbestos
minerals to nonasbestos sample components.
Polarization Colors - Interference colors displayed by anisotropic substances between two
. polarizers. Birefringence, thickness and orientation of the material affect the colors
and their intensity.
Precision The degree of mutual agreement characteristic of independent measurements as
the result of repeated application of the process under specified conditions. It is
concerned with the variability of results.
Reference Materials - Bulk materials, both asbestos-containing and nonasbestos-
containing, for which the components are well-documented as to identification and
quantitation.
Refractive Index (index of refraction) - The ratio of the velocity of light in a vacuum
relative to the velocity of light in a medium. It is expressed as n and varies with
wavelength and temperature.
Sign of Elongation - Referring to the location of the high and low refractive indices in an
elongated anisotropic substance, a specimen is described as positive when the higher
refractive index is lengthwise (length slow), and as negative when the lower refractive
index is lengthwise (length fast).
A-4
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Standard Reference Material (SRM) - A reference material certified and distributed by the
National Institute of Standards and Technology-
Visual Estimate - An estimation of concentration of asbestos in a sample as compared to the
other sample components. This may be a volume estimate made during
stereomicroscopic examination and/or a projected area estimation made during
microscopic (PLM) examination.
A-5
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APPENDIX B
Apparatus For Sample Preparation And Analysis
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Bl.O INTRODUCTION
The following lists the apparatus and materials required and suggested for the methods of
sample preparation and analysis described in the test method.l-2-3
B2.0 STEREOMICROSCOPIC EXAMINATION
The following are suggested for routine stereomicroscopic examination.
HEPA-Filtered hood or class 1 biohazard hood, negative pressure
Microscope: binocular microscope, preferably stereoscopic, 5-60X magnification
(approximate)
Light source: incandescent or fluorescent
Tweezers, dissecting needles, scalpels, probes, etc. (for sample manipulation)
Glassine paper, glass plates, weigh boats, petri dishes, watchglasses, etc. (sample
containers)
The following are suggested for sample preparation.
Mortar and pestle, silica or porcelain-glazed
Analytical balance (readability less than or equal to one milligram) (optional)
Mill or blender (optional)
B3.0 POLARIZED LIGHT MICROSCOPY
The laboratory should be equipped with a polarized light microscope (preferably capable
of Kohler or Kohler-type illumination if possible) and accessories as described below.
Ocular(s) binocular or monocular with cross hair reticle, or functional equivalent, and
a magnification of at least 8X
10X, 20X, and 40X objectives, (or similar magnification)
B-l
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Light source (with optional blue "day-light" filter)
360-degree rotatable stage
Substage condenser with iris diaphragm
Polarizer and analyzer which can be placed at 90 degrees to one another, and can be
calibrated relative to the cross-line reticle in the ocular.
Accessory slot for wave plates and compensators (or demonstrated equivalent).
Wave retardation plate (Red I compensator) with approximately 550 nanometer
retardation, and with known slow and fast vibration directions.
Dispersion staining objective or a demonstrated equivalent, (optional)
Monochromatic filter (nD), or functional equivalent, (optional)
In addition, the following equipment, materials and reagents are required or
recommended.'
NIST traceable standards for the major asbestos types (NIST SRM 1866 and 1867)
Class I biohazard hood or better (see "Note", Section 2.2.5)
Sampling utensils (razor knives, forceps, probe needles, etc.)
Microscope slides and cover slips
Mechanical Stage
Point Counting Stage (optional)
Refractive index liquids: 1.490-1.570, 1.590-1.720 in increments of less than or equal
to 0.005; high dispersion, (HD) liquids are optional; however, if using dispersion
staining, HD liquids are recommended.
Mortar and pestle
Distilled water
HC1, ACS reagent grade concentrated
B-2
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Muffle furnace (optional)
Mill or blender (optional)
Beakers and assorted glassware (optional)
Other reagents (tetrahydrofuran, amyl acetate, acetone, sodium hexametaphosphate,
etc.) (optional)
B4.0 GRAVEV1ETRY
The following equipment, materials, and reagents are suggested.
Scalpels
Crucibles, silica or porcelain-glazed, with lids
Muffle furnace - temperature range at least to 500°C, temperature stable to +. 10°C,
temperature at sample position calibrated to +. 10°C
Filters, 0.4 fim pore size polycarbonate
Petri dishes
Glass filtration assembly, including vacuum flask, water aspirator, and/or air pump
Analytical balance, readable to 0.001 gram
Mortar and pestle, silica or porcelain-glazed
Heat lamp or slide warmer
Beakers and assorted glassware
Centrifuge, bench-top
Class I biohazard hood or better
Bulb pipettes
Distilled water
HC1, reagent-grade concentrated
B-3
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Organic solvents (tetrahydrofuran, amyl acetate,etc)
Ultrasonic bath
BS.O X-RAY DIFFRACTION
Sample Preparation
Sample preparation apparatus requirements will depend upon the sample type under
consideration and the kind of XRD analysis to be performed.
Mortar and pestle: agate or porcelain
Razor blades
Sample mill: SPEX, Inc., freezer mill or equivalent
Bulk sample holders
Silver membrane filters: 25-mm diameter, 0.45-^m pore size. Selas Corp. of
America, Flotronics Div., 1957 Pioneer Road, Huntington Valley, PA 19006
Microscope slides
Vacuum filtration apparatus: Gelman No. 1107 or equivalent, the side-arm vacuum
flask
Microbalance
« Ultrasonic bath or probe: Model WHO, Ultrasonics, Inc., operated at a power
density of approximately 0.1 W/mL, or equivalent
Volumetric flasks: 1-L volume
Assorted pipets
Pipet bulb
Nonserrated forceps
Polyethylene wash bottle
Pyrex beakers: 50-mL volume
B-4
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Desiccator
Filter storage cassettes
Magnetic stirring plate and bars
Porcelain crucibles
Muffle furnace or low temperature asher
Class 1 biohazard hood or better
Sample Analysis
Sample analysis requirements include an x-ray diffraction unit, equipped with:
Constant potential generator; voltage and mA stabilizers
Automated diffractometer with step-scanning mode
Copper target x-ray tube: high intensity; fine focus, preferably
X-ray pulse height selector
X-ray detector (with high voltage power supply): scintillation or proportional counter
Focusing graphite crystal mbnochromator; or nickel filter (if copper source is used,
and iron fluorescence is not a serious problem)
Data output accessories:
- Strip chart recorder
- Decade sealer/timer
- Digital printer
or
- PC, appropriate software and Laser Jet Printer
Sample spinner (optional)
Instrument calibration reference specimen: a-quartz reference crystal (Arkansas
quartz standard, #180-147-00, Philips Electronics Instruments, Inc., 85 McKee Drive,
Mahwah, NJ 07430) or equivalent.
B-5
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Reagents, etc.
Reference Materials - The list of reference materials below is intended to serve as a guide.
Every attempt should be made to acquire pure reference materials that are comparable to
sample materials being analyzed.
Chrysotile: UICC Canadian, NIST SRM 1866 (UICC reference material available
from: UICC, MRC Pneumoconiosis Unit, Llandough Hospital, Penarth, Glamorgan,
CF61XW, UK); (NIST Standard Reference Materials available from the National
Institute of Standards and Technology, Office of Reference Standards, Gaithersburg,
MD 20899)
Crocidolite: UICC, NIST SRM 1866.
"Amosite": UICC, NIST SRM 1866.
Anthophyllite-Asbestos: UICC, NIST SRM 1867
Tremolite Asbestos: Wards Natural Science Establishment, Rochester, NY; Cyprus
Research Standard, Cyprus Research, 2435 Military Ave., Los Angeles, CA 900064
(washed with dilute HC1 to remove small amount of calcite impurity); Indian
tremolite, Rajasthan State, India; NIST SRM 1867.
" Actinolite Asbestos: NIST SRM 1867
Adhesive - Tape, petroleum jelly, etc. (for attaching silver membrane filters to sample
holders).
Surfactant - 1 Percent aerosol OT aqueous solution or equivalent.
Isopropanol - ACS Reagent Grade.
B6.0 ANALYTICAL ELECTRON MICROSCOPY
AEM equipment requirements will not be discussed in this document; it is suggested that
equipment requirements stated in the AHERA regulations be followed. Additional
information may be found in the NVLAP Program Handbook for Airborne Asbestos
Analysis.3
B-6
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The following additional materials and equipment are suggested:
Analytical balance, readable to 0.001 gram
Ultrasonic bath
Glass filtration assembly (25mm), including vacuum flask and water aspirator
Mixed cellulose ester (MCE) filters (0.22^im pore size) or 0.2/zm pore size
polycarbonate filters
MCE backing filters (5^m pore size)
Silica mortar and pestle
Beakers - glass and disposable
Pipettes, disposable, 1,5, and 10 ml
B7.0 REFERENCES
1. National Institute of Standards and Technology (NIST) National Voluntary Laboratory
Accreditation Program (NVLAP) Bulk Asbestos Handbook, NISTIR 88-3879, 1988.
2. Interim Method for the Determination of Asbestos in Bulk Insulation Samples,
U.S. E.P.A. 600/M4-82-020, 1982.
3. National Institute of Standards and Technology (NIST) National Voluntary Laboratory
Accreditation Program (NVLAP) Program Handbook for Airborne Asbestos Analysis,
NISTIR 89-4137, 1989.
B-7
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APPENDIX C
Preparation and Use of Bulk Asbestos
Calibration Standards
-------
Cl.O INTRODUCTION
Evaluation of the results from national proficiency testing programs for laboratories
analyzing for asbestos in bulk materials indicates that laboratories have had, and continue to
have, problems with quantitation of asbestos content, especially with samples having a low
asbestos concentration.1 For such samples, the mean value of asbestos content reported by
laboratories may be four to ten times the true weight percent value. It is assumed that the
majority of the laboratories quantify asbestos content by visual estimation, either
stereomicroscopically or microscopically; therefore, the problem of quantitation must be
attributed to lack of or inadequate calibration of microscopists.
As calibration standards for asbestos-containing bulk materials are not currently
commercially available, laboratories should consider generating their own calibration
materials. This may be done rather easily and inexpensively.
C2.0 MATERIALS AND APPARATUS
Relatively pure samples of asbestos minerals should be obtained. Chrysotile, amosite and
crocidolite (SRM 1866) and anthophyllite, tremolite and actinolite (SRM 1867) are available
from MIST. A variety of matrix materials are commercially available; included are calcium
carbonate, perlite, vermiculite, mineral wool/fiberglass, and cellulose. Equipment, and
materials needed to prepare calibration bulk materials are listed below.
Analytical balance, readable to 0.001 gram
Blender/mixer; multi-speed, - one quart capacity
Filtration assembly, including vacuum flask, water aspirator and/or air pump
(optional)
HEPA-filtered hood with negative pressure
Filters, 0. Vm pore size polycarbonate (optional)
Beakers and assorted glassware, weigh boats, petri dishes, etc.
Hot/warm plate
C-l
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Asbestos minerals
Matrix materials
Distilled water.
C3.0 MATERIAL FORMULATION PROCEDURES
The formulation procedure involves first weighing appropriate quantities of asbestos and
matrix material to give the desired asbestos weight percent. The following formula may be
used to determine the weights of asbestos and matrix materials needed to give a desired
weight percent asbestos.
WTa =WTrn
Wa ~Wm
Where:
WTa = weight of asbestos in grams (to 0.001 gram)
WTm = weight of matrix materials in grams (to 0.001 gram)
Wa = weight percent asbestos
Wm = weight percent matrix
Example: The desired total weight for the calibration sample is 10 grams containing 5 %
asbestos by weight. If 0.532 grams of asbestos are first weighed out, what corresponding
weight of matrix material is required?
WTa = 0.532 grams
Wa = 5% Q|32=w:rm
Wm =95% ^^ wTm = 10.108 grams
The matrix is then placed into the pitcher of a standard over-the-counter blender, the
pitcher being previously filled to approximately one-fourth capacity (8-10 ounces) with
distilled water. Blending is performed at the lowest speed setting for approximately ten
seconds which serves to disaggregate the matrix material. The asbestos is then added, with
additional blending of approximately 30 seconds, again at the lowest speed setting. Caution
should be taken not to overblend the asbestos-matrix mixture. This could result in a
- significant reduction in the size of the asbestos fibers causing a problem with detection at
normal magnification during stereomicroscopic and microscopic analyses. Ingredients of the
C-2
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pitcher are then poured into a filtering apparatus, with thorough rinsing of the pitcher to
ensure complete material removal. After filtering, the material is transferred to a foil dish
which is placed on a hot plate. The material is covered and allowed to sit over low heat
until drying is complete; intermittent stirring will speed the drying process. For fine-grained
matrix materials such as gypsum, calcium carbonate, clays, etc., the sample is not filtered
after the blending process. Instead, the ingredients in the pitcher are transferred into a series
of shallow, glass (petri) dishes. The ingredients should be stirred well between each
pouring to minimize the possible settling (and over-representation) of some components. The
dishes are covered and placed on a hot plate until the contents are thoroughly dried. For
small quantities of any matrix materials (15 grams or less), air-drying without prior filtering
is generally very suitable for removing water from the prepared sample. For each material,
the final step involves placing all formulated, dried subsamples into a plastic bag (or into one
petri dish, for small quantities), where brief hand-mixing will provide additional blending and
help to break up any clumps produced during drying. AH operations should be performed
in a safety-hood with negative pressure.
C4.0 ANALYSIS OF MATERIALS
All formulations should be examined with the stereomicroscope to determine
homogeneity. Gravimetric analysis (ashing and/or acid dissolution) should be performed on
those materials containing organic and/or acid-soluble components. Matrix materials to
which no asbestos has been added should be analyzed by gravimetric analysis to determine
the amount of nonashable or insoluble materials that are present. Several subsamples of each
material should be analyzed by the gravimetric technique to provide information concerning
the uniformity of the prepared materials. Experience has shown that the previously described
formulation procedure results in relatively homogeneous materials.2
C4.1 Stereomicroscopic Analysis
Visual estimation of sample components using the stereomicroscope is in reality a
comparison of the relative volumes of the components.3 Therefore, differences in specific
gravity between asbestos and matrix material must be considered and the relationship
C-3
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between weight percent and volume percent must be determined.4 Materials such as
expanded vermiculite, perlite, and cellulose have specific gravities significantly lower than
asbestos minerals. Table Cl lists the specific gravities for the three most commonly
encountered asbestos varieties and several common matrix materials.
TABLE Cl. SPECIFIC GRAVITIES OF ASBESTOS VARIETIES
AND MATRIX MATERIALS
Asbestos Type
Chrysotile
Amosite
Crocidolite
Specific Gravity
2.6
3.2
3.3
Matrix Type
Calcium Carbonate
Gypsum
Perlite
Vermiculite
(expanded)
Mineral Wool
Fiberglass
Cellulose
Specific Gravity
2.7
2.3
-0.4
-0.3
-2.5
-2.5
-0.9
The conversion of weight percent asbestos to equivalent volume percent asbestos is given
by the following formula:
Wa
Ga
Wa + Wm
Ga Gm
x 100 = Va
where:
Wa
Ga
Wm
Gm
Va
weight percent asbestos
specific gravity of asbestos
weight percent matrix
specific gravity of matrix
volume percent asbestos
C-4
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Example: Chrysotile and perlite have been combined to form a 5% asbestos
calibration standard, by weight. What is the equivalent volume
percent asbestos?
Wa = 5% _5_
Ga = 2.6 .. 2.6 x 100 = 0.8%
Va = -
Wm = 95% a _5_ + 95
Gm = 0.4 2.6 0.4
Conversely, to convert volume percent asbestos to equivalent weight percent, the
following formula may be used.
x 100 = Wa
(Va)(Ga) + (Vm)(Gm)
Vm = volume percent matrix
Example: A calibration standard consisting of amosite and cellulose is
estimated to contain 2% asbestos, by volume. What is the
equivalent weight percent asbestos?
Va = 2% (2X3.2) x 100 = 6.77%
Ga = 3.2 (2)(3.2) + (98)(0.9)
Vm = 98%
Gm = 0.9
Volume percentages should be calculated for all calibration materials prepared so that
visual estimates determined by examination with the stereomicroscope may be compared to
true volume concentrations.
Figure Cl illustrates the relationship between volume percent and weight percent of
chrysotile mixed with vermiculite and cellulose respectively. It should be noted that when
asbestos in a low weight percentage is mixed with matrix materials having low specific
gravities (vermiculite, perlite), the resulting volume concentration of asbestos is very low.
For example, a mixture containing three percent chrysotile by weight in a cellulose matrix
would result in a volume percent asbestos of approximately 1 . 1 %; in a vermiculite matrix,
the resulting volume percent asbestos would be approximately 0.4%. In the latter case
especially, an analyst might possibly fail to detect the asbestos or consider it to be present in
only trace amounts.
C-5
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40
S
o
M.
JS
w
20
10
X
X
X
X
.*
X
- « with vermiculite
»-*-* « with cellulose
4 6
Volume % Chrysotile
10
Figure Cl. Relationship between volume % and weight % of chrysotile mixed with
a)vermiculite and b) cellulose.
C-6
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C4.2 Microscopical Analysis (PLM)
The polarized light microscope may be used to quantify asbestos and other components of
a sample. Slide mounts are prepared from "pinch" samples of the calibration material and
asbestos content is determined by visual area estimate and/or point counting. Both of these
quantitation techniques are in fact estimates or measurements of the relative projected areas
of particles as viewed in two dimensions on a microscope slide. For quantitation results to
be meaningful, the following conditions should be met:
The sample should be homogeneous for slide preparations, which are made from
small pinches of the sample, to be representative of the total sample.
Slide preparation should have an even distribution of particles and approach a one
particle thickness (seldom achieved) to avoid particle overlap.
All materials used should be identified and specific gravities determined in order to
relate area percent to volume and/or weight percent.
The size (thickness) relationship between matrix particles and asbestos fibers should
be determined if the results based on projected area are to be related to volume and/or
weight percent.
Particle characteristics can greatly affect the quantitation results obtained by visual area
estimation or point counting. Figure C2 illustrates three hypothetical particle shapes of
identical length and width (as viewed from above). Although the three-dimensional shape is
different, the projected area is equal for all particles. The table accompanying Figure C2
presents data for each particle in terms of thickness, volume and projected area. It should be
noted that although the -projected areas may be equal, the volumes represented by the
particles may vary by a factor of 20(0.8 vs 16 cubic units). It is obvious that quantitation of
a sample consisting of a mixture of particles with widely ranging particle thicknesses could
result in different results. For example, if a sample contained relatively thick bundles of
asbestos and a fine-grained matrix such as clay or calcium carbonate, the true asbestos
content (by volume) would likely be underestimated. Conversely, if a sample contained thick
"books" of mica and thin bundles of asbestos, the asbestos content (by volume) would likely
be overestimated.
C-7
-------
0.1 unit
thick
As Viewed
Particle
A
B
C
Thickness
0.1 units
2 units
2 units
Volume
0.8 cubic units
12.6 cubic units
16 cubic units
Projected Area
8 sq. units
8 sq. units
8 sq. units
Note that although all particles have the same projected area,
particle C volume is 20x that of particle A.
Figure C2. Relationship of projected area to volume and thickness for three different particles
as viewed on a slide mount.
C-8
-------
Table C2 illustrates several examples of expected results from area estimates or point
counting of samples in which the asbestos fibers and matrix particles differ in thickness.
TABLE C2. RELATIONSHIP OF WEIGHT PERCENT, VOLUME PERCENT AND
PARTICLE THICKNESS TO QUANTITATION RESULTS
Composition of
Sample In Wt. %
1% Amosite
99% Calcium Carbonate
1% Amosite
99% Calcium Carbonate
1% Amosite
99% Calcium Carbonate
1% Amosite
99% Vermiculite
1% Amosite
99% Vermiculite
1% Amosite
99% Vermiculite
1% Amosite
99% Vermiculite
Theoretical Vol.
% Asbestos
0.9
0.9
0.9
0.1
0.1
0.1
0.1
Thickness Factor*
(Matrix/Asbestos)
0.5
1
2
1
10
20
30
Expected Area %
0.4
0.9
1.8
0.1
1.0
2.0 .
2.9
Value represents the relationship between the mean thickness of the matrix particles
compared to the mean thickness of the asbestos particles.
It should be noted that it is not uncommon for matrix particle thickness to differ greatly
from asbestos fiber thickness, especially with matrix materials such as vermiculite and
perlite; vermiculite and perlite particles may be 20 - 30 times as thick as the asbestos fibers.
The general size relationships between matrix particles and asbestos fibers may be
determined by scanning slide mounts of a sample. A micrometer ocular enables the
microscopist to actually measure particle sizes.
C-9
-------
If a thickness factor can be determined for a calibration sample of known volume
proportions of asbestos and matrix materials, an expected equivalent projected area asbestos
can be calculated using the following formula:
Va
where:
Va
Vm
T
Aa
x 100 = Aa
Vm + Va
T
true volume percent asbestos
true volume percent matrix
thickness factor (mean size matrix particle/mean size asbestos fiber)
expected projected area percent asbestos
Example:
Va
Vm
T
A calibration standard of known weight percent asbestos is
determined, by factoring in component specific gravities, to be
5.0% asbestos by volume. The matrix particles are estimated to
be ten times thicker than the asbestos fibers. What would be the
expected projected area percentage of asbestos?
5%
95%
10
Aa =
x 100 = 34.5%
25
10
Conversely, to convert projected area percent asbestos to equivalent volume percent,
the following formula may be used:
Aa
x 100 = Va
T(Am) + Aa
Where: Am = projected area matrix
Example:
A slide containing a subsample of an amosite/mineral wool
calibration standard is determined by point counting to have a
projected area asbestos of 18.6%. If the mineral wool fibers are
estimated to be six times the asbestos fibers, in diameter, what
is the equivalent volume percent asbestos?
C-10
-------
Am = 81.4%
Aa = 18.6% (18.6) x 100 = 3.67%
T = 6 6(81.4) + 18.6
Based on specific gravity values listed in Table 1C and on the
above volume asbestos determination, what is the equivalent
weight percent asbestos in the sample?
Va = 3.67% ... (3.67H3.2) x 100 = 4.7%
\A/O . -^ * -* *- *
Ga = 3.2 (3.67)(3.2) + (96.33)(2.5)
Vm = 96.33%
Gm = 2.5
C5.0 USE OF CALIBRATION STANDARDS FOR QA/QC
Once the materials have been formulated and thoroughly characterized by all techniques
to determine their suitability as calibration standards, a system for incorporating them into
the QA/QC program should be established. Someone should be designated (QA officer, lab
supervisor, etc.) to control the distribution of standards and to monitor the analysis results of
the microscopists. Both precision and accuracy may be monitored with the use of suitable
standard sets.
Records such as range charts, control charts, etc. may be maintained for volume
(stereomicroscopic estimates), area (PLM) estimates and point counts. For point counts and
area estimates, relatively permanent slides may be made using epoxy or Melt Mount *. Such
slides may be very accurately quantified over time as to point count values, and due to their
very long shelf life, may be used for QA/QC purposes almost indefinitely.
C6.0 REFERENCES
1. "Analysis Summaries for Samples used in NIST Proficiency Testing", National
Institute of Standards and Technology (NIST) National Voluntary Laboratory
Accreditation Program (NVLAP) for Bulk Asbestos, January 1989 to present.
2. Harvey, B. W., R. L. Perkins, J. G. Nickerson, A. J. Newland and M. E. Beard,
"Formulating Bulk Asbestos Standards", Asbestos Issues, April 1991.
3. Perkins, R. L. and M. E. Beard, "Estimating Asbestos Content of Bulk Materials",
National Asbestos Council Journal, Vol. 9, No. 1, 1991, pp. 27-31.
4. Asbestos Content in Bulk Insulation Samples: Visual Estimates and Weight
Composition, U.S. Environmental Protection Agency 560/5-88-011, 1988.
C-ll
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APPENDIX D
Special-Case Building Materials
-------
Asbestos laboratories are now called upon to analyze many types of bulk building
materials that are very difficult to characterize by routine PLM analysis. These materials are
dominantly nonfriable and can be grouped into ihe following categories:
Cementitious Products (pipe, sheeting, etc.)
Viscous Matrix Products (adhesives, cements, coatings, etc.)
Vinyl Materials (vinyl floor tile, sheeting)
Asphaltic Roofing Materials (shingles, roll, roofing)
Miscellaneous Products (paints, coatings, friction plates, gaskets, etc.)
Materials characterized by interfering binder/matrix, low asbestos content, and/or small
fiber size may require that additional sample treatment(s) and analysis be performed beyond
routine PLM analysis. The sample treatment(s) required is(are) determined by the dominant
nonasbestos sample components (see Section 2.3, Gravimetry). Materials containing an
appreciable amount of calcareous material may be treated by dissolution with hydrochloric
acid. Samples containing organic binders such as vinyl, plasticizers, esters, asphalts, etc.
can be treated with organic solvents or ashed in a muffle furnace (preferred method) or low
temperature plasma asher to remove unwanted components. Materials containing cellulose,
synthetic organic fibers, textiles, etc. may also be ashed in a muffle furnace or low
temperature plasma asher.
The method chosen for analysis of a sample after treatment is dependent on asbestos
concentration and/or fiber size. An examination of the sample residue by PLM may disclose
asbestos if the fibers are large enough to be resolved by the microscope, but additional
analytical methods are required if the sample appears negative. Analysis by XRD is not
fiber-size dependent, but may be limited by low concentration of asbestos and the presence of
interfering mineral phases. In addition, the XRD method does not differentiate between
-fibrous and nonfibrous varieties of a mineral. Analysis by AEM is capable of providing
positive identification of asbestos type(s) and semi-quantitation of asbestos content.
D-l
-------
The following flowchart illustrates a possible scheme for the analysis of special-case
building materials.
NOTE: Preliminary studies indicate that the XRD method is capable of detecting
serpentine (chrysotile) in floor tile samples without extensive sample preparation prior to
XRD analysis. XRD analysis of small, intact sections of floor tile yielded diffraction
patterns that confirmed the presence of serpentine, even at concentrations of -one percent
by weight. TEM analysis of these same tiles confirmed the presence of chrysotile asbestos.
With further investigation, this method may prove applicable to other types of nonfriable
materials.
D-2
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FLOWCHART FOR QUALITATIVE ANALYSIS OF SPECIAL CASE BUILDING
MATERIALS SUCH AS FLOOR TILES, ASPHALTIC MATERIALS, VISCOUS
MATRIX MATERIALS, ETC.*
BULK SAMPLE
STEREOMICROSCOPIC/PLM ANALYSIS
SAMPLE IS EXAMINED FIRST WITH A
STEREOMICROSCOPE
FOLLOWED BY EXAMINATION WITH PLM
ACM
(Asbestoi it confirmed at
concentration >1\ - considered ACH)
NON ACM
(Asbestos not detected or detected at
trace level - non ACH by PLH)
Confirmatory analysis by alternative
analytical method* (XRD and/or AEK)
considered necessary
ACM
CKAVXKETKY
Gravimetric methods used to remove
interferentsi residue ray be
analyzed by PLH
/\
NON-ACK
AEH
ACH
ample residue analyzed
XRO and/or AIM
ACK
\
by
NON-ACK
AEH
ACK
Although this flowchart is applicable to all bulk materials, it is primarily intended to be used
with known problem materials that are difficult to analyze by PLM due to low asbestos concentration,
nd/or small fiber size, and/or interfering binder/matrix. In addition to being qualitative, the
results may also be semi-quantitative. It should not be assumed that all samples need to be
analyzed by ACH and XKD. The flowchart simply illustrates options for methods of analysis.
Alternate methods such as SEM may be applicable to some bulk materials.
U.S COVWNMEVT HUNTING OFRCl U)3 -750 -002/«OZ37
D-3
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ITEM 2
Asbestos/NESHAP Regulated Asbestos Containing Material
-------
United States
Environmental Protection -
Agency .
EPA 340/1-90-018
December 1990 -
Asbestos/NESHAR«
Regulated Asbestos^
Containing Materials
Guidance!
I
'**:. v»\
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EPA 340/1-90-018
ASBESTOS NESHAP
REGULATED ASBESTOS CONTAINING
MATERIALS GUIDANCE
ILS. ENVIRONMENTAL PROTECTION AGENCY
Office of Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
December, 1990
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CONTENTS
Section Page
1. INTRODUCTION .' 6
2. FRIABLE ASBESTOS-CONTAINING MATERIALS ... 8
3. NON-FRIABLE ASBESTOS-CONTAINING
MATERIALS 9
Category I Nonfriable ACM 10
Category H Nonfriable ACM 11
4. INSPECTION PROCEDURES TO DETERMINE
THE POTENTIAL FOR FIBER RELEASE
FROM NONFRIABLE ASBESTOS-
CONTAINING MATERIALS 13
Friability Determination Decision
Trees 14
General Inspection Procedures 16
Specific Inspection Procedures 17
Category I Nonfriable ACM 17
Category II Nonfriable ACM 19
APPENDICES
A Asbestos NESHAP Coordinators
(For Demolition/Renovation Activities) A-l
B Regional Asbestos Coordinators
(For Schools) B-l
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ACKNOWLEDGEMENTS
This document was written by Alliance Technologies, Inc.,
based on discussions with a work group from EPA. The group
consisted of the Regional Asbestos NESHAP Coordinators, Ron
Shafer, Scott Throwe, and Omayra Salgado of the Stationary Source
Compliance Division, Charles Garlow and Elise Hoerath of the Air
Enforcement Division and Sims Roy of the Standards Development
Branch. We thank the individuals who reviewed an earlier draft and
provided comments, many of which are incorporated in the final
version. Their input is gratefully acknowledged.
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1. INTRODUCTION
Section 112 of the Clean Air Act (CAA) requires EPA to develop
emission standards for hazardous air pollutants. In response to this
section the Environmental Protection Agency (EPA) published a list
of hazardous air pollutants and promulgated the "National Emission
Standards for Hazardous Air Pollutants" (NESHAP) regulations.
Since asbestos presents a significant risk to human health as a result
of air emissions from one or more source categories, it is therefore
considered a hazardous air pollutant The Asbestos NESHAP (40
CFR 61, Subpart M) addresses milling, manufacturing and
fabricating operations, demolition and renovation activities, waste
disposal issues, active and inactive waste disposal sites and asbestos
conversion processes.
In the initial Asbestos NESHAP rule promulgated in 1973, a
distinction was made between building materials mat would readily
release asbestos fibers when damaged or disturbed and those
materials that were unlikely to result in significant fiber release.. The
terms "friable" and "non-friable" were used to make this distinction.
EPA has since determined that, if severely damaged, otherwise
nonfriable materials can release significant amounts of asbestos
fibers.
Friable asbestos-containing material (ACM), is defined by the
Asbestos NESHAP, as any material containing more than 1 percent
asbestos as determined using the method specified in Appendix A,
Subpart F, 40 CFR Pan 763, Section 1, Polarized Light Microscopy
(PLM), mat, when dry, can be crumbled, pulverized or reduced to
powder by hand pressure. (Sec. 61.141)
Nonfriable ACM is any material containing more than 1 percent
asbestos as determined using the method specified in Appendix A,
Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy
-------
(PLM), that, when dry, cannot be crumbled, pulverized, or reduced
to powder by hand pressure. EPA also defines two categories of
nonfriable ACM, Category I and Category n nonfriable ACM, which
are described later in this guidance.
"Regulated Asbestos-Containing Material" (RACM) is (a) friable
asbestos material, (b) Category I nonfriable ACM that has become
friable, (c) Category I nonfriable ACM that will be or has been
subjected to sanding, grinding, cutting or abrading, or (d) Category n
nonfriable ACM that has a high probability of becoming or has
become crumbled, pulverized, or reduced to powder by the forces
expected to act on the material in the course of demolition or
renovation operations.
The purpose of this document is to assist asbestos inspectors and the
regulated community in determining whether or not a material is
RACM and thus subject to the Asbestos NESHAP.
The recommendations made in this guidance are solely
recommendations. They are not the exclusive means of complying
with the Asbestos NESHAP requirements. Following these
recommendations is not a guarantee against findings of violation.
The EPA intends for owners/operators to be reasonably certain
whether or not they are subject to the NESHAP. In the end, if a
question arises, determinations of whether asbestos containing
materials are regulated by the Asbestos NESHAP are made by EPA
inspectors on site.
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2. FRIABLE ASBESTOS CONTAINING-
MATERIALS
Due to their high tensile strength, incombustibility, corrosion and
friction resistance and other properties, such as acoustical and
thermal insulation abilities, asbestos fibers have been incorporated
into over 3600 commercial products. Thermal system, fireproofing
and acoustical insulation materials have been used extensively in the
construction industry.
Thermal system applications include steam or hot water pipe
coverings and thermal block insulation found on boilers and hot
water tanks. Fireproofing insulation may be found on building
structural beams and decking. Acoustical insulation (soundproofing)
commonly has been applied as a troweled-on plaster in school and
office building stairwells and hallways. Unfortunately, with time and
exposure to damaging forces (e.g., severe weather, chemicals,
mechanical forces, etc.), many asbestos- containing materials may
become crumbled, pulverized or reduced to powder, thereby releasing
asbestos fibers, or may deteriorate to the extent that they may release
fibers if disturbed. Since inhalation of asbestos fibers has been linked
to the development of respiratory and other dispasgs. any material
which is friable, or has a high probability of releasing fibers, must
be handled in accordance with the Asbestos NESHAP.
The following work practices should be followed whenever
demolition/renovation activities involving RACM occur
notify EPA of intention to demolish/renovate,
remove all RACM from a facility being demolished or
renovated before any disruptive activity begins or before
access to the material is precluded.
-------
keep RACM adequately wet before, during, and after
removal operation,
conduct demolition/renovation activities in a manner which
produces no visible emissions to the outside air, and
handle and dispose of all RACM in an approved manner.
3. NONFRIABLE ASBESTOS-CONTAINING
MATERIALS
Because of the resilient nature of asbestos, it is used in materials
exposed to a wide variety of stressful environments. These
environments can cause the deterioration of binding materials and
cause nonfriable materials to become friable. For example, asbestos-
containing packings and gaskets (Category I nonfriable ACM) used
in thermal systems may be found in poor condition as a result of the
heat they have encountered. In petrochemical handling facilities,
which may have miles of transfer pipes and fittings which contain
asbestos gaskets and/or packings, profound degradation of the ACM
may occur due to exposure to organic-based liquids and gases or to
corrosive agents used to chemically clean these lines.
When nonfriable ACM is subjected to intense mechanical forces,
such as those encountered during demolition or renovation, it can be
crumbled, pulverized, or reduced to powder, and thereby release
asbestos fibers. When nonfriable materials are damaged or are likely
to become damaged during such activities, they must be handled in
accordance with the Asbestos NESHAP.
There are two categories of nonfriable materials: Category I
Nonfriable ACM and Category H Nonfriable ACM.
-------
CATEGORY I NONFRIABLE ACM
Category I nonfriable ACM is any asbestos-containing packing,
gasket, resilient floor covering or asphalt roofing product which
contains more than 1 percent asbestos as determined using polarized
light microscopy (PLM) according to the method specified in
Appendix A, Subpart F, 40 CFR Part 763. (Sec. 61. 141)
Category I nonfriable ACM must be inspected and tested for
friability if it is in poor condition before demolition to determine
whether or not it is subject to the Asbestos NESHAP. If the ACM
is friable, it must be handled in accordance with the NESHAP.
Asbestos-containing packings, gaskets, resilient floor coverings and
asphalt roofing materials must be removed before demolition only if
they are in poor condition and are friable.
The Asbestos NESHAP further requires that if a facility is
demolished by intentional burning, all of the facility's ACM,
including Category I and D nonfriable ACM, be considered RACM
and be removed prior to burning (Sec. 61.145 (c)(10)). Additionally,
if Category I or Category H nonfriable ACM is to be sanded,
ground, cut, or abraded, the material is considered RACM and the
owner or operator must abide by the following (Sec. 61.145 (c)(l)):
(i) Adequately wet the material during the sanding, grinding,
cutting, or abrading operations.
(ii) Comply with the requirements of 61.145(c)(3)(i) if wetting
would unavoidably damage equipment or present a safety
hazard,
(iii) Handle asbestos material produced by the sanding, grinding,
cutting, or abrading, as asbestos-containing waste material
subject to the waste handling and collection provisions of
Section 61.150.
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CATEGORY n NONFRIABLE ACM
Category II nonfriable ACM is any material, excluding Category I
nonfriable ACM, containing more than 1 percent asbestos as
determined using polarized light microscopy according to the
methods specified in Appendix A, Subpart F, 40 CFR Pan 763 that,
when dry, cannot be crumbled, pulverized, or reduced to powder by
hand pressure. (Sec. 61.141)
Category E nonfriable ACMs (cement siding, transite board shingles,
etc.) subjected to intense weather conditions such as thunderstorms,
high winds or prolonged exposure to high heat and humidity may
become "weathered" to a point where they become friable. The
photograph in Figure 1 demonstrates a split asbestos shingle that has
become friable along the cracked edge.
The following table lists examples and other relevant information
about Category I and Category n nonfriable ACM.
Figure 1. Nonfriable asbestos shingle which has become
friable along the broken axis.
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TABLE 1. NONFRIABLE ASBESTOS PRODUCTS
SuMMaton Gwnric IMHM AifcMtot (%)
Cmwnttbus mtnnion pmb: portend canwnt
eonoraMk* products CBTupiM) 20-45 portend nnwnt
(C«»9oryll) IU1 40-50 podttnd ownwit
3040 pofMnd ecmwil
i pcrtoraM 30-50 ponttnd owrwnt
35-50 ponMnd c*nwn(
(OUMT surtac*)
ml Ms 2040 pontwid owncnt
cupboard 12-15 portknd ftmtnt
Mtng ihmgks 12-14 pMtfcnd annnt
nolng tfitngW 2042 portend ovmvnt
pip* 20-15 poruwid ovnwni
maeih wtaot 10-15
10-15
1
10
Ait»iP»-oonu«i«iu caukins puttM 3D
compound. dtaMM (crtd ippM) MS
ranlingwpMi S
C-25
1345
1045
2-10
to-ioo
06
IS
0
XI
»
*>
From EPA Guidance entitled Guidance for Controlling Asbestos-Containing Materials In
BuMings* (Purple Book). Append* A. Page A-1; EPA 560/545-024.
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Except for the following, Section 61.145(c) of the Asbestos
NESHAP requires that each owner or operator of a demolition or
renovation activity involving RACM remove all such material from a
facility being demolished or renovated before any activity begins that
would break up, dislodge, or similarly disturb the material or
preclude access to the material for subsequent removal.
ACM need not be removed before demolition if it:
(i) Is a Category I nonfriable ACM that is not friable.
(ii) Is on a facility component that is encased in
concrete or other similarly hard material and is
adequately wet whenever exposed during demolition.
(iii) Was not accessible for testing and therefore was not
discovered until after demolition began and, as a
result of the demolition, cannot be safely removed.
If not removed for safety reasons, the exposed
RACM and any asbestos-contaminated debris must
be treated as asbestos-containing waste material and
kept adequately wet at all times until disposed of.
(iv) Is a Category n nonfriable ACM and the probability
is low that the material will become crumbled,
pulverized, or reduced to powder during demolition.
4. INSPECTION PROCEDURES TO DETERMINE THE
POTENTIAL FOR FIBER RELEASE FROM
NONFRIABLE ASBESTOS-CONTAINING
MATERIALS
Members of the regulated community (i.e. abatement contractors,
industrial hygienists, building owners & .operators, etc.) should
become familiar with these procedures as they are designed to
enhance compliance with the Asbestos NESHAP.
-------
Asbestos NESHAP RACM Decision Tree
(Pre Demolition/Renovation Activity)
t-
no to-
KMOUBHf 0 AT ONi TWIM
MUT <# OHt /CTWITIf TOW TVS TOTMS OF »U.
FKtunCS MUST II tUWED
T«
WTO-
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Asbestos NESHAP RACM Decision Tree
(Post Demolition/Renovation Activity)
/ REGUUTED AMOUNTS OF \
I SUSPECT RACM DISCOVERED
V AFTER DEMO/RENO /
NO
ANALYZE
REPRESENTATIVE
SAMPLE FOR ASBESTC
CONTENT
NOT COVERED BY
NO
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GENERAL INSPECTION PROCEDURES
1. Identify all nonfriable suspect ACM and determine whether
it is Category I or II.
2. If it is Category I nonfriable RACM:
Is it in "poor condition?"
[Is the binding of the ACM losing its integrity? Is
the ACM peeling, cracking, or crumbling?
(Remember, friable ACM may not appear in poor
condition.)]
Is it friable?
Collect a piece of dry ACM and seal it in a
transparent, reclosable sample bag.
Apply hand pressure and observe if the
ACM falls apart to the extent that it is
crumbled, pulverized, or reduced to powder.
Does it occur suddenly, all at once?
Send representative samples of the RACM
to an analytical laboratory which is able to
test them for the presence of asbestos
according to the methods specified in 40
CFR Part 763 Subpart F, Appendix A.
Ask the owner/operator if any ACM or
RACM has been sampled and analyzed. If
so, determine where the samples were taken
and ask if the methods of demolition/
renovation were considered when assessing
-------
the fiber release potential of the material.-
Will it or has it been subjected to sanding,
grinding, cutting or abrading?
3. If it is Category n nonfriable ACM:
Has the material been crumbled, pulverized or
reduced to powder or is there a high probability that
it will be crumbled, pulverized or reduced to powder
during the demolition/renovation operations, thus
rendering the material friable and subject to the
Asbestos NESHAP?
If Category II nonfriable ACM has been or will be
crumbled, pulverized, or reduced to powder by
demolition or renovation forces, take representative
samples and send them to a laboratory to test for the
presence of asbestos according to the method
specified in 40 CFR Part 763, Subpart F, Appendix A.
5. SPECIFIC INSPECTION PROCEDURES
Category I Nonfriable ACM
Packings and Gaskets
These materials are often very difficult to find because they are
usually placed inside ovens, doors, pipes, boilers, etc.
Often a packing or gasket is discovered during a stripping or
demolition activity. For example, some boilers have an asbestos-
containing paraffin wax packing between the steam lines that travel
between the mud and fire boxes. The paraffin binding of the
packing may decompose due to the high temperatures, and render the
packing friable. Observe all of the packing and note areas that are in
poor condition. Packings in poor condition appear dry and
-------
discolored, and fibers may be visible.
A representative piece of asbestos-containing packing material (in
good or poor condition) should be removed with a utility knife and
sealed in a transparent, reclosable bag. Apply hand pressure to the
packing in the sample bag to determine if any portion is crumbled,
pulverized or reduced to powder. If the material simply deforms, but
does not crumble or reduces to a powder, then the material is
considered nonfriable.
Resilient Floor Covering
There is a wide variety of resilient floor covering applications that
contain asbestos. The most common are linoleum flooring and vinyl
asbestos tile (VAT). VAT is most commonly found in either a
9"x9" or a 12"xl2" square size. The 9"x9" VAT's are normally
found in older buildings because they were manufactured earlier than
the 12"xl2" VAT's; however, floor tile sizes and resilient floor
covering applications vary greatly since many buildings have been
re-tiled several times.
In order to determine if a resilient floor covering is in poor condition
look for sections or tiles which are cracked or peeling to the extent
that they are crumbled. Floor coverings in poor condition can often
be found near doorways or loading/staging areas where the floor has
sustained a lot of stress and traffic. If the floor covering is in poor
condition, collect a small representative sample and seal it in a
transparent, sample bag. Hand pressure should be applied to
determine if the material can be crumbled, pulverized, or reduced to
powder. If it can, die material is considered friable. Resilient floor
covering that will be or has been sanded, ground or abraded is
subject to the Asbestos NESHAP. Figure 2 depicts a VAT which is
in poor condition.
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Figure 2. VAT in poor condition
Asphalt Roofing Products
Asbestos-containing roofing felts have been widely used in "built-up"
roofs. Built-up roofing was used on flat surfaces and consists of
alternating layers of roofing felt and asphalt The roofing felt
consists of asbestos paper saturated and coated with asphalt.
Asphalt-asbestos roofing products made from roofing felt coated with
asphalt were reportedly used on residential structures for only a short
time (1971-1974).
To determine if an asphalt roofing product is covered by the
Asbestos NESHAP, examine the RACM to spot any areas where the
material is in poor condition and friable. Figure 3 illustrates a
section of roofing felts which have deteriorated and display fibers.
If possible, sample areas where fibers can be seen protruding from
the matrix of the asphalt The sample should be sealed into a
transparent, rcclosable sample bag and hand pressure applied to see
if the sample can be crumbled, pulverized, or reduced to^powdr-
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Figure 3. Asphalt roofing felts which are in poor condition. Notice
the fibers protruding along die edge of this roofing felt
Category II Nonfriable ACM
Asbestos Cement Pipe and Sheet Products
Asbestos-cement (A-C) pipe has been widely used for water and
sewer mains and occasionally used as electrical conduits, drainage
pipe, and vent pipes. A-C sheet, manufactured in flat or corrugated
panels and shingles (transite board), has been used primarily for
roofing and siding, but also for cooling tower fill sheets, canal
bulkheads, laboratory tables, and electrical switching gear panels. If
these ACM are crumbled, pulverized or reduced to a powder, they
are friable and thus covered by the Asbestos NESHAP. Broken
edges of these materials typically are friable. The fractured surface
should be rubbed to see if it produces powder.
If Category n nonfriable ACM has not crumbled, been pulverized 01
reduced to powder and will not become so during the course of
demolition/renovation operations, it is considered nonfriable and
therefore is not subject to the Asbestos NESHAP. However, if
during the demolition or renovation activity it becomes crumbled,
pulverized or reduced to powder, it is covered by the Asbestos
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APPENDIX A
ASBESTOS NESHAP COORDINATORS
(FOR DEMOLITION/RENOVATION ACTIVITIES
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3265
CT, MA, ME, NH, RI, VT
Asbestos NESHAP Coordinator
Air & Waste Management Division
U.S. EPA Region U
26 Federal Plaza
New York, NY 10278
(212) 264-6770
NJ, NY, PR, VI
Asbestos NESHAP Coordinator
Air Management Division
ILS. EPA Region m
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6550
DC, DE, MD, PA, VA, WV
Asbestos NESHAP Coordinator
Air Management Division
ILS. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6819
IL, IN, MI, MN, OH, WI
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7223
AR, LA, NM, OK, TX
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region VH
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
IA, KS, MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA Region Vm
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-7685
CO, MT, ND, SD, UT, WY
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Asbestos NESHAP Coordinator
Air and Toxics Division
U.S. EPA Region DC
75 Hawthorne Street
San Francisco, CA 94105
(415) 774-5569
American Samoa, AZ, CA, Guam, HI
Northern Marianas, Trust Territories
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(205) 442-1757
AK, ID, OR, WA
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APPENDIX B
REGIONAL ASBESTOS COORDINATORS (FOR SCHOOLS)
Regional Asbestos Coordinator
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3835
CT, MA, ME, NH, RI, VT
Regional Asbestos Coordinator
U.S. EPA Region JJ
Woodbridge Avenue
Raritan Depot, Building 5
Edison, NJ 08837
(201) 321-6671
NJ, NY, PR, VI
Regional Asbestos Coordinator
ILS. EPA Region m
841 Chestnut Building
Philadelphia. PA 19107
(215) 597-3160
DC, DE, MD, PA, VA, WV
Regional Asbestos Coordinator
U.S. EPA Region IV
345 Courtland SL N£.
Atlanta, GA 30365
(404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Regional Asbestos Coordinator
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6003
IL, IN, MI, MN, OH, WI
Regional Asbestos Coordinator
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244
AR, IA, NM, OK, TX
Regional Asbestos Coordinator
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
IA. KS. MO. NE
Regional Asbestos Coordinator
U.S. EPA Region VTU
1 Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2413
(303) 293-1442
CO,MT,ND, SD.UT.WY
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Regional Asbestos Coordinator
U.S. EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5406
American Samoa, AZ, CA Guam,
Northern Marianas, Trust Territories
Regional Asbestos Coordinator
U.S. EPA Region IV
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-4762
AK, ID, OR, WA
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ITEMS
Asbestos/NESHAP Adequately Wet Guidance
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EPA340/1-90-019
ASBESTOS NESHAP
ADEQUATELY WET GUIDANCE
VS. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and
Standards
Stationary Source Compliance Division
Washington, DC 20460
December 1990
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CONTENTS
Section Page
1 INTRODUCTION 1
2 IMPORTANT TERMS 2
Adequately Wet 2
Friable Asbestos Material 3
Nonfriable Asbestos-containing Materials 3
3 FRIABLE AND NONFRIABLE ASBESTOS
CONTAINING MATERIALS 4
4 REQUIREMENTS FOR ADEQUATELY WETTING
ASBESTOS-CONTAINING MATERIALS 5
5 EXCEPTIONS TO ADEQUATELY WETTING
ASBESTOS-CONTAINING MATERIALS 9
6 TECHNIQUES FOR WETTING ASBESTOS-CONTAINING
MATERIALS 11
General Information 11
7 PROCEDURES FOR WETTING ASBESTOS-CONTAINING
MATERIALS 12
Thermal System Insulation 12
Asbestos-Containing Surfacing Materials 18
Miscellaneous Asbestos-
Containing Materials 18
8 INSPECTION PROCEDURES 21
Appendices
A Asbestos NESHAP Coordinators
(for Demolition/Renovation Activities) A-l
B Regional Asbestos Coordinators
(for Schools) i B-l
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ACKNOWLEDGEMENTS
This document was written by Alliance Technologies, Inc.,
based on discussions with a work group from EPA. The group
consisted of the Regional Asbestos NESHAP Coordinators, Ron Shafer,
Scott Throwe, and Omayra Salgado of the Stationary Source Compliance
Division, Charles Garlow and Elise Hoerath of the Air Enforcement
Division and Sims Roy of the Standards Development Branch. We thank the
individuals who reviewed an earlier draft and provided comments, many of
which are incorporated in the final version. Their input is gratefully
acknowledged.
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1. INTRODUCTION
The Clean Air Act (CAA) of 1970 requires the U.S. Environmental
Protection Agency (EPA) to develop and enforce regulations to
protect the general public from exposure to airborne contaminants
that are known to be hazardous to human health. In accordance with
Section 112 of the CAA, EPA established National Emissions
Standards for Hazardous Air Pollutants (NESHAP) to protect the
public. Asbestos was one of the first hazardous air pollutants
regulated under Section 112. The Asbestos NESHAP (40 CFR 61,
Subpart M) addresses milling, manufacturing and fabricating
operations, demolition and renovation activities, waste disposal
issues, active and inactive waste disposal sites and asbestos
conversion processes.
The Asbestos NESHAP requires facility owners and/or operators
involved in demolition and renovation activities to control emissions
of paniculate asbestos to the outside air because no safe
concentration of airborne asbestos has ever been established. The
primary method used to control asbestos emissions is to adequately
wet the Asbestos Containing Material (ACM) with a wetting agent
prior to, during and after demolition/renovation activities.
The purpose of mis document is to provide guidance to asbestos
inspectors and the regulated community on how to determine if
friable ACM is adequately wet as required by the Asbestos
NESHAP.
The recommendations made in this guidance are solely
recommendations. They are not the exclusive means of complying
with the Asbestos NESHAP requirements. Following these
recommendations is not a guarantee against findings of violation.
Determinations of whether asbestos materials are adequately wetted
are made by EPA inspectors on site.
2. IMPORTANT TERMS
Adequately Wet
EPA defines 'adequately wet" to mean "sufficiently mix or penetrate
with liquid to prevent the release of particulates. If visible emissions
are observed coming from asbestos-containing material (ACM), then
that material has not been adequately wetted. However, the absence
of visible emission is not sufficient evidence of being adequately wet
(Section 61.141, Definitions). Amended water is often used to wet
ACM during repair/removal operations.
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Friable Asbestos Material
Friable asbestos material is any material containing more than
1 percent asbestos as determined using Polarized Light Microscopy
(PLM), that, when dry, can be crumbled, pulverized, or reduced to
powder by hand pressure.
Asbestos-Containing Waste Materials (ACWM)
EPA defines ACWM to mean mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to the
provisions of this subpart. This term includes filters from control
devices, friable asbestos waste material, and bags on other similar
packaging contaminated with commercial asbestos. As applied to
demolition and renovation operations, this term also includes friable
asbestos waste and Category II nonfriable ACM waste that becomes
crumbled, pulverized, or reduced to powder by forces that acted on
the material during the course of demolition and renovation
operations regulated by this subpart, and materials contaminated with
asbestos including disposal equipment and clothing.
Nonfriable Asbestos-containing Materials
Nonfriable asbestos-containing material is any material containing
more than 1 percent asbestos as determined using Polarized Light
Microscopy (PLM) that, when dry, cannot be crumbled, pulverized,
or reduced to powder by hand pressure.
Regulated Asbestos-Containing Material (RACM)
Is (a) friable asbestos material, (b) Category I nonfriable ACM that
has become triable, (c) Category I nonfnable ACM that will be or
has been subjected to sanding, grinding, cutting or abrading, or (d)
Category II nonfnable ACMthat has a high probability oiDecorrung
or has become crumbled, pulverized, or reduced to powder by die
force expected to act on the material in the course of demolition or
renovation operations.
3. FRIABLE AND NONFRIABLE ASBESTOS-
CONTAINING MATERIALS
The Asbestos NESHAP defines two categories of nonfriable ACM:
Category I nonfriable ACM (asbestos-containing packings, gaskets,
resilient floor covering and asphalt roofing products) and Category II
nonfnable ACM (any nonfnable material not designated as
Category I).
The Agency requires that, where the Asbestos NESHAP is
applicable, friable ACM and Category n and nonfnable ACM that is
Hkely to become disturbed or damaged so that the material could be
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crumbled, pulverized or reduced to powder during a demolition or
renovation oe removed, from a facility prior to its demolition/
renovation. The fibrous or fluffy spray-applied asbestos materials
found in many buildings for fireproofing, insulating, sound-proofing,
or decorative purposes are generally considered friable. Pipe and
boiler wrap found in numerous buildings is also considered friable.
Nonfriable ACM, such as vinyl-asbestos floor tile, generally emits
low levels of airborne fibers unless subjected to burning or to
sanding, grinding, cutting or abrading operations. Other materials,
such as asbestos cement sheet and pipe, can emit asbestos fibers if
the materials are crumbled, pulverized or reduced to powder during
demolition/renovation activities. Whenever nonfriable materials are
going to be damaged to the extent that they are crumbled, pulverized
or reduced to powder, they must be handled in accordance with the
Asbestos NESHAP.
4. REQUIREMENTS FOR ADEQUATELY WETTING
ASBESTOS-CONTAINING MATERIALS
The NESHAP regulation requires that RACM be adequately wetted
during the following activities:
a. During cutting or disjoining operations when a facilit
component which is covered or coated with friable ACM
is being removed from that facility as units or in sections
(Section 61.145 (c)(2)(i)).
During demolitions or renovations a contractor may choose to
remove an entire boiler, a section of pipe, or other facility
components without first removing the asbestos insulation from these
structures. Any ACM which will oe disturbed during cutting or
disjoining operations must be adequately wet
b. During stripping operations when a facility component
containing RACM remains in place in the facility.
(Section 61.145 (c)(3)).
Stripping operations are the most common form of asbestos removal
during renovation activities, since most items that are covered with
asbestos are facility components or structural members which will
not be removed. Stripping off all of the RACM can generate
significant asbestos emissions if the ACM is not adequately wet
during removal
Friable spray-on ACM, which includes fire-proofing materials found
on decking and support I-beams, is normally easy to wet throughout
because of the absorbing property of the cellulose mixing/binding
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agent The Asbestos NESHAP reauires that these materials be fully
penetrated with the wetting agent during demolition/renovation
activities.
Other ACM, however, such as "thermal-block* insulation used on
pipes and boilers, certain ceiling and floor tile applications, etc.,
which do .not absorb water readily may be hard to penetrate by water
or a wetting agent For such materials, adequate wetting consists of
coating the surfaces of the materials with water or a wetting agent
prior to, during, and, in most cases, after removal activities in
order to prevent asbestos emissions. Whenever such materials are
broken during the removal process, the exposed, dry surfaces must
be wetted immediately to reduce emissions.
If pieces of dry ACM are accidentally disturbed, they should be
immediately wetted and kept wet until collected for disposal.
Removal personnel are commonly assigned to keep the fallen RACM
wet prior to its being collected for disposal.
c. After the RACM has been stripped from a facility
component, it must remain adequately wet until it has
been collected and contained or treated in preparation
for disposal (Section 61.145 (c)(6)(i))
After removal, adequately wetted ACWM must be sealed in leak-
tight containers or wrapping which must be labeled as specified by
the Occupational Health and Safety Administration (OSHA) under 29
CFR 19 ID. 10010X2) or 1926^8(k)(2)fifi). Such waste materials
destined for off-site transport must additionally be labeled with the
name of the generator and location of the waste generation site
(Section 61.150 (a)(l)(iv and v)).
d. In demolitions where the RACM was not removed prior
to demolition (Section 61.145 (c)(l)(i)(u)ftii)(iv))
RACM on a facility component encased in concrete
or other similarly hard material must be adequately
wet whenever exposed during demolitions (Section
61.145 (c)(l)(ii));
RACM which was not accessible for testing and,
due to demolition, cannot be safely removed, must
be kept adequately wet at all times until disposed of
(Section 6U45 (c)(l)(ui)):
The portion of a facility ordered demolished mat
contains RACM must be adequately wet during the
wrecking operation (Section 61.145 (c)(9)).
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In each of the above situations, ACWM generated must be kept
adequately wet during handling and loading for transport to the
disposal site. In cases where ACWM can t be segregated from the
debri pile it must be disposed of as ACWM. Such ACWM does not
have to be sealed in leak-tight containers or wrapping, but may be
transported and disposed of in bulk (Section 61.150 (a)(3)).
5. EXCEPTIONS TO ADEQUATELY WETTING ASBESTOS-
CONTAINING MATERIALS
The Asbestos NESHAP allows two exceptions to wetting RACM
during a demolition or renovation project:
When the temperature at the point of wetting is
below 0°C (32*F) (Section 61.145 (c)(7)(i)).
The owner/operator must remove facility
components coated or covered with friable ACM as
units or sections to the maximum extent possible and
meet subsequent requirements of 61.145, including
the wetting requirements.
During periods when wetting operations are
suspended due to freezing temperatures, the
owner/operator must record the temperature in the
area containing the facility components at the
beginning, middle, and end of each workday and
keep daily temperature records available for
inspection by the Administratorduring normal
business hours at the demolition or renovation site.
The owner or operator shall retain the temperature
records for at least 2 years,
When the use of water would unavoidably
damage equipment or present a safety hazard
(SecTSLl45 (c)(3)(D(AS.
The owner/operator must first obtain written
approval from the Administrator for an alternative
work practice, prior to renovation activities and
utilize a local exhaust ventilation and collection
system designed to capture paniculate asbestos
released during removal operations. (Section 61.145
(c)(3)(i)(B)(T)); or a glove bag system or a leak-tight
wrapping which can contain the paniculate asbestos
materials produced by stripping ACM. (Section
61.145 (c)(3)(i)(B)(2)and S))
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6. TECHNIQUES FOR WETTING ASBESTOS-
CONTAINING MATERIALS
General Information
Adequate wetting of ACM is typically accomplished by repeatedly
spraying it with a liquid or a wetting agent, usually amended water
(water to which surfactant chemicals have been added), until it can
absorb no more. However, this does not necessarily mean that the
ACM will be soaked throughout Surfactant chemicals reduce the
surface tension of the water, thereby increasing its ability to
penetrate the ACM and surround the asbestos fibers. Although
amending agents are not required by the Asbestos NESHAP (the
NESHAP only requires the use of a liquid), EPA, in its "Guidance
for Controlling Asbestos-Containing Materials in Buildings", EPA-
560/5-85-024 (Purple Book), recommends the use of a 50:50 mixture
of polyoxyethylene ester and polyoxyethylene ether, or the
equivalent, in a 0.16 percent solution (1 ounce to 5 gallons) of water.
Wetting agents may be applied with garden sprayers or hoses.
Garden sprayers are hand-held, portable, and nave a one- to five-
gallon capacity. Water hoses are usually attached to a faucet tap,
fire hydrant or water tank. Generally, the hose has a nozzle attached
which spreads the water stream so that a fine mist is created.
An engineering control often used is a misting unit which can be
used to create a high level of humidity within a removal area. It is
believed that fibers emitted into a saturated environment will absorb
the wetting agent and fall out of the air faster, thus reducing airborne
fiber levels.
7. PROCEDURES FOR WETTING ASBESTOS-
CONTAINING MATERIALS
The following procedures describe methods of adequately wetting
various applications of ACM.
Thermal System Insulation
Molded Pipe Insulation
The recommended wetting procedure for mis type of RACM is to
saturate the outer surface with amended water, strip off the wet
canvas coating and then rewet the surface in order to thoroughly
saturate the ACM. The metal bands supporting the RACM should
be removed and the half-round sections carefully separated. While
this occurs, the interior side and edges of the sections should be
saturated with amended water. If a section breaks during removal,
the exposed surfaces should be wetted immediately. A misting
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sprayer may also be used to keep the air in the removal area or
containment area saturated with amended water to attempt to reduce
airborne asbestos fiber levels.
Corrugated Paper Pipe Insulation
The outer surface of the corrugated paper ("air-cell") pipe insulation,
usually a canvas wrap, should be saturated with a wetting agent and
then removed. Wetting should continue until all the insulation is
permeated with amended water. Metal bands holding the insulation
in place should be removed and the corrugated RACM insulation
stripped. Any unsaturated surfaces exposed during the stripping
operation must be wetted immediately to reduce asbestos emissions.
A misting sprayer may also be used to keep the air in the removal
area saturated with amended water to attempt to reduce airborne
asbestos fiber levels. Inadequately wetted and adequately wetted
corrugated paper pipe insulation can be seen in Figures 1 and 2.
Figure 1. Inadequately wetted corrugated paper, pipe insulation.
(Note the fibrous material adjacent to the lagging clamp.)
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Figure 2. Adequately wetted corrugated paper, pipe insulation.
(Note the saturated material adjacent to the lagging clamp.)
Boiler and Water Tank Thermal Block Insulation
Asbestos-containing preformed block insulation has been used as
thermal insulation on boilers, hot water tanks and heat exchangers in
industrial, commercial, institutional and residential applications. The
blocks are commonly chalky in nature and may be held in place by
chicken wire or expanded metal lath. A plaster-saturated canvas was
often applied as a final covering or wrap.
Due to the number, thickness and varying absorbencies of these
layers of materials, adequate wetting may be accomplished only by
continually wetting the materials with amended water as the various
layers are strip;
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One person may be assigned to spray the materials as they are
stripped, and a misting sprayer may DC used in an attempt to reduce
airborne asbestos fiber levels.
Cementitious Fitting Insulation
Wetting of cementitious fitting insulation is similar to that used when
removing asbestos-containing thermal block insulation. The outer
surface is saturated with amended water and the outer covering (if
applicable) is removed. The fitting insulation is then rewettedand
the insulation stripped. To ensure that the fitting remains adequately
wet during the removal operation, a person is often assigned to spray
the ACM as it is stripped. A misting sprayer may be used to reduce
airborne asbestos fiber levels. Inadequately wetted cementitious
fitting insulation can be seen in Figure 3.
Figure 3. Inadequately wetted cementitious fitting insulation. (Note
that the part of the insulation which has been wetted is dark grey in
color, whereas the dry section remains white.)
Asbestos-Containing Surfacing Materials
"Surfacing Material* is a generic term designated by the Asbestos
Hazard Emergency Response Act (AHERA; Asbestos Containing
Materials in Schools, 40 CFR Part 763, Subpart E) to mean any wall
or ceiling material that is sprayed-on or troweled-on, such as
acoustical plaster or fireproofing. The recommended wetting method
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for this type of RACM is to saturate the surfaces, begin the stripping
operation and continue to wet the RACM as it is being removed. A
misting sprayer may also be used to keep the air saturated while the
removal occurs. Since surfacing materials vary in their ability to
absorb a wetting agent, inspectors must consider the type of
surfacing material that is being removed in order to determine the
requiredextent of penetration by the amended water. Surfacing
materials which easily absorb a wetting agent need to be fully
penetrated or permeated to be considered adequately wet, whereas
only the exposed surfaces of materials which do not absorb water
readily need to be wetted.
The use of high pressure water to remove asbestos-containing
surfacing materials, either through a steam-cleaning device or a
diesel powered hydroblasting water applicator, should be avoided
since such use may unduly disturb RACM and contribute to higher
airborne asbestos fiber levels. However, if this removal method is
used, contractors must adequately wet the ACM prior to and during
the removal.
Miscellaneous Asbestos-Containing Materials
Both friable and nonfriable forms of other asbestos-containing
building materials exist Friable materials include asbestos-
containing paper (commonly found beneath wooden floors),
wallpaper, and joint compound. It has been estimated mat 5 to 10
percent of the ceiling tiles currently installed in the U.S. contain
asbestos.
Nonfriable miscellaneous ACM includes floor tiles, asbestos cement
sheet (transits board), siding shingles, asphalt roofing shingles,
laboratory benchtops and even chalkboards. These materials may
become friable with age, and under harsh conditions. Category I
nonfriable ACM must be carefully examined to determine u the
material is in poor condition, that is, if the binding material is losing
its integrity, exhibited by peeling, cracking or crumbling; and is also
friable. When Category 1 nonfriable ACM has become friable it is
subject to the NESHAP.
If Category I or n ACM is sanded, ground, cut or abraded it is also
covered by the NESHAP. Category n nonfriable ACM which is
damaged to the extent that it has or will become crumbled,
pulverized or reduced to powder due to demolition/ renovation
activities, is subject to the Asbestos NESHAP.
Miscellaneous materials are wetted in manners similar to those used
to wet other categories of RACM. Coverings are saturated with a
wetting agent before removal and the asbestos-containing portions
fully penetrated with the agent prior to, during and after their
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removal, while stored in the removal area, and while being placed
into disposal containers. Miscellaneous materials that don't absorb
water readily (e.g., asbestos-concrete products, and floor tiles) are
only required to nave wetted surfaces. A misting sprayer may be
used to diminish airborne asbestos fiber levels.
8. INSPECTION PROCEDURES
The intent of the following guidelines is to provide
GUIDANCE ONLY, to the regulated community regarding the
inspection procedures recommended to Asbestos NESHAP inspectors
for determining compliance widi the "Adequately Wet" requirements
of the Asbestos NESHAP. The purpose of the wetting provisions is
to require as much wetting as is necessary to prevent airborne
emissions of asbestos fibers. In order to achieve this result, RACM
and ACWM must be wetted and maintained wet until collected for
disposal. The determination of whether RACM or ACWM has been
adequately wetted is generally based on observations made by the
inspector at the time of inspection. Observations probative or
whether a material is adequately wet include but are not limited to,
the following:
1. Is there a water supply in place?
2. Is water or a wetting agent observed being sprayed onto the
RACM or ACWM Both during stripping or removal and
afterwards while the material awaits proper disposal? If yes,
carefully note the method of application used (e.g., misting,
fogging, spraying of surface area only or drenching to
penetrate the ACM throughout).
3. If water or a wetting agent is being used, what equipment is
used to apply it (e.g., garden hose, plant mister)?
4. If water or a wetting agent is not being used, determine why
it is not and document the reason. Possible (although not
arily valid) reasons include:
prior permission obtained from the Administrator
(safety hazard, potential equipment damage);
no water source at the facility;
temperature at the point of wetting below
32 degrees F;
portable water supply ran out and contractor
continued to work; or
contractor prepared the area earlier, etc.
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5. Examine a stripped or removed piece of ACWM or RACM
which wets readily. Does it appear to be wetted throughout?
If it does not, adequately wet the sample. Describe and
photograph how the physical characteristics of the
material change upon wetting (e.g., color, weight, texture,
etc.). Take samples, as necessary, to document the presence
of asbestos in the suspect material.
6. When examining materials that do not readily absorb water
or a wetting agent (e.g.,j>remolded thermal system
insulation, ceiling tiles, floor tiles') inspectors should note
whether all exposed surfaces of these materials have been
wetted as required.
7. Is there visible dust (airborne or settled), or dry ACWM
debris in the immediate vicinity of the operation? Inspectors
should collect samples of such materials for analysis of their
possible asbestos content
8. Examine ACWM in bags or other containers using the
procedures that follow, to determine if the material has been
adequately wetted?
1. Randomly select bags or the containers for
inspection.
2. Lift the bag and assess its overall weight. (A bag of
dry ACWM can generally be lifted easily by one
hand. A bag filled with well-wetted material would
be substantially heavier.)
3. If the bag or other container is transparent:
Visually inspect the contents of the
unopened bag for evidence of moisture (e.g.,
water droplets, water in the bottom of the
bag, a change in the color of the material
due to water).
Without opening the bag, squeeze chunks of
debris to ascertain whether moisture droplets
are emitted.
If the material appears dry or not penetrated
with liquid or a wetting agent, open the bag
using the additional steps described in step 9
below, and collect a bulk sample of each
type of material in the bag ascertaining
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variations in size, patterns, color and
textures.
9. If the waste material is contained in an opaque bag or other
container, or if the material is in a transparent bag which
appears to be inadequately wetted:
Carefully open the bag (in the containment
area, if possible). If mere is no containment
area at the site, a glove bag may be used to
enclose the container prior to opening it to
minimize the risk of any fiber release.
Examine the contents of the bag for
evidence of moisture as in 8 above, and if
the material appears dry or it is not fully
penetrated with water or a wetting agent,
collect a bulk sample.
Reseal the bag immediately after evaluating
and sampling its contents.
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APPENDIX A
ASBESTOS NESHAP COORDINATORS
(FOR DEMOLITION/RENOVATION ACTIVITIES)
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3265
CT, MA, ME, NH, RI, VT
Asbestos NESHAP Coordinator
Air & Waste Management Division
U.S. EPA Region II
26 Federal Plaza
New York, NY 10278
(212) 264-6770
NJ, NY PR, VI
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region ffl
841 Chestnut Street
Philadelphia, PA 19107
S15) 597-6550
C, DE, MD, PA, VA, WV
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region IV
345 Courtland Street, RE.
Atlanta, GA 30365
(404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312)886-6793
EL, IN, MI, MN, OH, WI
Asbestos NESHAP Coordinator
Air, Pesticide & Toxics Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7223
AR, LA, NM, OK, TX
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
IA, KS, MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA Region Vffl
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1767
CO, MT, ND, SD, UT, WY
Asbestos NESHAP Coordinator
Air Management Division (A-3-3)
U.S. EPA Region DC
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5569
AS, AZ, CA, GU, HI, NV,
Northern Marianas, TT
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(205) 442-1757
AK, ID, OR, WA
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APPENDIX B
REGIONAL ASBESTOS
COORDINATORS (FOR SCHOOLS)
Regional Asbestos Coordinator
EPA Region I
Air & Management Division
JFK Federal Building
Boston, MA 02203
(617) 565-3835
CT, MA, ME, NH, RL. VT
Regional Asbestos Coordinator
EPA Region n
Woodbndge Avenue
Raritan Depot, Building 5
Edison, NJ 08837
(201) 321-6671
NJ, NY, PR, VI
Regional Asbestos Coordinator
EPA Region m
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-3160
DC, DE, MD, PA, VA, WV
Regional Asbestos Coordinator
EPA Region IV
345 Courtland St RE.
Atlanta, GA 30365
(404) 347-5014
AL, FL. GA, KY, MS, NC, SC, TN
Regional Asbestos Coordinator
EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312)886-6003
IL, IN, MI, MN, OH, WI
Regional Asbestos Coordinator
EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244
AR, LA, NM, OK. TX
Regional Asbestos Coordinator
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
IA, KS, MO, NE
Regional Asbestos Coordinator
EPA Region Vm
1 Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2413
(303) 293-1442
CO, MT, ND, SD, UT, WY
Regional Asbestos Coordinator
EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5406
AS, AZ, CA GU, HI, NV,
Northern Marianas, TT
Regional Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-4762
AK, ID, OR, WA
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ITEM 4
Reporting and Recordkeeping Requirements For
Waste Disposal (A Field Guide)
-------
rEPA
united SUtas
Environmental Protection
Agency
Air And Radiation
(EN-341)
EPA 340/1-90-016
November 1990
Reporting And
Recordkeeping Requirements
For Waste Disposal
A Field Guide
' iv;^- -;- '.
r ..~ ^T ^
*>.^ -V
-------
DISCLAIMER
This manual was prepared by Entropy Environmentalist, Inc. for the Stationary Source
Compliance Division of the U.S. Environmental Protection Agency. It has been
completed in accordance with EPA Contract No. 68-02-4462, Work Assignment No. 90-
123. This document is intended for information purposes ONLY, and may not in any
way be interpreted to alter or replace the coverage or requirements of the asbestos
National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61,
Subpart M. Any mention of product names does not constitute endorsement by the
US. Environmental Protection Agency.
-------
\C/EPA Reporting And
Recordkeeping Requirements
For Waste Disposal
A Field Guide
-------
FIELD GUIDE
REPORTING AND RECORDKEEPING REQUIREMENTS FOR WASTE DISPOSAL
This is a guide to help you comply with the new reporting and recordkeeping requirements of
the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). The specific
responsibilities of waste generators, transporters and waste disposal site operators are addressed, as
well as detailed explanations of how to complete the new forms accurately and efficiently. This field
guide is organized into four main sections as follows:
Waste Shipment Record
Reporting Requirements
Recordkeeping Requirements
Source Reporting Requirements for Disposal Site Operators
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I. WASTE SHIPMENT RECORD
After (the effective date of this rule), all shipments of asbestos containing waste material must be
accompanied by a Waste Shipment Record (WSR) similar to the sample shown in Figure 1. When it is
signed by the generator, the transporter and the waste disposal site operator, the WSR documents the
movement and ultimate disposition of asbestos waste. The WSR consists of three parts and requires
three signatures, those of the generator, the transporter and the disposal site operator.
A. Waste Generator
Waste generator means any owner or operator of a source covered by this rule whose
activities produce asbestos-containing waste materials. Included are asbestos mills,
manufacturers, fabricators, demolitions, renovations and spraying operations [40 CFR 61.149
and 150]. Generators are responsible for filling out Items 1-9 of the WSR. The original should
be turned over to the transporter along with the waste shipment, although the generator
should retain a copy of the WSR signed by the transporter acknowledging receipt of the waste
shipment (Item 10) for his records.
Directions for filling out the WSR form are found in Figure 1. Items 1-4 and 6 provide
important reference information. In Item 5, Category I nonfriable materials (asbestos-
containing packings, gaskets, resilient floor covering and asphalt roofing products) should be
considered nonfriable if they have not been sanded, ground, burned, or abraded; and Category
n materials such as asbestos-cement products taken out before demolition may be reported as
nonfriable also.
Item 7 asks for the quantity of waste in cubic meters or cubic yards. You may report in the
units that you are most comfortable using, but you are expected to make a good faith effort to
report correctly. Some helpful conversion factors are provided below:
Drums and barrels used as asbestos-waste containers are typically of 35 gallons capacity.
Gallons can be converted to cubic yards by multiplying gallons by 0.00379. In our example, 35
gallons x 0.00379 » 0.133 cubic yards for the volume of a drum or barrel.
Plastic bags have a nominal volume of 0.1 cubic yards, but when they contain asbestos waste
their volume is assumed to be about 0.075 cubic yards.
Cubic yards can be changed to cubic meters by multiplying cubic yards by 0.765. The drum
for which we calculated a volume of 0.133 cubic yards would nave a volume of 0.133 x 0.765
0.102 cubic meters.
Follow the instructions given in Figure 1 to complete Items 8 and 9. When you turn the waste
over to the transporter, require the transporter to acknowledge receipt of the asbestos waste by signing
the WSR at Item 10: retain a copy of the WSR signed by the transporter for your files.
B. Transporter
At the time that you take possession of the load of waste, ask the generator for a WSR.
Acknowledge receipt of the asbestos waste by signing the WSR at Item 10; return a copy of it
to the generator. If you turn the shipment over to a second transporter require him to
-------
acknowledge receipt of the shipment by signing the WSR at Item 11. It is recommended that
you retain a copy of the signed document for your files when you surrender the WSR to a
second transporter. The transporter who delivers the waste shipment to the waste disposal
site should surrender the WSR to the disposal site operator. It is recommended that you keep
a copy of the WSR signed by the disposal site operator for your files as a matter of good
business practice.
C. Waste Disposal Site Operator
Waste disposal site operators are not expected to open bags or other containers to verify that
the material is asbestos: if a WSR accompanies the shipment, that is sufficient verification.
You must complete Items 12 and 13 of the WSR according to the instructions in Figure 1 and
send a copy of the WSR according to the name and address listed in Item 2 of the WSR. The
disposal site operator should check to see that the numbers of containers reported in WSR
Item 6 and the quantities reported in WSR Item 7 appear to be correct. Any discrepancy
should be noted in Item 12.
If the WSR indicates a truckload of asbestos waste, ask the driver if he knows the truck's cargo
capacity. If he cannot tell you the capacity, estimate it by multiplying the length by the width
by the height of the cargo compartment (all in feet) and divide by 27 cubic feet to obtain cubic
yards. If you know the capacity of a trucksay 20 cubic yardsand you judge it to be half-
full, estimate the load as 10 cubic yards.
Item 12 is also used to note improperly enclosed or uncovered waste.
H. REPORTING REQUIREMENTS
The revised NESHAP now includes reporting requirements for generators and waste disposal
site operators. Generators are required to submit exception reports if they do not receive a copy of the
WSR signed by the disposal site owner or operator within 45 days of the date the shipment was
accepted by the first transporter. Disposal site operators must file reports of discrepancies between the
quantities of waste indicated on the WSR and the quantities actually received, as well as reports of
improperly enclosed or uncovered waste.
A. Exception Report
If you as a generator of a shipment of asbestos waste do not receive a copy of the WSR signed
by the disposal site operator within 35 days after you turned the waste over to the first
transporter, you must take steps to locate the waste shipment.
First contact the transporter and verify the fact that the waste was delivered to the waste
disposal site specified in Item 3 of the WSR, If the transporter has not delivered the shipment,
determine the reason for the delay, and when it will be delivered. If the transporter has
delivered the waste to the specified waste disposal site, inquire if a copy of the WSR signed by
the disposal site operator can be made available to you. (The transporter is not required to
obtain or keep a copy signed by the disposal site operator however, some may do so as a
matter of good business practice.) Next contact the disposal site operator and determine why
you have not received a copy of the WSR signed by him. Request that the disposal site
operator send a signed copy of the WSR to you immediately.
If you have not received a signed WSR from the disposal site operator within 45 days after
te £«e over to^the initial transporter, you must submit a written exception
-------
report to the responsible NESHAP program agency (see Appendix A for a list of agencies and
their jurisdictions). The report should include a copy of the W5R in question as well as a
cover letter that explains what you have done to locate the shipment, and the results of your
search.
B. Discrepancy Report
As a waste disposal site operator, you will be checking the WSR that accompanies each
asbestos waste shipment that arrives at your site to make sure that the information on the
WSR accurately describes the waste shipment. If you see that there is a discrepancy between
the number of containers shown on the WSR and the number that you count in the truck you
should note this in Item 12 of the WSR and contact the generator to determine if there is a
reasonable explanation for the discrepancy. If you are able to reconcile the apparent
discrepancy, make a note of it on the WSR and forward it to the generator as you would
normally do.
If you are unable to resolve the discrepancy within 15 days of accepting the waste, you must
send a written discrepancy report immediately to the responsible agency in whose jurisdiction
the generator of the waste is located. The discrepancy report should describe the discrepancy
in question and the steps you have taken to obtain an explanation for it, such as how and
when you attempted to reach the generator. A copy of the shipment's WSR must accompany
the discrepancy report.
C. Report of Improperly Enclosed or Uncovered Waste
Disposal site operators will check asbestos waste shipments arriving at their sites and are
expected to look for significant amounts of improperly enclosed or uncovered waste before the
material is disposed of. If significant amounts of improperly enclosed or uncovered waste are
discovered in a shipment (see discussion under WSR), note it in Item 12 of the WSR and send,
by the following working day, a written report of the problem to the specific agency
responsible for administering the NESHAP program for the jurisdiction where the job site is
located (identified on the WSR). If the disposal site is located in a different jurisdiction than
the job site, you should also send a copy of the WSR to the agency responsible for the disposal
site. The written report should describe the improperly enclosed or uncovered waste in
sufficient detail that the responsible agency can determine the urgency of the situation and
what action to take. A copy of the WSR must be submitted along with the written report.
RECORDKEEPING REQUIREMENTS
New requirements for recordkeeping are set for waste generators and waste disposal sites.
Generators must keep copies of all WSR's for at least 2 years. In addition to keeping WSR's for at
least 2 years, active waste disposal sites must also keep records of the asbestos-containing waste
material located within the site.
A. Waste Generator
As a waste generator, you must retain copies of all WSR's, including WSR's signed by the
owner or operator of the waste disposal site where the waste was deposited for at least 2
years. The WSR's should be kept in chronological order in a secure, water-tight file. You are
expected to provide copies of WSR's upon request of the responsible agency and to make the
WSR file available for inspection during normal business hours.
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B. Active Waste Disposal Site Operator
You, the waste disposal site operator, are required to keep copies of WSR's that you have
received for at least 2 years. The WSR's should be kept in chronological order in a secure,
water-tight file. You are expected, further, to provide copies of WSR's upon request of the
responsible agency and to make the WSR file available for inspection during normal business
hours.
Another new requirement is that you now must maintain up-to-date records that indicate the
location, depth and area, and quantity of asbestos containing waste material within the
disposal site on a map or diagram of the disposal area.
You have the option of either restricting the asbestos waste to specified areas within the
disposal site or depositing it throughout the site. In making this decision you should consider
the future use of the property after the disposal site has been closed. By restricting the area
where asbestos waste is deposited you will be able to preserve more of the property for future
use. However, if you choose to deposit asbestos waste throughout the site, the responsible
agency would consider that the entire disposal area contains asbestos.
When you open a new trench (or area) for asbestos waste disposal, place stakes in the ground
at the comers of the trench. Take precautions to see that the stakes are kept where they are
originally positioned and are not broken during the time that the trench is being filled. When
you have filled the trench, call in a land surveyor. The surveyor will use the stakes to
determine the location of the asbestos deposit within the disposal site. Ask the surveyor to
prepare a map or diagram of the disposal site that shows the location(s) and surface
dimensions of the asbestos deposit.
Before beginning to fill a new trench with asbestos waste, measure the maximum depth of the
trench, record it, and save it to put on the map provided by the surveyor. Use the data
provided in Item 7 of the WSR's to obtain the quantity of asbestos-containing waste material.
Add up the cubic yards (cubic meters) of waste indicated on the WSR's for all of the asbestos
waste shipments that are deposited in the trench up until the time that it is full and is closed.
Also, put the total quantity of asbestos-waste deposited at the site on the map provided by the
surveyor.
The map should be kept current until the time that the waste disposal site b closed. At
closure you must submit a copy of records of asbestos waste disposal locations and quantities
to the agency responsible for administering the NESHAP program in your area. The
surveyor's map or diagram of the disposal site with the location and surface dimensions of the
asbestos deposit(s), maximum depth of the deposit(s) and asbestos waste quantities fulfills this
requirement and should be submitted to the Administrator. See Figure 2 for an example of a
map.
Within 60 days of closing your waste disposal site you must record on the deed to the waste
disposal site the following information:
The land has been used for the disposal of asbestos-containing waste material,
The survey plot and record of the location and quantity of asbestos containing waste
disposed of within the disposal site have been filed with (name of responsible agency), and
The site is subject to 40 CFR 61 Subpart M.
-------
In some states, a Notation of Deed form can be used to add this information to a deed, while
in others it may be easier to prepare a new deed than it is to annotate an existing deed. You should
contact the Register of Deeds at the county seat of the county in which your disposal site is located to
learn the rules that cover deeds and for instructions on how to proceed.
IV. SOURCE REPORTING REQUIREMENTS FOR DISPOSAL SITE OPERATORS
Another new requirement is that, within 90 days of the effective date of this rule, you are
required to report certain information about your asbestos waste disposal operations to the responsible
asbestos NESHAP program agency (see Appendix A for a list of agencies). Section 61.153 of the
asbestos NESHAP requires that you report the following information:
A brief description of the waste disposal site, which would include such information as .the
location and size of the disposal facility.
A description of the method or methods that will be used to comply with the asbestos
NESHAP, or a description of alternative methods that will be used. Methods to be used, such
as covering asbestos waste daily with 6 inches of nonasbestos cover or the use of dust
suppressants should be reported. Other information that might be reported includes
procedures to prevent public access to the asbestos waste disposal area, such as the use of
warning signs and fencing. You must report this information using the format in Appendix A
of Part 61 of Title 40 of the Code of Federal Regulations (40 CFR).
In addition to the information listed above, you as the waste disposal site operator, must also
report the following information required by the source reporting requirements of Section 61.10 of
Subpart, Part 61 of 40 CFR.
Name and address of the owner or operator.
The location of the source.
The type of hazardous pollutants emitted by the stationary source.
A brief description of the nature, size, design, and method of operation of the stationary
source including the operating design capacity of the source. Identify each point of emission
for asbestos.
The average weight per month of asbestos being processed by the source over the last 12
months preceding the date of the report
If there is a change in any of the information listed above, you must report the changes to the
appropriate agency within 30 days after they occur.
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Generator _j
Transporter
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O
1. Work site name and mailing address Owner's name
2. Operator's name and address
3. Waste disposal site (WOS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
Owner's
telephone no.
Operator's
telephone no.
WDS
phone no.
agency
6. Containers
No . Type
7. Total quantity
m3 (yd3)
8. Special handling Instructions and additional information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are 1n all
respects 1n proper condition for transport by highway according to
applicable International and government regulations.
Printed/ typed name & title
10. Transporter 1 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
12. Discrepancy Indication space
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
13. Waste disposal site
owner or operator: Certification of receipt of asbestos materials
covered bv this manifest except as noted in item 12.
Printed/ typed name & title
Signature
Month Day Year
(Continued
Figure 1. Waste Shipment Record
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INSTRUCTIONS
Waste Generator Section (Items 1-9)
1. Enter the name of the facility at which asbestos waste 1s generated and
the address where the facility 1s located. In the appropriate spaces,
also enter the name of the owner of the facility and the owner's phone
number.
2. If a demolition or renovation, enter the name and address of the company
and authorized agent responsible for performing the asbestos removal.
In the appropriate spaces, also enter the phone number of the operator.
3. Enter the name, address, and physical site location of the waste
disposal site (WDS) that will be receiving the asbestos materials. In
the appropriate spaces, also enter the phone number of the WDS. Enter
"on-s1te" 1f the waste will be disposed of on the generator's property.
4. Provide the name and address of the local, State, or EPA Regional office
responsible for administering the asbestos NESHAP program.
5. Indicate the types of asbestos waste materials generated. If from a
demolition or renovation, Indicate the amount of asbestos that 1s
- Friable asbestos material
- Nonfrlable asbestos material
6. Enter the number of containers used to transport the asbestos materials
listed In Item 5. Also enter one of the following container codes used
1n transporting each type of asbestos material (specify any other type
of container used If not listed below):
DM - Metal drums, barrels
DP - Plastic drums, barrels
BA - 6 nil plastic bags or wrapping
7. Enter the quantities of each type of asbestos material removed 1n units
of cubic meters (cubic yards).
8. Use this space to Indicate special transportation, treatment, storage
or disposal or Bill of Lading Information. If an alternate waste
disposal site 1s designated, note 1t here. Emergency response
telephone numbers or similar Information may be Included here.
NOTE: The waste generator must retain a copy of this form.
(continued)
Figure 1. Waste Shipment Record
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9. The authorized agent of the waste generator must read and then sign
and date this certification. The date 1s the date of receipt by
transporter.
Transporter Section (Items 10 & 11)
10. & 11. Enter name, address, and telephone number of each transporter
used, 1f applicable. Print or type the full name and title of
person accepting responsibility and acknowledging receipt of
materials -as listed on this waste shipment record for transport.
Enter date of receipt and signature.
NOTE: The transporter must retain a copy of this form.
Disposal Site Section (Items 12 & 13)
12. The authorized representative of the WDS must note 1n this space any
discrepancy between waste described on this manifest and waste actually
received as well as any Improperly enclosed or contained waste. Any
rejected materials should be listed and destination of those materials
provided. A site that converts asbestos-containing waste material to
nonasbestos material 1s considered a WDS.
13. The signature (by hand) of the authorized WDS agent Indicates
acceptance and agreement with statements on this manifest except as
noted In Item 12. The date 1s the date of signature and receipt of
shipment.
NOTE: The WDS must retain a completed copy of this form. The WDS must
also send a completed copy to the operator listed 1n Item 2.
Figure 1. Waste Shipment Record
9
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Maximum depth - 12 feet below original ground
Surface
Quantity - 10,000 cubic yards
Figure 2. Example plat of waste disposal site showing asbestos waste disposal area.
-------
Appendix A
Local, State, and EPA Regional Agencies
Responsible for Administering
The Asbestos NESHAP Program
11
-------
EPA Regions
Region 1 Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA
JFK Federal Building
Boston. MA 02203
(617) 565-3265
States: CT, MA, ME. NH. PI, VT
Region 2 Asbestos NESHAP Coordinator
Air & Waste Management
Division
U.S. EPA
26 Federal Plaza
New York. NY 10278
(212) 264-6770
States: NJ. NY. PR. VI
Region 3 Asbestos NESHAP Coordinator
Air. Toxics & Radiation
Management Division
U.S. EPA
84 1 Chestnut Building
Philadelphia. PA 19107
(215) 597-6550
States: DC, DE. MD, PA, VA. WV
Region 4 Asbestos NESHAP Coordinator
Air. Pesticide & Toxic Division
U.S. EPA
345 Courtland Street. N.E.
Atlanta. GA 30365
(404)347-5014
States: AL. FL, GA. KY. MS. NC.
SC.TN
Region 5 Asbestos NESHAP Coordinator
Air & Radiation Division
U.S. EPA
230 South Dearborn Street
Chicago. IL 60604
(312)353-6793
States: IL. IN. Ml. MN. OH. Wl
legion 6 Asbestos NESHAP Coordinator
Air. Pesticides & Toxics Division
U.S. EPA
1445 Ross Avenue. Suite 1200
Dallas. TX 75202-2733
(214) 655-7223
Region 7 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
726 Minnesota Avenue
Kansas City. KS 66101
(913) 551-7018
States: IA. KS. MO. NE
Region 8 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
One Denver Place
999 18th Street. Suite 500
Denver. CO 80202-2405
(303) 294-7685
States: CO. MT, ND, SD. UT. WY
Region 9 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
75 Hawthorne Street
San Francisco. CA 94105
(415)744-1135
States: AZ. CA, HI. NV
Region 10 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
1200 6th Avenue
Seattle. WA 98101
(206) 442-1757
States: AK. ID. OR. WA
States: AR. LA. NM. OK. TX
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Region 1 State Contact*
Region 2 State Contacts
REGION 1
REGION 2
Connecticut
Maine
Massachusetts
Damlen Houlihan
U.S. EPA
JFK Federal Building. Room
2313
Boston. MA 02203
(617) 565-3265
Bruce Buck
Dept. of Environmental
Protection
State House. Station 17
Augusta. ME 04333
(207) 582-8740
Metro Boston and North
John MacAulcy
Dept. of Environmental
Protection
5 Commonwealth Avenue
Wobum. MA 01801
(617) 935-2160
Southeast
Vacant. Inquiries are being
temporarily handled by the Metro
Boston and North office (above)
Central
Greg Levins
Dept. of Environmental
Protection
75 Grove Street
Worcester. MA 01605
(508) 792-7692
Western
Roberta Ken
Dept of Environmental
Protection
436 Dwlght Street
Springfield. MA 01103
(413)784-1100
»w Hampshire John Le Febvre
Air Resources Division
Dept. of Environmental Services
64 N. Main St. Caller Box 2033
Concord. NH 03302-2033
(603) 271-1370
ode Island Damlen Houlihan
U.S. EPA
JFK Federal Building. Room
2313
Boston. MA 02203
(617) 565-3265
fflont Damlen Houlihan
U.S. EPA
JFK Federal Building, Room
2313
Boston, MA 02203
(617) 565-3265
New Jersey Robert Fltzpatrick
U.S. EPA
Air and Waste Management
Division
26 Federal Plaza
New York. NY 10278
(212) 264-6770
New York Robert Fltzpatrick
U.S. EPA
Air and Waste Management
Division
26 Federal Plaza
New York. NY 10278
(212) 264-6770
Puerto Rico Commonwealth of Puerto Rico
Environmental Quality Board
P.O.Box 11785
Santurce. PR 00910
U.S. Virgin U.S. Virgin Islands Dept. of
Islands Conservation and Cultural
Afialrs
P.O. Box 578
Charlotte Amalle. St. Thomas
U.S. Virgin Islands 00801
Region 3 State Contacts
REGION 3
Delaware New Castle County
JimWalmer
Dept of Natural Resources and
Environmental Control
715 Grantham Lane
Newcastle. DE 19720
(302) 323-4542
Kent or Sussex County
Dave Burke
Delaware Dept of Natural
Resources
89 Kings Highway
P.O. Box 1401
Dover. DE 19903
(302) 739-4791
District of John Holmes
Columbia DC Dept of Consumer and
Regulatory Affairs
2100 Martin Luther King Avenue
S.E.
Washington. DC 20020
(202) 783-3181
13
-------
Region 3 St*tr Contact*
Maryland John McQuade
Air Management Administration
Maryland Dept of the
Environment
2500 Broenlng Highway
Baltimore, MD 21224
(301) 631-3200
Pennsylvania Dean Van Orden
Division of Hazardous Air
Pollutants
Bureau of Air Quality Control
Dept. of Environmental
Resources
P.O. Box 2357
Harrisburg. PA 17105-2357
(717) 787-9257
Allegheny County (Pittsburgh)
Fred Ebel
Bureau of Air Pollution Control
Allegheny County Health
DepLSOl 39th Street
Pittsburgh. PA 15201
(412) 578-8133
Philadelphia
EdO-Neil
Air Management Services
Dept. of Public Health
500 South Broad Street
Philadelphia. PA 19146
(215) 875-5678
Virginia Charles King
Virginia Air Pollution Control
Board
9th Street Office Building.
Room 801
Richmond. VA 23219
(804) 786-6079
For Notifications
Virginia DepL of Labor, and
Industry
Division of Occupational Health
Enforcement
P.O. Box 12064
Richmond. VA 23241
(804) 786-8009
9»t Virginia Paul Rader
West Virginia Air Pollution
Control Commission
1558 Washington Street. Cast
Charleston. WV 25311
(304) 348-4022
Region 4 State Contacts
REGION 4
Alabama
Florida
Ludwig C. Hoffmann. Ill
Air Division
Alabama Dept. of Environmental
Management
1751 W.L. Dickinson Drive
Montgomery. AL 36109
(205) 271-7861
Jefferson County
Gerald Coker
Jefferson County Dept. of Health
P.O. Box 2648
Birmingham. AL 35202
Contact: Joe Wilson
(205) 930-1210
Hnntsville
Charles Terrell
Natural Resources and
Environmental Management
Dept
CltyofHuntsvllle
2033-C Airport Road
HuntsviUe. AL 35801
(205) 883-3645
EdPalagyl
Bureau of Air Regulation
Florida DepL of Environmental
Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee. FL 32301
(904) 488-1344
Duval County
Pat Patterson
Dlv. of Bio-Environmental
Services
Duval County DepL of Health,
Welfare, and Blo-
Envlronmental Sciences
421 West Church Street.
Suite 412
Jacksonville. FL 32202
(904) 630 3638
Hillsborough County
Sheila Luce
Hillsborough County
Environmental Protection
Commission
1410 North 21st Street
Tampa. FL 33605
(813) 272-5530
14
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Region 4 State ConUcU
Georgia
Kentucky
Palm Beach County
JlmHearn
Air Pollution Control
Palm Beach County Health Dept.
901 Evemla Street
West Palm Beach. PL 33402
(407) 355-3070
Broward County
Bill Hahne
Broward County Environmental
Quality Control Board
621 South Andrews
Fort Lauderdale, FL 33301
(305) 765-4441
Dade County
Frank Echanlquc or Peter Basil
Dade County Dept. of
Environmental Resource
Management
Metro Government Ctr.,
Suite 1310
111 Northwest First Street
Miami. FL 33128
(305) 858-0601
Pinellas County
Eric Fehrmann
Division of Air Quality
Plnellas County Dept. of
Environmental Management
16100 Fairchild Drive
Building V102
Clearwater, FL 34622
(813) 530-6522
Marvin Bradford
Asbestos Licensing and
Certification Unit
Environmental Protection
Division
Georgia Dept of Natural
Resources
156 Trinity Avenue. .Suite 315
Atlanta. GA 30303
(404) 656-4999
Parker Moore
Division for Air Quality Control
Frankfort Office Park
18 Rellly Road
Frankfort, KV 40601
(502) 564-2150
Jefferson County
Jerry Schlatter
Jefferson County Air Pollution
Control District
850 Barrett Avenue
Louisville, KY 40204
(502) 625-6000
Mississippi
North Carolina
South Carolina
Jimmy Asblll
Office of Pollution Control
Mississippi Dept. of
Environmental Quality
P.O. Box 10385
Jackson. MS 39289-0385
(601) 961-5171
Pat Curran
Division of Environmental
Management
Asbestos Hazard Management
Branch P.O. Box 27687
Raleigh. NC 27611
(919) 733-0820
Mecklenburg County
Dan Hardln
Air Quality Section
Environmental Management
Division
Mecklenburg County Dept. of
Environmental Protection
1200 Blythe Boulevard
Charlotte. NC 28203
(704) 376-4603
Porayth County
Robert Fulp. Director
Forsyth County Environmental
Affairs Dept
537 North Spruce Street
Wlnston-Salem, NC 27101
Contact: Michael Hastings
(919) 727-8060
Western North Carolina
Ronald Boone. Director
Western North Carolina Regional
Air Pollution Control Agency
Buckingham County Courthouse
P.O. Box 7215
Ashevllle. NC 28801-3569
Contact: David Brtgman
(704) 255-5655
DlckSharpe
South Carolina Dept. of Health
and Environmental
Control
2600 Bull Street
Columbia. SC 29201
Contact: Jean Wheeler
(803) 734-4750
-------
Region 4 State Contact*
Region S State Contacts
Tennessee Robert Foster
Division of Air Pollution Control
Tennessee Dept. of Public Health
Customs House, 4th Floor
701 Broadway
Nashville. TN 37247-3101
Contact Jackie Waynlck
(615) 741-3931
Chattanooga-Hamilton County
J. Wayne Cropp. Director
Chattanooga-Hamilton County
Air Pollution Control Bureau
3511 Rossvllle Boulevard
Chattanooga. TN 37404
Contact: Jim Weyier
(615) 867-4321
MemphU-Shelby County
Helen Keith. Manager
Air Pollution Control
Memphis-Shelby County Health
Dept
814 Jefferson Avenue
Memphis. TN 38105
Contact Jlnneal Clark
(901) 576-7653
Nashville-Davidson County
Paul Bontrager, Director
Metropolitan Health Dept
Pollution Control Division
Nashville-Davidson County
311 Twenty-Third Avenue. North
Nashville. TN 37203
Contact Fred Hugglns
(615) 340-5653
Knoz County
Terry Harris. Director
Knox County Dept of Air
Pollution Control
4OO Main Avenue
City/County Building. Room 459
Knoxville. TN 37902
Contact: Lynne Uddlngton
(615) 521-2488
REGION 5
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Otto Klein
Division of Air Pollution Control
Illinois Environmental Protection
Agency
P.O. Box 19276
Springfield, IL 62794-9276
(217) 785-1743
Frank Profit
Asbestos Section
Office of Air Management
Indiana Dept of Environmental
Management
P.O. Box 6015
Indianapolis. IN 46206-6015
Contact: Deborah Dubenetzky
(317) 232-8373
Keshav Singh
Air Quality Division
Michigan Dept of Natural
Resources
P.O. Box 30028
Lansing. MI 48909
(517) 335-1588
David Crowell or Steve Glddlngs
Division of Air Quality
Minnesota Pollution Control
Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-7653/296-7513
Tom Hadden
Division of Air Pollution Control
Ohio Environmental Protection
Agency
P.O. Box 1049
Columbus. OH 43266-0149
(614) 644-2270
JoeBrehm
Bureau of Air Management
Wisconsin Dept of Natural
Resources
P.O. Box 7921
Madison, WI 53707
(608) 267-7541
-------
Region 6 State ConUcU
REGION 6
Arkansas
Texas
Louisiana
New Mexico
Oklahoma
Arkansas Dept of Pollution
Control and Ecology
8001 National Drive, P.O. Box
9583
Littk Rock, AR 72219
Contact: JeffPurtle
(501) 562-7444
Asbestos Unit Coordinator
Louisiana Dept. of Environmental
Quality
P.O. Box 44096
Baton Rouge. LA 70804-4096
Contact: Chris Roberie
(504) 342-9056
BemallUo County
Air Pollution Control Division
Environmental Health and
Energy Dept.
P.O. Box 1293
Albuquerque, NM 87103
Contact: Steve Walker
(505) 768-2637
Outside Bemalillo County
Air Quality Bureau
NM Environmental Improvement
Division
P.O. Box 968
Santa Fe, NM 87504-0968
Contact BUI Margraves
(505) 827-0062
Air Quality Service
Oklahoma State Dept of Health
P.O. Box 53551
Oklahoma City. OK 73152
Contact Tom Hudson
(405) 271-5220
Oklahoma City-Comity
Air Quality Section
Oklahoma City-County Health
Dept
921 N.E. 23rd Street
Oklahoma City. OK 73105
Contact Curt Goeller
(405) 427-8651
Tnlaa City-County
Air Pollution Control Program
Tulsa City-County Health Dept.
4616 East 15th Street
Tulsa. OK 74112
Contacts: Ray Bishop or Grady
Baron
(918) 744-1000
Texas
Municipal
Offices
Director of Compliance Division
Texas Air Control Board
6330 Highway 290 East
Austin, TX 78723
Contact Jeanne Phllqulst
(512)451-5711
(Submit notifications to Texas
regional offices)
Dallas
Air Pollution Control Program
Environmental Health Division
Dept. of Health and Human
Services
320 E. Jefferson. LL-13
Dallas, TX 75203
Contacts: Gary Burlbaw or Roger
Jayroe
(214) 948-4435
El Paso
Air Pollution Control Program
El Paso City Health Dept.
222 South Campbell
El Paso, TX 79901
Contact Jesus J. Reynoso
(915) 543-3646
Galveston County
Environmental Control Services
Galveston County Health District
P.O. Box 939
LaMarque.TX 77568
Contact Karen Alexander
(409) 938-7221
Houston
Bureau of Air Quality Control
Houston City Health and Human
Services Dept
7411 Park Place Blvd.
Houston. TX 77087
Acting Contact Henry H.
Branham
(713) 640-4200
Fort Worth
Environmental Health Division
Fort Worth Public Health Dept.
1800 University Drive
Fort Worth, TX 76107
Contact Gene Rattan
(817) 870-7281
Contact: Gerald Bearden
(817) 870-7289
17
-------
Region 6 State Contact*
Texas Air
Control Board
Regional
Offices
Region 1
Archer, Baylor, Brown,
rj»ii«h««, Children, Clay,
Coleman, Comanche, Cottle,
Eastland. Fiaher. Foard,
Hardeman. Haskell. Jack.
Jonea, Kent, Enoz, Mitchell,
Montague. Nolan, Runnels,
Scurry, Shackelford. Stephens.
Stonewall. Taylor.
Throckmorton, Wichita,
Wilbarger and Young Counties
Wlnona Henry. Director
Commerce Plaza Office Building
1290 South Willis. Suite 205
Abilene, TX 79605
(915) 698-9674
Region 2
Armstrong, Bailey, Briscoe,
Carson, Castro, Cochran,
CoUingsworth, Crosby, Dallam,
Deaf Smith. Dickens. Donley.
Floyd, Garza. Gray. Hale. Hall,
Hansford, Hartley, Hemphlll,
Hockley, Hntchinson. King.
Lamb, Upscomb. Lynn.
Lnbbock. Moore. Motley.
Ochiltree, Oldham, Farmer,
Potter. »»«"i«iil Roberts.
Sherman. Swisher, Terry,
Wheeler and Yoaknm Counties
Gerald Hudson, Director
Briercroft South #1
5302 South Avenue Q
Lubbock.TX 79412
(806) 744-0090
Regions
Bastrop. Bell. Blanco, Boaque,
Brazos, Bnrleson, Bnrnet,
Caldwell, Coryell, Falls,
Fayette. Freestone, Grimes.
Hamilton. Hays. Hill.
Lampasa*. Lee. Leon, Llano,
Limestone. Madison,
McClennan. Mllum, Mills,
Robertson, Travis. Washington
and Williamson Counties
Eugene Fulton. Director
500 Lake Air Drive, Suite 1
Waco.TX 76710-5887
(817) 772-9240
Region 4
Cameron, Hidalgo, Jim Hogg,
Starr. Webb. Willacy and Zapata
Counties
Robert Guzman. Director
Matz Building. Room 204
513 East Jackson
Harllngen. TX 78550
(512) 425-6010
Region 5
Aranaas. Bee. Brooks. Calhoun,
Dewitt, Dnval, Goliad, Jackson.
Jim WeUs, Kennedy. Kleberg.
Lavaca, Live Oak. McMullen,
Nneces, Refugio, San Patricio.
and Victoria Counties
Tom Palmer, Director
1231 Agnes St, Suite #103
Corpus Christl. TX 78401
(512) 882-5828
Region 6
Andrews, Borden, Coke,
Concho, Crane, Crockett,
Dawson, Ector. Gaines,
Glasscock, Howard. Irion.
Loving, Martin, McCulloch,
Menard, Midland, Pecos.
Reagan, Reeves, San Saba,
Schleicher. Sterling. Sutton.
Terrell, Tom Green. Upton.
Ward, and Winkler Counties
Charley Sims. Director
1901 East 37th Street. Suite 101
Odessa. TX 79762
(915) 367-3871
Region?
Austin, Brazoria, Chambers,
Colorado. Fort Bend, Galveston.
Harris. Liberty. Matagorda.
Montgomery, Walker, Waller,
and Wharton Counties
Herbert W. Williams, Jr., Director
5555 West Loop, Suite 300
Bellalre.TX 77401
(713) 666-4964
Regions
Collin. Cooke. Dallas, Denton,
Ellis, Erath. Fannin, Grayson.
Hood, Hunt. Johnson,
Kaufman, Palo Pinto, Parker,
Rockwall, SomerveU, Tarrant,
and Wise Counties
MeMn Lewis. Director
6421 Camp Bowie Blvd.. Suite
312
Fort Worth. TX 76116
(817) 732-5531
Region 9
Atascosa. Bandera, Bezar,
Comal, Dimmit, Edwards. Frio,
Gillespie. Gonzalea. Guadelnpe.
Karnes, Kendall, Kerr, Kimble.
Kinney. La Salle, Mason.
Maverick. Medina. Real.
TJvalde. Val Verde, Wilson, and
Zapata Counties
James Menke. Director
4335 Pledras West, Suite 101
San Antonio. TX 78228
(512) 734-7981
18
-------
Region 6 State Contact*
Region 10
Angelina. Hardln, Houston,
Jasper, Jefferson,
Nacogdoches, Newton, Orange,
Polk, Sabine, San Augustine,
San Jaeinto, Shelby, Trinity,
and Tyler Counties
Vic Fair, Director
4605-B Concord Road
Beaumont, IX 77703
(409) 838-0397
Region 11
firewater, Culbertson, El Paso,
Hndspeth, Jeff Davis, and
Presidio Counties
Manuel Agulrre, P.E.. Director
1200 Golden Key Circle. Suite
369
El Paso, TX 79925
(915) 591-8128
Region 12
Anderson. Bowie, Camp. Cass,
Cherokee, Delta. Franklin.
Gregg, Harrison. Henderson.
Hopkins. Lunar, Marion.
Morris. Panola. Rains, Red
River. Rusk. Smith. Titus,
Upshur, Van Zandt, Upshur and
Wood Counties
Richard Leant. P.E., Director
1304 South Vine Avenue
Tyler. TX 75701
(214) 595-2639
Region 7 State Contacts
Nebraska
REGION 7
Iowa
Kansas
Missouri
KurtEskew
Air and Toxic Division
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
Gary Miller
Asbestos Control Program
Kansas Dept. of Health and
Environment
Forbes Field, Building 740
Topeka, KS 66620-0001
(913) 296-1550
MlkeTharpe
Chief of Enforcement
Air Pollution Control Program
Missouri Dept of Natural
Resources
P.O. Box 176
Jefferson City. MO 65102
(314) 751-4817
Greene County-Springfield
Ron Boyer or Bryan Adams
Air Pollution Control
Health Unit
Greene County-City of Springfield
Health Dept
227 East Chestnut Expressway
Springfield, MO 65802
(417) 864-1663
City
Paul Stablcln or Jennifer Logan
Kansas City Air Quality Program
414 East Twelfth Street. 21st
Floor
Kansas City. MO 64106
(816) 274-2501
St. Louis
Ronald Stelnkamp
Division of Air Pollution Control
City Hall, Room 4 19
St. Louis. MO 63103
(314) 662-3334
St. Louis County
Dan Overton
St. Louis County Air Pollution
Branch
111 South Meramec Avenue
Clayton. MO 63105
(314) 854-6912
Nebraska DepL of Environmental
Control
P.O. Box 94877
State House Station
Lincoln. ME 68509
(402)471-2186.
Jacqueline Fiedler
Division of Asbestos Control
Nebraska Dept of Health
301 Centennial Mall South
P.O. Box 94877
Lincoln. NE 68509-5007
(402) 471-2541
tf»r County
Gary Walsh
Air Pollution Control Section
Division of Environmental Health
Lincoln-Lancaster County Health
Dept
2200 St Marys Avenue
Lincoln. NE 68502
(402) 471-8039
Omaha
Chester Black
Air Quality Control Division
5600 South 10th Street
Omaha. NE 68107
(402) 444-6015
19
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Region 8 State Contact*
Region 9 State Contact*
REGION 8
Colorado
Montana
North Dakota
South Dakota
tah
>ming
Alan Savllle or Steve Fine
Compliance Monitoring and
Enforcement Section
Air Pollution Control Division
Stationary Sources Program
Colorado Dept of Health
4210 East 11th Avenue
Denver, CO 80220
(303) 331-8509
Denver
Jack Bendtxon
Denver Dept. of Health and
Hospitals
605 Bannock
Denver, CO 80204
(303) 893-6243
Warren Norton
Air Quality Bureau
Dept. of Health and
Environmental Sciences
Cogswell Building
Helena, MT 59620
(4O6) 444-3454
KenWangler
State Dept. of Health and
Consolidated Laboratories
1200 Missouri Avenue
P.O. Box 5520
Bismarck. ND 58502-5520
(701) 224-2348
Office of Air Quality and Solid
Waste
Division of Water and Natural
Resources .
Joe Foss Building
Pierre. SD 57501
(605) 773-3153
Kent Bott
Bureau of Air Quality
Dept. of Health
P.O. Box 16690
Salt Lake City. UT 84116-0690
(801) 538-6108
Salt Lake Citr County
Donald K. Horsley
Salt Lake City County Health
DepL
610 South 200 East
Salt Lake City. UT 84111
(801) 534-4516
F. Gerald Blackwell
Air Quality Division
Dept of Environmental Quality
122 West 25th Street
Cheyenne. WY 82002
(307) 777-7391
REGION 9
Arizona
California
Wayne Hunt
Office of Air Quality
Arizona Dept. of Environmental
Quality
2005 North Central Avenue
Room 603C
Phoenix. AZ 85004
(602) 257-2276
Pima County
John Bartlett
Pima County AQCD
150 West Congress Street
Tucson. AZ 85701
Maricopa County
Stephen Olson
Maricopa County APCD
P.O. Box 2111
Phoenix. AZ 85001
(602) 258-6381 x5O6
California Air Resources Board
1101 "R" Street
Sacramento. CA 95812
Contact: Francis Mateo
(916) 322-3976
For Information:
Charles Kersey
CARB Compliance Division
P.O. Box 2815
Sacramento. CA 95812
(916) 322-8272
Alameda. Contra Costa. Marin.
Napa, Saa Francisco, San
Mateo, Santa Clara, South
Sonoma and South Solano
Counties
Public Information
Bay Area AQMD
939 Ellis Street
San Francisco, CA 94109
(415)771-6000x210
Fresno County
Bob Bashian
Fresno County APCD
P.O.Box 11867
Fresno, CA 93775
(209) 445-3239
Bnmboldt, Del Norte, Trinity
Counties
Leonard Herr
North Coast Unified AQMD
5630 South Broadway
Eureka, CA 95501
(707) 443-3093
-------
Region 9 State Contact*
Kern County
Jon Adams
Kern County APCD
2700 "M" Street. Suite 275
Bakersfield, CA 93301
(805) 861-3662
King* County
Mark Polndexter or Chuck Hanna
Kings County APCD
330 Campus Drive
Hanford. CA 93230
(209)584-1411
Lake County
John Thompson
Lake County AQMD
883 Lakeport Blvd.
Lakeport, CA 95453
(707) 263-7000
Los Angeles. Orange, Riverside.
and San Bernardino (except
Desert
Portion) Counties
Paul Aunchman
South Coast AQMD
9150 Flair Drive
El Monte. CA 91731
(818) 572-6195
loaders. County
BillSturk
Madera County APCD
135 West Yosemlte Avenue
Madera, CA 93637
(209) 675-7823/24/25
Mendocino County
Philip Towie
Mendodno County APCD
Courthouse
Uklah. CA 95482
(707) 463-4354/5458
Merced County
John Lathrop
Roland Brooks. Asst APCO
Environmental Health
Merced County APCD
385 East Thirteenth Street
Merced. CA 95340
(209) 385-7391
Modoc County
Clinton B. Greenbank
Modoc County APCD
202 West Fourth Street
Alturas. CA 96101
(916) 233-3939 x401
Mono, Inyo. and Alpine
Counties
Larry Cameron or Duane Ono
Great Basin Unified APCD
157 Short Street
Bishop, CA 93514
(619)872-8211
Monterey County
EdKendig
Monterey Bay Unified APCD
1164 Monroe Street. Suite 10
Salinas. CA 93906-3596
(408)443-1135
Northern Sonoma County
George Erdman
Northern Sonoma County APCD
109 North Street
Healdsburg. CA 95448
(707)433-5911
Sacramento County
Asbestos Coordinator
Sacramento Metropolitan AQMD
8475 Jackson Road. Suite 215
Sacramento, CA 95826
(916) 386-6650
San Bernardino County
(Desert Portion)
Richard Wales or Steve Jenkins
San Bernardino County APCD
15428 CMC Drive, Suite 200
Vlctorvllle. CA 92392
(619) 243-8200
San Diego County
Jimmy Cooksey
San Diego County APCD
9150 Chesapeake Drive
San Diego. CA 92123
(619) 694-3340
San Joaquin County
San Joaquin County APCD
P.O. Box 2009
Stockton, CA 95201
ATTN: i-afc-Hintr Grcwal
APCD Director
(209) 468-3400
Contact: Jim Czarneckl
(209) 468-3476
San Luis Obispo County
San Luis Obispo County APCD
2156 Sierra Way. Suite B
San Luis Obispo. CA 93401
(805) 549-5912
Santa Barbara County
George F. Tise, D
Santa Barbara County APCD
240 East Highway 246. Suite 207
BueUton. CA 93427
(805) 686-5012
-------
Region 9 State Contact*
Region 10 State Contact*
vaii
ida
Stanislaus County
Mark Macedo
Stanislaus County APCD
1716 Morgan Road
Modesto. CA 95351
(209) 525-4152
Tnlare County
Joel Martins
Environmental Health Division
Tulare County APCD
Health Building
County Civic Center
Visalla. CA 93291
(209) 733-6441
Ventura County
Jay Nicholas
Ventura County APCD
800 South Victoria Avenue
Ventura. CA 93009
(805) 654-5031 .
Tolo and Northern Solano
Counties
Bill Schuldt
Yolo-Solano County APCD
P.O. Box 1006
Woodland. CA 95695
(916) 666-8146/47
Ken Hall
Clean Air Branch
Hawaii Dept of Health
P.O. Box 3378
26 llKUlhau Street
Honolulu. HI 96801
(808) 543-8200
Waahoe County .
Brian Wright
Environmental Health/Air
Quality
Washoe County District Health
Dept
P.O. Box 11130
1001 East Ninth Street
Reno. NV 89520
(702) 328-2620
Clark County
Harold Glasser
Air Pollution Control Division
Clark County Health District
P.O. Box 4426
Las Vegas. NV 89127
(702) 383-1276
REGION 10
Alaska
Idaho
Oregon
For Notification
Tom Wilson
Alaska Operations Office
U.S. EPA
Room 537. Federal Building
222 W. 7th Ave. #19
Anchorage. AK 99513-7588
(907) 271-5083
For Disposal
Alaska Dept of Environmental
Conservation
3601 C Street Suite 1350
Anchorage. AK 99503
(907) 563-6529
TimTrumbuIl
U.S. EPA
422 W. Washington Street
Boise. ID 83702
(208) 334-1626
SaraAnnltage
State Asbestos Program
Oregon Dept of Environmental
Quality
611 S.W. 6th Avenue
Portland, OR 97204
(503) 229-5186
Lane County
Tom Freeman
Lane Regional Air Pollution
Control Authority (LRAPA)
225 North 5th Street Suite 501
Springfield. OR 97477
(503) 726-2514
22
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Region 10 State Contact*
Washington Ken Fukutoml
Washington Dept of Ecology
4350 150th Avenue NE
Redmond, WA 98502
(206) 867-7107
Tri-Conntiei
J. Phillip Cooke
Trt-Countles Air Pollution Control
Authority
650 George Washington Way
Richland. WA 99352
(509) 946-4489
Northwest
Terry Nyman
Northwest Air Pollution Authority
302 Pine Street. Suite 207
Mount Vernon. WA 98273
(206) 428-1617
Olympic
Chuck Peace
Olympic Air Pollution Control
Authority
120 East State Avenue
Olympla. WA 98103
(206) 586-0593 xlOO
Puget Sound
JoeEng
Puget Sound Air Pollution
Control Agency
200 West Mercer Street. Room
205
Seattle, WA 98119-3958
(206) 296-7335
Southwest
Richard Serdoz
Southwest Air Pollution Control
Authority
1308 N.E. 134th St. Suite D
Vancouver. WA 98685-2747
(206) 574-3058
(800) 633-0709
Spokane
Ron Edgar
Spokane County Air Pollution
Control Authority
W. 1101 College Avenue,
Room 230
Spokane. WA 99201
(509) 456-4727 x!05
Yakima County
Yakima County Clean Air
Authority
County Courthouse
Yakima. WA 98901
(509)575-4116
23
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State Index
Page
Alabama 14
Alaska 22
Arizona 20
Arkansas 17
California 20
Colorado 20
Connecticut 13
Delaware 13
District of Columbia 13
Florida 14
Georgia 15
Hawaii 22
Idaho 22
Illinois 16
Indiana 16
Iowa 19
Kansas 19
Kentucky 15
Louisiana 17
Maine 13
Maryland 14
Massachusetts 13
Michigan , 16
Minnesota 16
Mississippi 15
Missouri 19
Montana 20
Nebraska 19
Nevada 22
New Hampshire 13
Page
New Jersey 13
New Mexico 17
New York 13
North Carolina 15
North Dakota 20
Ohio 16
Oklahoma 17
Oregon 22
Pennsylvania 14
Puerto Rico . 13
Rhode Island 13
South Carolina 15
South Dakota 20
Tennessee 16
Texas 17
Utah 20
Vermont 13
U.S. Virgin Islands 13
Virginia 14
Washington 23
West Virginia 14
Wisconsin 16
Wyoming 20
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ITEMS
Common Questions On The Asbestos NESHAP
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^
*. e
-
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Common Questions
On The Asbestos NESHAP
United States
Envrionmental Protection Agency
Office Of Air Quality Planning and Standards
Stationary Source Compliance Division
December 1990
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Common Questions on the Asbestos NESHAP
Contents Introduction 1
General Information 2
NESHAP Jurisdiction 3
Notifications 6
Removal 9
Ordered Demolitions 10
Friable and Non-Friable Asbestos 11
Transport and Disposal 12
Monitoring and Sampling 14
Inspections 15
Training 17
Violations and Penalties 17
MARS 19
Additional Information 21
Glossary of Terms 22
AHERA and NESHAP Coordinators 24
snber 1990
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DISCLAIMER
This manual was prepared by Entropy Environmentalist, Inc. for the Stationary Source
Compliance Division of the U.S. Environmental Protection Agency. It has been completed in
accordance with EPA Contract No. 68-02-4462, Work Assignment No. 90-123. This
document is intended for information purposes ONLY, and may not in any way be interpreted
to alter or replace the coverage or requirements of the asbestos National Emission Standards
for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M. Any mention of
product names does not constitute endorsement by the U.S. Environmental Protection Agency.
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Asbestos NESHAP Questions
Common Questions on the Asbestos NESHAP
Introduction The dean Air Act (CAA) requires the U. S. Environmental Protection Agency (EPA) to
develop and enforce regulations to protect die general public from exposure to
airborne contaminants that are known to be hazardous to human health. In
accordance with Section 112 of the CAA, EPA established National Emissions
Standards for Hazardous Air Pollutants (NESHAP) to protect the public. Asbestos
was one of the first hazardous air pollutants regulated under Section 112. On March
31, 1971, EPA identified asbestos as a hazardous pollutant, and on April 6,1973,
EPA first promulgated the Asbestos NESHAP in 40 CFR Part 61.
In 1990, a revised NESHAP regulation was promulgated by EPA. Information
contained in this pamphlet is consistent with the amended regulation.
This pamphlet answers the most commonly asked questions about the Asbestos
NESHAP for demolitions and renovations. Many of (he questions included in this
pamphlet have been raised by demolition and renovation contractors in recent years.
Most questions relate to how a demolition or renovation contractor or building
owner can best comply with the regulation. The responses assume that the
questioner has a basic understanding of me Asbestos NESHAP and demolition and
renovation practices. A brief glossary of terms is also included at the back of the
pamphlet.
The Asbestos NESHAP regulations protect the public by minimizing the release of
asbestos .fibers during activities involving the processing, handling, and disposal of
asbestos-containing material. Accordingly, the Asbestos NESHAP specifies work
practices to be followed during demolitions and renovations of all structures,
installations, and buildings (excluding residential buildings That have four or fewer
dwelling units). In addition, the regulations require the owner of the building
and/or the contractor to notify applicable State and local agencies and/or EPA
Regional Offices before all demolitions, or before renovations of buildings that
contain a certain threshold amount of asbestos.
For more information about the Asbestos NESHAP or for answers to questions not
covered in this pamphlet, contact the delegated State or local agency or the
appropriate EPA Regional Office listed on page 24.
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Asbestos NESHAP Questions
General What Is the purpose of the Asbestos NESHAP regulation?
Information
The purpose is to protect the public health by minimising the release of asbestos
when facilities which contain asbestos-containing materials (ACMs) are demolished
or renovated.
How much regulated asbestos-containing material (RACM) Is disposed of
annually from demolition/renovation operations?
Approximately 5.7 million cubic feet of RACM is disposed of annually. In accordance
with the regulation, most RACM is taken to landfills, where it is covered by soil or
other debris in order to keep it from releasing asbestos fibers.
What Is the difference between demolishing a facility and renovating tt?
"Demolition' and "renovation* are defined in the regulation. You "demolish* a facility
when you remove or wreck any load-supporting structural member of that facility or
perform any related operations; you also 'demolish' a facility when you burn it. You
"renovate" a facility when you alter any part of that facility in any other manner.
Renovation includes stripping or removing asbestos from the facility.
What percentage of asbestos related activities Involve demolitions?
Demolitions comprise approximately 10% of all reported asbestos-related activities.
Is there a numeric emission limit for the release of asbestcs fibers during
renovations or demolitions in the asbestos NESHAP regulation?
No, the Asbestos NESHAP relating to demolitions or renovations is a work practice
standard. This means that it does not place specific numerical emission limitations
for asbestos fibers on asbestos demolitions and removals. Instead, it requires specific
actions be taken to control emissions. However, the Asbestos NESHAP does specify
zero visible emissions to the outside air from activity relating to the transport and
disposal of asbestos waste.
c2zber 1990
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Asbestos Nc£»J ?.-.._-.:
Who Is resparoslDiE to' err1arc;nr tne Acses;os KES.-.i<~ r.r'-.CL-cr'
Under Section 112 of the dean Air Act, Congress gave EPA the responsibility for
enforcing regulations relating to asbestos renovations and demolitions. The CAA
allows EPA to delegate this authority to State and local agencies. Even after EPA
delegates responsibility to a State or local agency, EPA retains the authority to
oversee agency performance and to enforce NESHAP regulations as appropriate.
As of October 1990, approximately 45 states.
As defined in the regulation, a "facility* is any institutional, commercial, public,
industrial or residential structure, installation or building (including any structure,
installation or building containing condominiums, or individual dwelling units
operated as a residential cooperative, but excluding residential buildings having four
or fewer dwelling units); any ship; or any active or inactive waste disposal site. Any
building, structure or installation mat contains a loft used as a dwelling is not
considered residential. Any structure, installation, or building that was previously
subject to the Asbestos NESHAP is not excluded, regardless of its current use or
function*
If I renovate several two-family units, are the units defined cs e facility?'
Residential buildings which have four or fewer dwelling units are not considered
facilities' unless they are pan of a larger installation (for example, an army base,
company housing, apartment or housing complex, part of a group of houses subject
to condemnation for a highway right-of-way, an apartment which is an integral part
of a commercial facility, etc.).
Are mobile homes or mobile structures regulated by the Asbestos
NESHAP?
Mobile homes used as single-family dwellings are not subject to Asbestos NESHAP.
Mobile structures used for non-residential purposes are subject to NESHAP.
c2sber 1990
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Asbestos NESHAP Questions
Are Federal facilities regulated by the Asbestos NESHAP?
Yes.
Are single-family private residences regulated by the Asbestos NESHAP?
No.
How much asbestos must be present before the Asbestos NESHAP work
practice standards apply to renovation projects?
Asbestos NESHAP regulations must be followed for all renovations of facilities with at
least 80 linear meters (260 linear feet) of regulated asbestos-containing materials
(RACM) on pipes, or 15 square meters (160 square feet) of regulated asbestos-
containing material? on other facility components, or at least one cubic meter (35
cubic feet) off facility components where the amount of RACM previously removed
from pipes and other facility components could not be measured before stripping.
These amounts are known as the "threshold11 amounts.
How much asbestos must be present before the Asbestos NESHAP work
practice standards apply to demolition projects?
Asbestos NESHAP regulations must be followed for demolitions of facilities with at
least 80 linear meters (260 linear feet) of regulated asbestos-containing materials
(RACM) on pipes, 15 square meters (160 square feet) of regulated asbestos-
containing materials on other facility components, or at least one cubic meter (35
cubic feet) off facility components where the amount of RACM previously removed
from pipes and other facility components could not be measured before stripping.
However, all demolitions must notify the appropriate regulatory agency, even if no
asbestos is present at die site, and all demolitions and renovations are 'subject* to
the Asbestos NESHAP insofar as owners and operators must determine if and how
much asbestos is present at the site.
December 1990
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Asbestos NESHAP Questions
Are homes that are demolished or renovated to buiid non-residential
structures regulated by the Asbestos NESHAP?
Yes. For example, homes which are demolished as pan of an urban renev/al project,
a highway construction project, or a project to develop a shopping mall are regulated
by the Asbestos NESHAP.
A single home which is convened into a non-residential structure is also regulated by
the Asbestos NESHAP. For example, if someone buys a house and converts it into a
store, the renovation is subject to the Asbestos NESHAP.
If e renovation site is abandoned, Is the site stll! regulated by the Asbestos
NESHAP?
Yes. Even after a renovation site is abandoned, it is still regulated by the Asbestos
NESHAP.
What Is encapsulation, and Is It regulated by the Asbestos NESHAP?
Encapsulation is die application of a material with a sealant to stop it from releasing
fibers. Normally, encapsulation is not regulated by the Asbestos NESHAP unless it
involves removing or stripping asbestos. However, if encapsulation is done using
methods that damage asbestos and release fibers it would be covered. For example,
high pressure spraying to apply encapsulant could damage asbestos. Also, if friable
RACM is encapsulated, the RACM is still covered by me Asbestos NESHAP if
renovation or demolition occurs.
Are offshore oil rigs regulated In terms of asbestos removal and
demolition?
Yes. Federal jurisdiction extends to the continental shelf (100 miles). When EPA
delegates authority to State or local agencies, the State and local agencies are usually
considered to have authority only in territorial waters (12 miles). The Department of
the Interior is still evaluating whether States may extend their jurisdiction beyond
territorial waters. EPA currently enforces the NESHAP between territorial waters and
die continental shalf.
December 1990
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Asbestos NESHAP Questions
Notifications What is a notification?
A notification is a written notice of intent to renovate or demolish. Notifications
must contain certain specified information, including but not limited to, the
scheduled starting and completion date of the work, the location of the site, the
names of operators or asbestos removal contractors, methods of removal and the
amount of asbestos, and whether die operation is a demolition or renovation.
See Section §61.145 (b) of the Asbestos NESHAP regulation.
Whom do I notify?
You should notify the delegated State/Local Pollution Control Agency in your area
and/or the EPA Regional Office of the demolition or renovation operations subject to
NESHAP. Some EPA Regions require that bom the EPA Regional Office and the local
delegated agency be notified, while some require notice only to the delegated State
or local agency. If the program is not delegated, notify the EPA Regional Office.
How do I notify?
Mail or hand-deliver the notification to the appropriate agency.
Are teiefaxed or telephone notifications acceptable?
No. Teiefaxed notifications are not accepted. Telephone notifications are only
acceptable in emergency situations at the discretion of the EPA Regional Office or
delegated agency and must be followed with a written copy by the following working
day.
Who is responsible tor remitting a notfflceticn - the owner of the buiicilng
which is being demolished or renovated, or the contractor?
The NESHAP regulation states that either the owner of the building or operator of
the demolition or renovation operation can submit the notification. Usually, the two
parties decide together who will notify. If neither provide adequate notice, EPA can
hold either or both parties liable.
December 1990
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Asbestos NESHAP Qussasns
When e condominium complex Is being renovated, who as owner, Is
responsible for submitting & notification?
While owners and operators share responsibility for proper notification, the
condominium or co-op board is responsible as the owner. The board should ensure
that they are told when work takes place on individual units, so that they can comply
with notification (and other EPA) requirements, especially if multiple operators are
involved.
Is there c forrr or forms? for notifications?
Yes, there is a suggested form for notifications. You can obtain a form, and
instructions on how to fill it out, from your delegated State or local agency or from
your EPA Regional Office.
Do demolitions of tecllftlss In which no asbestos Is present require
nstlflsetion?
Yes. All demolitions that meet the definition of facility must notify.
When I notify regarding a renovation, what date do I consider the start
date?
For a renovation, the start date is the day that the removal of asbestos-containing
material, or any other asbestos-handling activities, including predeaning,
construction of containment, or other activities that could disturb the asbestos, will
begin.
When I notify regarding a demolition, do I give the start date of the
demolition or of the asbestos removal? Which date do I use to determine
whether I've met the 10-day waiting period?
For a demolition, the start date is the date that the removal or related activity begins.
The date the demolition starts also must be reported. The waiting period should be
calculated based on the start date of the removal or the demolition, if no removal is
required. The waiting period is necessary to give inspectors time to visit me site
before activity begins.
December 199Q
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Asbestos NESHAP Questions
Does the 10-day notification requirement refer to 'calendar' days or
working' days?
The Asbestos NESHAP regulation specifies "working days.' Holidays that fall
between Monday and Friday count as "working days."
What is a 'nonscheduled renovation operation*?
A "nonscheduled renovation operation" is a renovation operation that is caused by
the routine failure of equipment which is expected to occur based on past operating
experience, but for which an exact date cannot be predicted.
Do I have to notify for non-schedu!ed operations? When?
Yes, if you can predict based on past experience that renovations will be necessary
during the calendar year and the amount of asbestos is likely to exceed die
jurisdictional amount, notification is required. This notification must be submitted at
least 10 working days before the end of the calendar year preceding the year for
which notice is being given.
Note: Single renovation projects which exceed the threshold amount are not covered
by this type of notice. A separate notification is required for these projects.
Must I notify the agency again if 1 know that a specific renovation project
Involving more than the threshold amount (Including the work covered by
the calendar year notice for non-scheduled operations) is about to ccsur at
a specific time?
Yes.
What constitutes an emergency renovation?
An emergency renovation is a renovation that was not planned, but results from a
sudden, unexpected event that either immediately produces unsafe conditions, or
that, if not quickly remedied, could be reasonably foreseen to result in an unsafe or
detrimental effect on health or is necessary to protect equipment and avoid
unreasonable financial burden. The term includes renovations necessitated by non-
routine equipment failures. For example, the explosion of a boiler in a chemical
plant might require emergency renovations, since such an explosion would disrupt
December 1990
8
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Asbestos NESHAP Questions
normal operations. However, renovations involving routine repairs are not
emergencies.
Under what conditions must I notify for emergency renovEticnc? When
must I notify?
First, inspect the facility and determine the amount of RACM that may have to be
removed or disturbed to repair the facility. (If you don't have the time to have
samples analyzed, you should assume that all insulation is RACM.) Then, if the
amount of RACM is in excess of the threshold amount, you should mail or deliver a
notification as soon as possible, but certainly no later than the following workday. A
notification which is postmarked more than one working day after the emergency
will be considered in violation of die notification requirements. EPA recommends
that you send the notice by overnight express mail, and that you phone in a
notification as well to the delegated agency and/or EPA Regional Office.
When does a notification need to be revised?
A notification must be revised if information contained in the original notice has
changed. For example, you must revise the notification if you change the start date
of an operation. If the change relates to the amount of RACM involved, you need
only revise the notification if die amount changes by more than 20 percent.
When do I submit a revised notification?
You should telephone EPA as soon as possible after you realize the revision is
necessary, and should dien mail or hand deliver .a written notice. If you delay the
start date of a project, EPA must receive the revised notification no later than the
original start date. If you plan to begin work before die date specified in die original
notice, EPA must receive die revised notice at least 10 working days before die
revised start date.
emoval Does the Asbestos NESHAP require a building owner or operator to remove
damaged or deteriorating asbestos-containing material?
No. Not unless a renovation of die facility is planned which would disturb die ACM
and it exceeds die direshold amount.
December 1990
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Asbestos NESHAP Questions
What does 'adequately wet* mean?
To "adequately wet* ACM means to sufficiently mix or penetrate die material with
liquid to prevent die release of particulates. If visible emissions are observed coming
from ACM, then die material has not been adequately wetted. However, die absence
of visible emissions is not evidence of being adequately wet.
If a contractor puts water in tne octtcm of £ bag, then strips the friable
asbestos material dry and lets 'A fail Into the water, Is this a vicisticn of the
Asbestos NESHAP standards?
Yes. The regulation states that friable asbestos-containing material must be
'adequately wet* during stripping operations. The material must remain wet until
disposal.
Section 61.145(c)(6)(HI) states that the operator must transport the
materials to the ground via dust tight chutes or containers If it has been
removed or stripped more than 53 feet above ground level.' Can a room
sealed with plastic and a negative air system be considered a dust tight
chute?
No, me area in which removal is being conducted (die containment area) cannot be
considered a dust tight chute in order to comply widi §61.145(c)(6)(iii).
C reared ff a facility & be!rc ismci «:?« uri«" *n cr^-r ?* 2 St-m :* '?-..
Demolitions ^cvsmrrant S^s^'jc* ^-s -it-11*" ;* rtrjrr:rr'^. ±r.zc^r~ ;. - :r3
jnasfs, do all Lw.c -rr-r-- --.-:.--- ?cv-r'--; r^-C:-;-.-. ^55,
No. The regulations which do apply are specified in §61.145 (a) (3) of the
regulation.
If a facility Is being demciLir.sc; -ncJsr an arc!er of a Stata zr jccal
govarnment, must aii th» iscrs b« *r ;«*t?c :ss a?!:«3tss-c3rTa.r:;r3t~i
waste?
If, for safety reasons, the RACM in the facility is not removed prior to demolition, the
RACM must be kept adequately wet during die wrecking operations. After
wrecking, all the contaminated debris must be kept adequately wet until disposal
December 1990
10
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S
All contaminated debris which cannot be segregated and cleaned should be disposed
of as asbestos waste.
Friable £.r>
Ncn-Fr;c:'
As-bestos
Wrist IE trieble esoectr-f-so-rsir.;:^ meisrial?
Friable ACM is any material containing more than one percent asbestos (as
determined by Polarized Light Microscopy) that, when dry, may be crumbled,
pulverized, or reduced to powder by hand pressure.
\Vnfit !s
Non-friable ACM is any material containing more than one percent asbestos (as
determined by Polarized Light Microscopy) that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure. Under the Asbestos NESHAP,
non-friable ACM is divided into two categories. Category I non-friable ACM are
asbestos-containing resilient floor coverings (commonly known as vinyl asbestos tile
(VAT)), asphalt roofing products, packings and gaskets. These materials rarely
become friable. All other non-friable ACM are considered category II non-friable
ACM.
Must I remove category I non-friable material prior to demolition or
renovation?
Under normal circumstances, category I non-friable materials need not be removed
prior to demolition or renovation, because generally these materials do not release
significant amounts of asbestos fibers, even when damaged. This is not, however, a
hard and fast rule. If category I materials have become friable or are in poor
condition, they must be removed. Also, if you sand, grind, abrade, drill, cut or chip
any non-friable maw'8*1*, including category I materials, you must treat the material
as friable, if more than the jurisdictional amount is involved.
Must I remove category II non-friable materials prior to demolition or
renovation?
These materials should be evaluated on a case-by-case basis. If category n non-
friable materials are likely to become crushed, pulverized or reduced to powder
during demolition or renovation, they should be removed before demolition or
renovation begin. For example, A/C (asbestos cement) siding on a building that is
Seceaber 1990
11
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Asbestos NESHAP Questions
going to be demolished with a wrecking ball should be removed, because it is likely
that the siding will be pulverized by the wrecking ball.
Does non-friable waste, If broken, damaged, etc., have to be wetted and
contained?
Non-friable ACM that has been damaged during a demolition or renovation operation
such that some portions of the material are crumbled, pulverized or reduced to
powder is covered by the Asbestos NESHAP if the facility contains more than the
threshold amount of RACM. However, category II non-friable ACM that has a high
probability of being damaged by the demolition or renovation forces expected to act
on the materials such that it will be crumbled, pulverized, or reduced to powder
must be-removed prior to the demolition or renovation operation. It is the owner's
or operator's responsibility to make these determinations.
Transport How should I handle bulk waste from a facility that contained RACM and
and Disposal that was not found until after demolition began?
The demolition debris must be treated as asbestos-containing waste. Adequately wet
the demolition debris until collected for disposal and during loading, transport it in
covered vehicles and emit no visible emissions to the outside air as required by
§61.150. The waste must be deposited at an acceptable waste disposal site.
Can I transport bulk asbestos waste without placing It In containers as long
as I keep the waste pile wet?
No. After wetting, seal all asbestos-containing waste material in leak-tight containers
while wet and label with the appropriate signs and labels. If the waste will not fit
into containers, it must be placed in leak-tight wrapping.
However, for facilities that are demolished without removing the RACM and for
ordered demolitions, the material must be adequately wet after the demolition has
occurred and again when loading the material for transport to a disposal site. RACM
covered by this paragraph may be transported in bulk without being placed in leak-
tight containers or wrapping.
December 1990
12
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Asbestos NESHAP Questions
How should I label asbestos-containing waste that is being taken away from
the facility?
You should label the containers or wrapped materials with the name of the waste
generator and the location at which the waste was generated. An OSHA warning
label must also be used.
Does EPA license landfills for asbestos waste?
The EPA does not license asbestos landfills under the Clean Air ACL. However, it has
established asbestos disposal requirements for active and inactive disposal sites under
the NESHAP, and general requirements for solid waste disposal under the Resource
Conservation and Recovery Act (RCRA). In addition, State and/or local agencies
usually require asbestos landfills to be approved or licensed.
Where can I obtain a list of licensed landfills?
State and local agencies which require handling or licensing procedures can supply a
list of "approved" or licensed asbestos disposal sites upon request. Solid waste
control agencies are listed in local telephone directories under State, county or city
headings.
What should the owner or operator of a waste disposal site do If It is
determined that there is a discrepancy between the amount of waste that left
the facility and the amount of waste that was delivered to the site?
The waste site owner or operator must contact the demolition/renovation owner or
operator, and attempt to reconcile the discrepancy. If they cannot do so within 15
days after the waste was received, the waste site owner or operator must notify both
the delegated agency responsible for the facility from which the waste was removed,
and the delegated agency responsible for the area in which the waste was disposed.
Can water be considered 'six-Inch compacted non-asbestos cover? In other
words, could asbestos covered components be dropped In the ocean?
December
13
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Asbestos NESHAP Questions
Monitoring
and
Sampling
Does the NESHAP regulation require air monitoring during renovation or
removal?
No.
Does the Asbestos NESHAP regulation require me to Inspect my property for
asbestos?
No, not unless demolition or renovation is planned. The only Federal regulation
which requires general inspections are the AHERA regulations, which mandate that
schools must be inspected for asbestos. The NESHAP regulation requires that you
inspect for asbestos before demolition or renovation.
What Is the acceptable exposure/ambient air standard for asbestos?
EPA does not specify an acceptable exposure/ambient air standard.
What is a bulk sample?
A bulk sample is a solid quantity of insulation, floor tile, building material, etc., mat
is suspected of containing asbestos fibers mat will be analyzed for the presence and
quantity of asbestos.
Will EPA test my building for asbestos for me?
No. Owners and operators are responsible for getting their buildings tested.
How can I find someone to do the testing?
The National Institute of Standards and Technology (NIST) publishes a yearly listing
of accredited laboratories enrolled in the National Voluntary Laboratory Accreditation
Program (NVLAP). Then, on a quarterly basis NIST publishes updates to the master
list detailing labs newly accredited, labs which have had their accreditation
suspended, etc. Contact NIST NVLAP for a current listing of accredited labs. The
NIST NVLAP number is listed at the end of this pamphlet, along with other contact
numbers.
December 1990
14
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Asoestos NESHA? Q-ueiDons
Does EPA accredit laboratories that test for asbestos?
No. EPA, under CFR Pan 763, requires local education agencies to use laboratories
accredited by the National Institute of Standards and Technology (NIST) in its
National Voluntary Laboratory Accreditation Program (NVLAP). It is recommended
for NESHAP related projects that MIST accredited laboratories be used.
how do laboratories analyze bulk samples?
Laboratories analyze bulk samples a number of ways. Most laboratories use
Polarized Light Microscopy (PLM). Some laboratories use Transmission Electron
Microscopy (TEM). However, there is currently no published method for bulk
analysis using TEM.
How much doss it cost to have a bulk sample analyzed?
The cost varies with the method. The cost of PLM analysis ranges from $20.00 to
$100.00. The average cost is $30.00. TEM analysis is more expensive.
inspections Does an inspector have the right to enter any facility and the containment area?
Yes. All inspectors have the right under the dean Air Act to inspect any. facility and
the containment area. Inspectors are trained and equipped to do this safely.
If I can see ACM dust inside the containment area or inside a glovebag, Is this
a violation of the Asbestos NESHAP?
The observation of ACM dust will be used as evidence of a violation of the
"adequately wet" requirement. This is consistent with the definition of adequately
wet that requires enough wetting "to prevent the release of particulates."
Is visible asbestos-containing debris on the ground outside a removal job
considered a "visible emission," and a violation of the NESHAP?
Yes. Dry friable asbestos insulation on the ground violates the "adequately wet"
requirement, and can be considered evidence of a visible emission.
'ecember 1990
15
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Asbestos NESHAP Questions
Is It appropriate for an Inspector to open any bags outside the designated
contaminated area?
Yes. The inspector may open any bags outside the designated contaminated area to
inspect them. The inspector may use a glovebag or other control techniques. The
inspector will then properly reseal the bag, or request that the operator do so.
Must an Inspector witness Improper removal of more than 160 square feet or
260 linear feet of asbestos-containing material to prove a violation of the
NESHAP regulation?
No. First, the inspector must gather information about the quantity of asbestos to
prove that the project is subject to the NESHAP standards. Second, the inspector
must prove that there has been improper removal. The two tasks are distinct from
each other.
Are Inspectors required to have medical examinations to ensure that they are
medically fit to wear respirators?
Yes. Several Federal provisions under OSHA, EHSD, and NIOSH require people to be
examined by a doctor and pronounced physically fit before they are permitted to
wear respirators.
Must Inspectors have personnel monitoring conducted on them during
inspections to comply with OSHA requirements for workers?
No. The inspectors do not have to comply with the work practice safety standards
required by OSHA for personnel monitoring.
Do Inspectors need to follow facility training requirements including fit testing?
No.
December 1990
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Asbestos NESHAP Questions
Training
Do contractors and employees need to be accredited?
As of November 20,1991, the Asbestos NESHAP requires a person trained in the
provisions of this rule and the means of complying with them to be on-site when
asbestos-containing material is stripped, removed, or disturbed. Under AHERA, all
contractors and employees involved in the removal and disposal of asbestos-
containing material from schools must be accredited. Additionally, many States
require that all workers be accredited before they remove asbestos from any facility.
How can t qualify as an asbestos contractor/worker/consuttant under AHERA?
You must attend and pass an EPA accredited Darning course. A list of training
courses approved by EPA is published quarterly in the Federal Register, and is
available through the TSCA hotline. The TSCA number is printed at the end of this
pamphlet, along with other contact numbers. Contact your State or local agency for
more information.
Do supervisors need to be trained?
Beginning on November 20, 1991, the Asbestos NESHAP requires at least one trained
supervisor to be present at any site at which RACM is stripped, removed, or
otherwise disturbed at any facility which is being demolished or renovated and is
regulated by NESHAP. Evidence of the training must be posted and made available
for inspection at the demolition or renovation site. Training includes, at a minimum-
applicability, notification, material identification, control procedures, waste disposal,
reporting and record keeping, asbestos hazards and worker protection. Completion
of an AHERA accredited course constitutes adequate training. Every 2 years the
trained individual is required to receive refresher training. Information about both
the training and refresher courses is available through EPA or delegated State or
local agencies.
Violations
and
Penalties
What will happen if I violate the Asbestos NESHAP?
Sanctions vary. In some cases, Notices of Deficiency (NOD) - written warnings - or
Notices of Violation (NOVs) are issued to owners or operators who violate
notification requirements. Or, depending upon the offense, EPA recommends fines
up to $25,000 per day per violation.
December 1990
17
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Asbestos NESHAP Questions
Violators of the work practice or disposal standards may be subject to either written
warnings, administrative orders or civil penalties up to $25,000 per day per violation,
depending upon the seriousness of the violation. EPA may also bring criminal
charges against violators. Some owners and operators who have knowingly violated
the Asbestos NESHAP have been sentenced to prison terms.
For more information on penalties and enforcement, see the EPA Public Information
Document entitled 'Asbestos NESHAP Enforcement.*
What Is the maximum penalty which can be assessed for NESHAP
violations?
$25,000 per day, per violation, with no absolute ma-rimum However, some NESHAP
violators may also be liable under CERCLA, and if so, the mayifnum penalty may be
much higher.
How are penalties calculated?
Penalties are computed on a case-by-case basis. The amount of asbestos involved,
the number of previous violations, the duration of the offense, the economic benefit
that accrued to the owner or operator as a result of the violation, and similar
considerations are taken into account.
What Is 'contractor listing?1
Contractors who have shown a pattern of violation, or who have been convicted of a
criminal violation, may be placed on a list of violators who are prohibited from
contracting for any jobs involving Federal money (grams, contracts, sub-grants, etc.).
Can a corporation that has changed Its name, but Is owned by an Individual
who has been listed be subject to contractor listing?
Yes.
December 1990
18
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Asbestos NtSHA? Cn:c:^;r_-
NARS
What is NARS?
NARS stands for "National Asbestos Registry System.' NARS is a computerized
database established by EPA in April, 1989. NARS stores data on the compliance
history of firms doing demolition or renovation work subject to the Asbestos
NESHAP.
What Is the purpose of NARS?
NARS is used by EPA Regional Offices as well as State and local agencies to "target*
inspections of contractors with poor compliance histories, and to monitor activity
subject to the NESHAP regulations.
-;-. K4rȣ nicrmciionT
Yes. NARS information is available through EPA Regional Offices under the
provisions of the Freedom of Information Act.
Are there any penalties for being listed In NARS as a violator?
No. NARS is only an information system. Contractors who have violations listed in
NARS may, however, be inspected more frequently than contractors who have no
violations.
Why does EPA recommend inspection targeting?
Delegated agencies receive over 60,000 notifications of planned renovation or
demolition projects each year. Because all projects cannot be inspected, EPA
recommends targeting inspections so mat agencies can make better use of their
inspection resources.
Can firms avoid future inspections based on past good performance?
Past performance is an important criterion for targeting inspections; however, other
criteria are also used. As a result of EPA guidance to State and local air pollution
agencies, many asbestos removal contractors will be inspected at least once per year.
December 1990
19
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Asbestos NESHAP Questions
How many contractors and owners are currently listed In NARS?
As of October 1990, there were approximately 7,000 contractors and owners in
NARS.
How does information get Into NARS?
Information on the number of notifications, inspections, and violations for each
contractor or owner is submitted by delegated State and local air pollution agencies
and is reported through the EPA Regional NARS Coordinators to EPA Headquarters
where the report is compiled.
December 1990
20
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Asbestos NESHAP Questions
Additional You can obtain more information about the Asbestos NESHAP by contacting your
Information EPA Regional Office's NESHAP coordinator. You can obtain more information about
AHERA by contacting your Regional Asbestos Coordinator (RAC). The addresses and
phone numbers of both the RAC and NESHAP coordinators are listed at the end of
this pamphlet.
You may also call the EPA Toxic Substances Control Act (TSCA) Hotline to ask
general questions about asbestos, or to request asbestos guidance documents. The
Hotline number is (202) 554-1404. The EPA Public Information Center can send you
information on EPA regulations. You can reach the Center at (202) 382-2080 or
(202) 475-7751.
The EPA has an Asbestos Ombudsman to provide information on the handling and
abatement of asbestos in schools, the workplace and the home. Also, the EPA
Asbestos Ombudsman can help citizens with asbestos-in-school complaints. The
Ombudsman can be reached toll-free at (800) 368-5888, direct at (703) 557-1938 or
557-1939.
To obtain a current listing of accredited labs contact MIST NVLAP at (301)975-4016.
December 1990
21
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Glossary of Terms
Glossary of Terms
AHERA
CAA
CERCLA
EPA
EHSD
Friable Asbestos
Material
Glovebag
NARS
NESHAP
NICSH
NIST
NVLAP
OSHA
Participate
Asbestos
Material
RACM
The Asbestos Hazard Emergency Response Act, passed by Congress in 1986
dean Air Act
The Comprehensive Environmental Response Compensation and Liability ACL Also
known as the "Superfund."
The United States Environmental Protection Agency
Environmental Health and Safety Division, U.S. EPA
Any material containing more than one percent asbestos, as determined using the
method specified in Appendix A, subpart F 40 CFR part 763, section 1, Polarized
Light Microscopy, that when dry, can be crumbled, pulverized, or reduced to powder
by hand pressure. If die asbestos content is less than 10 percent as determined by a
method other than point counting by polarized light microscopy (PLM), verify the
asbestos by point counting using PLM.
A sealed compartment with attached inner gloves used for the handling of asbestos-
containing materials.
National Asbestos Registry System
The National Emission Standard for Hazardous Air Pollutants found in Title 40 CFR
part 61 promulgated under Section 112 of the dean Air ACL
National Institute for Occupational Safety and Health
National Institute of Standards and Technology
National Voluntary Laboratory Accreditation Program
Occupational Safety & Health Administration
Finely divided particles of asbestos or material containing asbestos.
Regulated Asbestos-Containing Material. RACM means (a) Friable asbestos material,
(b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable
December 1990
22
-------
Glossary of Terms
ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or
(d) Category II nonfriable ACM that has a high probability of becoming or has
become crumbled, pulverized, or reduced to powder by the forces expected to act on
the material in the course of demolition or renovation operations regulated by the
Asbestos NESHAP.
RCRA Resource Conservation and Recovery Act
TSCA Toxic Substances Control Act
Visible Emission* Any emissions, which are visually detectable without the aid of instruments, coming
from RACM or asbestos-containing waste material, or from any asbestos milling,
manufacturing, or fabricating operation.
December 1990
23
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AHERA and NESHAP Coordinators
AHERA and NESHAP Coordinators
Region
NESHAP
AHERA
Region 1
CT, MA, ME
NH, RI, VT
Asbestos NESHAP Coordinator
Air Management Diviiion
US EPA
JFK Building
Boston, MA 02203
(617) 565-3265
Regional Asbestos Coordinator
US EPA
JFK Federal Building
Boiton, MA 02203
(617) 565-3835
Region 2
NJ, NY
PR, VI
Asbestos NESHAP Coordinator
Air & Waste Management Div.
US EPA
26 Federal Plaza
New York, NY 10278
(212) 264-6770
Regional Asbestos Coordinator
US EPA
Woodbridge Avenue
Edison, NJ 08837
(201) 321-6671
Region 3
DC, DE, MD
PA, VA, WV
Asbestos NESHAP Coordinator
Air and Toxics Division
US EPA
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-8683
Regional Asbestos Coordinator
US EPA
841 Chestnut Street
Philadelphia, PA 19107
(215)597-3160
Region 4
AL, FL. GA.
KY. MS. NC,
SC.TN
Asbestos NESHAP Coordinator
Air, Pesticide A Toxics Div.
US EPA
345 Counland Street
Atlanta, CA 30365
(404) 347-5014
Regional Asbestos Coordinator
US EPA
345 Courtland Street
Atlanta, GA 30365
(404) 347-5014
Region 5
IL, IN, Ml
MN. OH, WI
Asbestos NESHAP Coordinator
Air tt Radiation Division
US EPA
230 South Dearborn Street
Chicago, IL 60604
(312) 353-6793
Regional Asbestos Coordinator
US EPA
230 South Dearborn St.
Chicago, tt. 60604
(312) 353-6003
December 1990
24
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AHERA and NESHAP Coordinators
AHERA and NESHAP Coordinators
Region
NXSHAP
AHERA
Region 6
AR, LA, NM
OK, TX
Asbestos NESHAP Coordinator
Air, Pesticides &. Toxics Div.
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7233
Regional Asbestos Coordinator
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7244
Region 7
IA, KS
MO, NE
Asbestos NESHAP Coordinator
Air &. Toxics Division
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7618
Regional Asbestos Coordinator
US EPA
726 Minnesota Avenue
Kansas City. KS 66101
(913)551-7020
Region 8
CO, MT, ND
SD, UT, WY
Aabeatoi NESHAP Coordinator
Air tt Watte Management Div.
US EPA
One Denver Place
999 18lh Street
Suite 500
Denver, CO 80202-2405
(303) 294-7685
Regional Asbestos Coordinator
US EPA
On* Denver Place
999 18th Street'
Suite 500
Denver, CO 80202-2405
(303) 293-1442
Region 9
AS, CA, HI,
NV, AZ, GU,
TT
Asbestos NESHAP Coordinator
Air Management Division
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1135
Regional Asbestos Coordinator
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1128
Region 10
AK, ID
OR, WA
Asbestos NESHAP Coordinator
Air & Toxics Management Div.
US EPA
12006th Avenue
Seattle, WA 98101
(206) 442-1757
Regional Asbestos Coordinator
US EPA
1200 6th Avenue
Seattle, WA 98101
(206) 442-4762
December 1990
25
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ITEM 6
The Asbestos/NESHAP Demolition Decision Tree
-------
Asbestos/NESHAP
Demolition
Decision
Tree
U.S. ENVIROISfMENTAL PROTECTION AGENCY
Manufacturing, Energy, and Transportation Division
Office of Compliance
June 1994
-------
DISCLAIMER
The policies in this document are intended solely as
guidance. EPA may decide to follow this guidance or act at
variance therewith, based on an analysis of individual
circumstances. Furthermore, although this guidance is directed
toward EPA asbestos NESHAP inspectors, it may also be appropriate
for State and local regulatory inspectors. However, this guidance
should be used only as a supplement to any existing State and
local program requirements.
111
-------
Although this guidance is directed toward EPA asbestos NESHAP
inspectors, it may also be appropriate for State and local
regulatory inspectors. However, this guidance should be used only
as a supplement to any existing program requirements, particularly
State or local requirements.
The guidance document was prepared in the SSCD by Jeffery
KenKnight with assistance from Tom Ripp and the Regions.
Attachment
cc: Asbestos NESHAP Coordinators
Regions I-X
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUN 2 9 1994
MEMORANDUM
SUBJECT:
FROM:
TO:
Asbestos NESHAP Demolition Decision Tree Guidance
Document
vson
John B. Rasnic,
Manufacturing, Energy, and Transp
Office of Compliance
Air, Pesticides and Toxics Management Division
Directors
Regions I and IV
Air and Waste Management Division Director
Region II
Air, Radiation and Toxics Division Director
Region III
Air and Radiation Division Director
Region V
Air, Pesticides and Toxics Division Director
Region VI
Air and Toxics Division Directors
Regions VII, VIII, IX and X
Attached you will find the final version of the Asbestos
NESHAP Dexncr!t£|rion Decision Tree. Over the past few years, several
demolition projects with unique issues were brought to the
attention of the Stationary Source Compliance Division (SSCD). In
order to maintain as much national consistency as possible, SSCD
developed this guidance document addressing both normal and unique
demolition projects and outlining a decision process that should
be followed. The document is designed to help regulatory
inspectors decide which of the regulatory requirements may be
applicable to a given demolition.
Printed on Recycled Paper
-------
TABLE OF CONTENTS
SECTION PAG
I . INTRODUCTION [[[ !
II . DEFINITIONS [[[ 2
III . DEMOLITION DECISION TREE ........................................ 3
FLOW CHART 1 [[[ 4
FLOW CHART 2 [[[ 5
FLOW CHART 3 [[[ 6
FLOW CHART 4 [[[ 7
IV. INSPECTION OF FACILITIES UNDERGOING ORDERED DEMOLITION ........... 3
V. STRUCTURALLY SOUND FACILITIES UNDERGOING
NORMAL (other than intentional burning) DEMOLITION .............. 8
A. Inspection of a Facility ..................................... 8
B. Material Identification and Analysis ......................... 9
C. Removal of RACM Prior to Demolition .......................... 9
D. Discovery of RACM During Demolition ......................... 10
E. Evaluation of -Unique Methods for Removing RACM .............. 10
F . Isolating RACM Contaminated Debris .......................... 11
G . Site Assessment ............................................. 11
H. Decontamination of Demolition Site .......................... 11
VI . DEMOLITION OF STRUCTURALLY UNSOUND FACILITIES .................. 12
A. Demolition of Structurally Unsound Facilities ............... 12
B . Inspection of a Facility .................................... 12
C. Material Identification and Analysis ........................ 13
D. Removal of RACM Prior to Demolition ......................... 14
E. Evaluation of Unique Methods for Removing RACM .............. 14
F. Post Demolition Inspection for RACM Contaminated Debris ..... 15
G. Isolating RACM Contaminated Debris .......................... 15
H. Site Assessment ............................................. 15
I. Decontamination of Area Surrounding Demolition Site ......... 16
VII . DEMOLITION OF A FACILITY BY INTENTIONAL BURNING ................ 16
A. Inspection of a Facility .................................... 16
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I. INTRODUCTION
This guidance has been prepared to help asbestos NESHAP
inspectors provide guidance to the regulated community and to
build stronger enforcement cases through more thorough and
effective inspection practices. The guidance touches on
difficult situations inspectors may encounter while
conducting an asbestos inspection. In order to limit the
scope of this document it concentrates on affected facilities
undergoing demolition and deals only with EPA guidance
regarding the asbestos NESHAP.
The primary focus of this document is the application of
a demolition decision tree that is designed to help
inspectors decide which of the NESHAP regulatory requirements
are applicable to a given situation. Determining compliance
with these requirements is addressed in the inspection
checklist found in Guidelines for Asbestos NESHAP Demolition
and Renovation Inspection Procedures (EPA 340/1-90-007,
Revised November 1990).
Regardless of the current status of a facility (e.g., a
partially burned structure, a structurally sound facility,
etc.), regulatory inspectors utilizing the decision tree
should always begin with Flow Chart 1. For example, if a
facility is an ordered demolition, the inspector must first
determine if the order was made by a qualified agency. An
inspector should then determine if the demolition is ordered
because the facility is structurally unsound and in danger of
imminent collapse. If this is true, the decision process
will proceed to Flow Chart 2, which details a chain of
decisions an inspector should consider when conducting an
asbestos NESHAP compliance inspection. Facilities that are
not structurally unsound and will not be demolished by
intentional burning (normal demolition) will proceed from
Flow Chart 1 to Flow Chart 3 and possibly to Flow Chart 4.
Demolition by intentional burning is covered in Flow Chart 1.
The decision tree is accompanied by a list of pertinent
definitions and a detailed explanation of the process
including examples of situations that may be encountered.
Two case studies have been included in the appendices to the
guidancjgr^ehat demonstrate how the demolition decision tree
can be-applied to real life situations.
-------
II. DEFINITIONS
Installation means any building or structure or any group
of buildings or structures at a single demolition or
renovation site that is under the control of the same owner
or operator (or owner or operator under common control).
Asbestos Containing Waste Material includes regulated
asbestos-containing material waste and materials contaminated
with asbestos including disposable equipment and clothing.
Regulated Asbestos Containing Material (RACM) is
defined as (a) friable material, (b) Category I non-friable
material that has become friable, (c) Category I non-friable
material that will be or has been subjected to sanding,
grinding, cutting or abrading, or (d) Category II non-friable
material that has a high probability of becoming or has
become crumbled, pulverized or reduced to powder by the
forces expected to act on it during the course of the
demolition.
Facility means any institutional, commercial, public,
industrial, or residential structure, installation, or
building (including any structure, installation, or building
containing condominiums or individual dwelling units operated
as a residential cooperative, but excluding residential
buildings having four or fewer dwelling units); any ship; and
any active or inactive waste disposal site. For purposes of
this definition, any building, structure, or installation
that contains a loft used as a dwelling, is not considered a
residential.structure, installation, or building. Any
structure, installation or building that was previously
subject to this subpart is not excluded, regardless of its
current use or function.
Ordered Demolition* means a demolition that is mandated by
order of a qualified State or local governmental agency
because a facility is either structurally unsound and in
danger of imminent collapse or it is being demolished as part
of a government project (e.g., urban renewal project or road
project).
Quali£-iAej«t State or Local Governmental Agency* means the
governmental agency that has legal authority to inspect a
facility and declare it structurally unsound and in imminent
danger of collapse. Generally, these responsibilities will
be held by the local building department or local engineering
department. In order for such an agency to make declarations
concerning a building's structural soundness and risk of
collapse, the persons making such determinations must have
appropriate training and/or experience.
-------
Suspect RACM* means any material that is believed to contain
asbestos that is either friable or Category I or II
nonfriable material that has or will become regulated by
actions that are expected to act upon the material.
Unique Methods* means any method of removing RACM that is
not normally or has not been previously considered but when
implemented will allow the owner/operator to remove RACM in
situations otherwise thought too dangerous or impossible
(i.e., the removal of material from a structurally unsound
facility).
* Definitions to be used only for the purposes of this
document.
III. Demolition Decision Tree
The demolition decision tree provided in flow charts 1-4
is designed to help regulatory inspectors determine which of
the NESHAP regulatory requirements are applicable to a given
demolition. The decision tree is a series of decisions that
an inspector should go through when evaluating the demolition
of a regulated facility. Use of the flow charts is explained
in the following discussions.
IV. INSPECTION OF FACILITIES UNDERGOING ORDERED DEMOLITION
[Refer to Flow Chart -1]
Regulatory inspectors sent out to make asbestos NESHAP
inspections of facilities undergoing demolition must first
confirm whether or not the demolition is an ordered
demolition and if so, the reason for the order and its
origin. This information should be included on the
notification.
It is important to make a distinction between ordered
demolitions that are made because the facility is
structurally unsound and in danger of imminent collapse and
those that are ordered as part of one common project, such as
a highway right of way or an urban renewal project, because
the forn«»F allows for some exemptions from the requirements
of the .asbestos NESHAP.
Demolitions ordered as part of one common project may in.
fact include facilities -that are structurally sound. These
facilities are not exempt from any of the requirements of the
asbestos NESHAP. The owner/operator of such a facility is
required to follow all the requirements of the asbestos
NESHAP including inspection and notification and if
applicable, abatement.
3
-------
FLOW CHART 1
Refer the owner/operator ot the
affected facility to a qualified
governmental agency.
A facility
demolished
Was the
order made by a
qualified state or
local governmental
agency?
(§61.145(b)(4)(XIV))
Is the demolition
ordered because the
facility is structurally
unsound and in imminent
danger of collapse?
(§B1.145(a)(3))
Is it an ordered
demolition?
Not exempt from any
requirements of the
asbestos NESHAP.
Will the
building be
demolished by
intentional
burning?
GOTO
©
GOTO
©
YES
The asbestos NESHAP requires the removal of all
ACM if a facility that contains greater than the
threshold amount of asbestos will be demolished
by intentional burning. This requirement includes
the removal of all Category I and Category II
nonfriable ACM which for the purposes of
intentional burning shall always be considered
RACM (section 61.145 (c)).
Remove all RACM
prior to demolition
according to section
61.145{c) and dispose of
according to section
61.150.
Thoroughly inspect
facility for ACM.
Analyze
representative samples
for asbestos content
Is it
possible to
v [amove all of the
RACM from the
facility?
(§61.14S(C)(10))
Is the total
amount of material
containing greater
than 1% asbestos
above the threshold
amount?
Notice requirements
only.
(§61.145(a)(2))
Does any sample
contain more than
1% asbestos?
Demolition by burning
Is not applicable.
-------
©
FLOW CHART 2, Structurally Unsound Facility
Is the total
amount of material
containing greater
than 1% asbestos
above the threshold
amount?
Is it possible to
remove all of the
RACM prior to
demolition?
Is It possible to
thoroughly Inspect
the facility for the
presence oft
RACrATJ £,
Analyze
representative
samples
for asbestos content.
Demollitlon by burning
Is not applicable to
structurally unsound
facilities.
Does any
sample contain
more than 1%
asbestos?
Can a
portion of
the RACM be
removed prior to
demolition?
Have unique
methods of
removal been
considered?
Evaluate unique
methods and utilize If
applicable.
Remove as much RACM as
possible In accordance with
section 61.145(c).
Inspect debris
(or RACM.
Can the
RACM be Isolated
from the rest of the
debris (I.e., a wing
of a facility}?
Does the
debris contain
Dispose of all
debris as RACM In
accordance with
section 61.150.
No additional
requirements.
No additional
requirements apply.
Isolate the contaminated
debris and dispose of
according to §61.150.
Non-contaminated debris
may be disposed of as
normal demolition debris.
Sites that have not removed
RACM prior to demolition will
need a site assessment to
determine If the Immediate area
surrouding the demolition site
has been contaminated.
Is the area
surrounding the
facility (soil, etc.)
contaminated with
RACM?
Decontaminate the area
surrounding the demolition
site (i.e.. remove
contaminated soil, etc.)
II an owner/operator ol a facility that was not previously
Inspected. demonstrate (through records, blue prints.
elc I that 3rts does not contain RACM, then the
disposal i .ments of the NESHAP may not apply.
-------
Thoroughly inspect
lacility lor RACM
FLOW CHART 3, Structurally Sound Facility
YES
Is It ACM
Category I
non triable
Material?
Will
It be sanded.
ground, cut or
abraded?
Is it
In good
condition?
GOTO B2
Is It ACM
category II
nontriafale
material?
GOTO f R1
will it
be rendered
friable during
demolition?
Analyze representative
samples for asbestos
content.
GOTO
Does any
sample contain
more than 1%
asbestos?
Is the
total amount of
material containing
greater than 1%
asbestos above the
threshold amount?
Remove all RACM in
accordance with section
61.14S(c) and dispose of In
accordance with 61.ISO.
-------
FLOW CHART 4, Structurally Sound Facility (cont.)
Remove the RACM
prior to continuing
demolition in
accordance with
section 61.145(C).
During
demolition was
suspect RACM
discovered that was
previously.
Inaccessibly?
fi*\
Is the total
amount ol material
containing greater
than 1% asbestos
above the threshold
amount?
Is it possible
to safely
remove
the RACM?
Does any
sample contain
more than 1%
asbestos?
Analyze representaive
samples lor asbestos
content.
Decontaminate the area
surrounding the demolition site (I.e.,
remove contaminated soil, etc.)
Sites that have not removed
RACM prior to demolition will
need a site assessment to
determine II the Immediate area
surroudlng the demolition site
has been contaminated.
Isolate the contaminated debris
and dispose of according to
§61.150. Non-contaminated debris
may be disposed of as clean
demollton debris.
Have unique
methods ol
removal been
considered?
Evaluate unique
methods and utilize
if applicable.
Can the RACM be
isolated from the rest
of the debris (i.e., a
wing of a facility)?
Dispose of all debris as RACM in
accordance with section 61.150
-------
inactive waste disposal sites for asbestos mills and
manufacturing and fabricating operations). However,
according to 40 CFR 61.05, the establishment of an active
waste site requires prior approval from EPA or the delegated
State program. To clean up the site to background levels, it
will probably be necessary to remove all the asbestos
contaminated soil. The contaminated soil should be treated
and disposed of as asbestos-containing waste material.
VI . DEMOLITION OF STRUCTURALLY UNSOUND FACILITIES
[Refer to Flow Chart 2]
A. Demolition of Structurally Unsound Facilities
Facilities declared unsafe and in danger of imminent
collapse as a result of some emergency such as a fire,
earthquake or other disaster can not be demolished by means
of fire because of the inability to properly inspect such
facilities for the presence of asbestos.
A representative from a qualified governmental agency
typically makes this declaration.
B . Inspection of Facility
Facilities declared unsafe because of some emergency
such as fire, earthquake or other disaster can often be
dangerous if not impossible for regulatory inspectors to
enter and EPA would not expect an inspector to enter such an
environment.
Some facilities that are too dangerous to enter may
contain suspect RACM (e.g., roofing, siding, etc.) that can
be easily identified without entering the facility.
In some cases, a facility is declared unsafe when only
one wall or a portion of a facility is unsound. Occasionally
a facility is made unsound when the key structural load
supporting members from the facility are intentionally
removecF2£o avoid the inspection and removal (if applicable)
requirements of the asbestos NESHAP. In such cases the
owner/operator of that facility can:
Make the facility- safe to enter by knocking down the
portion that is unsafe or temporarily shoring up the
structure, thus allowing the inspector to go in to
conduct a thorough inspection, subsequently triggering
abatement if applicable.
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Identify materials in the safe portion of the facility
that are suspect and abate if applicable. Unsafe
portions of the facility (portions that can not be
safely inspected) should be carefully pulled down while
applying adequate amounts of water to control any
visible emissions.
Assume the entire facility or the portion that was not
thoroughly inspected to be asbestos and properly handle
and dispose of all the demolition debris as asbestos-
containing waste material.
Any portion of a facility that can be safely entered
should be thoroughly inspected. A thorough inspection
includes identifying all asbestos containing materials
present including Category I and II nonfriable ACM and the
quantities to be affected, the nature of the demolition and
the steps that will be taken to control any release of
fibers.
EPA requires that inspectors in the regulated community
attend and pass the 3-day Building Inspectors Course under 40
CFR Part 763, the revised Asbestos Model Accreditation Plan
(MAP) as mandated by section 15(a)(3) of the Asbestos School
Hazard Abatement Reauthorization Act (ASHARA).
C . Material Identification and Analysis
Before demolition may begin, all suspect ACM (all
material that can be safely examined) must be identified,
including Category I and II nonfriable material. Once all
suspect RACM is identified, and it is determined that a
facility contains greater than the threshold amount (260
linear feet, 160 square feet or 35 cubic feet), the
material(s) should be assumed to be RACM, or sampled (in the
safe portion of the facility) and analyzed to verify that
RACM is or is not present.
Category I nonfriable material that has not been or will
not be subjected to sanding, cutting or abrading and will not
become triable during demolition and subsequent clean-up is
not sublet to the handling requirements of the asbestos
NESHAP r"
Category II nonfriable material that is not friable and
has not or will not become friable (crumbled, pulverized, or
reduced to powder) during demolition and subsequent clean-up
is not subject to the handling requirements of the asbestos
NESHAP.
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If either the suspect amount of asbestos is below the
threshold amount or the asbestos content of the
representative sample(s) contains less than one percent, only
the notice requirements listed at 40 CFR 61.145(a)(3) apply.
D . Removal of RACM Prior to Demolition
RACM that exists in quantities above the threshold
amount (that can be safely removed) must be removed prior to
demolition. RACM may include Category I nonfriable material
that is friable or is likely to be subjected to sanding,
grinding, cutting, or abrading during demolition. Most
normal demolition techniques will not require the removal of
Category I nonfriable ACM that is not in poor condition and
is not friable prior to the demolition. However, waste
consolidation methods both at the demolition site and at the
disposal site may render these materials friable. RACM may
also include Category II nonfriable material that has a high
probability of becoming crumbled, pulverized or reduced to
powder by the forces expected to act on the material during
demolition. Most if not all Category II nonfriable ACM is
expected to become RACM during demolition. EPA recommends
that all Category II nonfriable ACM be removed prior to
demolition to avoid any further requirements of the asbestos
NESHAP.
E . Evaluation of Unique Methods for Removing RACM
When RACM is difficult or "impossible" to remove,
innovative methods of removal should be evaluated and used if
applicable. These unique methods might include the use of
equipment such as cranes or a specially adapted grappling
bucket (Bainbridge Case Study, see appendix A). If unique
methods have not been considered by the contractor, the
demolition should not continue while the RACM remains in
place until unique methods have been considered and
determined to be infeas.ible.
When the asbestos cannot be safely removed, the asbestos -
containing material must be kept wet and the entire asbestos
contamljSrCed waste pile (or the portion that is contaminated)
must ber"*disposed of as asbestos-containing waste material in
accordance with 40 CFR 61.150.
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F. Post Demolition Inspection for RACM Contaminated
Debris
Demolition debris from a facility that is demolished
without an inspection or demolished with RACM in place must
be inspected. All ACM material must be identified and
treated properly.
Debris that is inspected and found to contain any amount
of RACM is assumed to be entirely contaminated unless the
owner/operator of the facility can demonstrate through
building and/or maintenance records that the facility either
contains no asbestos or that the quantities are less than the
threshold amount or the contaminated debris can be
sufficiently isolated from the majority of the demolition
debris.
6. Isolating RACM Contaminated Debris
Sometimes RACM is identified in only one room of a
facility or a wing of a facility. Contaminated debris that
can be isolated should be disposed of in accordance with
section 61.150 of the asbestos NESHAP while the remainder of
the debris (non-contaminated debris) can be disposed of as
normal "clean" demolition debris. This determination should
be based on a visual inspection and sampling and analysis of
the debris. If any asbestos contamination is found in an
area (even below one percent), the waste must be disposed of
in accordance with section 61.150, unless the owner/operator
of the affected facility can demonstrate that the intact
material contained less than one percent.
H. Site Assessment
Any facility that undergoes demolition without removing
all of the RACM should undergo a site assessment to determine
if the immediate area surrounding the facility has been
contaminated with asbestos.
A site assessment should include but is not limited to a
visual~jipsraiuation and a comprehensive soil sampling scheme to
determifie compliance with the asbestos NESHAP. The degree of
testing should be evaluated on a case-by-case basis.
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I . Decontamination of Area Surrounding
Demolition Site
If a site assessment detects contamination of soil
surrounding a demolition site, the site must be cleaned up to
background levels of asbestos contamination. Alternatively,
the site may be operated in accordance with 40 CFR 61.154
(Standard for active waste disposal sites) and closed in
accordance with 40 CFR 61.151 (Standard for inactive waste
disposal sites for asbestos mills and manufacturing and
fabricating operations). However, according to 40 CFR 61.05,
the establishment of an active waste site requires prior
approval from EPA or the delegated State program. To clean
up the site to background levels, it will probably be
necessary to remove all the asbestos contaminated soil. The
contaminated soil should be treated and disposed of as
asbestos-containing waste material.
VII. DEMOLITION OP A FACILITY BY INTENTIONAL BURNING
[Refer to Flow Chart 1]
A. Inspection of Facility
In order for a facility to be demolished by burning,
section 61.145 requires a thorough inspection of the affected
facility prior to demolition.
EPA requires inspectors in the regulated community to
attend and pass the 3-day Building Inspectors Course under 40
CFR Part 763, the revised Asbestos Model Accreditation Plan
(MAP) as mandated by section 15(a)(3) of the Asbestos School
Hazard Abatement Reauthorization Act (ASMARA).
B . Material Identification and Analysis
Before intentionally burning a facility, all suspect ACM
must be identified including all Category I and II nonfriable
material.
-£^>-
C . Resioval of RACM Prior to Demolition
The asbestos NESHAP requires the removal of all ACM if a
facility will be demolished by intentional burning. This
requirement includes the removal of all Category I and II
nonfriable ACM which for the purposes of intentional burning
shall always be considered RACM (section 61.145(c)).
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Appendix A.
CASE STUDY
The Bainbridge Naval Training Center
Background
The Bainbridge Naval Training Center (BNTC) near Port
Deposit, Maryland, is a federal facility owned by the U.S. Navy
occupying approximately 1,300 acres in a residential and rural
area in northeast Maryland.
The BNTC was an active Navy facility from the early 1940s
until 1976. On November 3, 1986, the U.S. Congress authorized the
Secretary of the Navy to dispose of the Bainbridge facility by
sale to private parties or transfer to other government agencies.
Over 700 abandoned buildings and structures in various stages of
dilapidation existed on the site. Congress specified that before
any sale, the Secretary of the Navy was required to "restore such
property to a condition that meets all applicable Federal and
State of Maryland environmental protection regulations" Public Law
99-956.
Site Description
The buildings at the BNTC were mainly one to three story wood
frame structures. A few of the buildings were masonry and several
of the wood frame structures had concrete grade slabs. Some of
the buildings contained friable asbestos in the form of boiler
wrap and pipe lagging, while most buildings had asbestos-cement
transite board (Category II non-friable ACM) on the exterior, the
interior, or in both areas. Because of the age of the buildings,
the lack of maintenance, exposure to the elements, and vandalism,
the buildings at BNTC were in various stages of dilapidation.
Some of the structures had collapsed entirely, while nearly all
the other structures to be demolished had sustained some
structural damage making thorough inspections difficult and in
some cases impossible.
Naw's Preliminary Agreement with the State of Maryland
The Navy decided to turn the BNTC site over to the State of
Maryland, -redoing so, the Navy agreed as mandated by Congress to
"restore the--"property to a condition that meets all applicable
Federal and State of Maryland environmental protection
regulations." The restoration activities included demolition and
clean-up at the BNTC site. The Navy contracted a private
demolition company to demolish and clean-up the BNTC site. Before
EPA's involvement, most buildings that were standing at the BNTC
had only friable asbestos insulation removed prior to demolition.
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Buildings declared unsafe (ordered by a State or local
governmental agency) and in danger of collapse as a result of
some emergency such as a fire, earthquake or other disaster,
must typically be demolished immediately and cannot await an
inspection by EPA. Section 61.145 (a)(3) of 40 CFR gives
certain exemptions to the requirements of the asbestos NESHAP
only when the facility is structurally unsound and in danger
of imminent collapse. However, with respect to the
procedures for emission control, ordered demolitions are
subject to paragraphs (c)(4) through (c)(9) of section
61.145. Additionally, paragraphs (b)(1), (b)(2),
(b)(3)(iii), (b)(4) (except(b)(4)(viii)}, and (b)(5) of
section 61.145 still apply to ordered demolitions.
To discourage abuse of this provision, the notification
that is submitted must identify the government representative
who ordered the demolition, the date the order was issued and
the date demolition was ordered to begin. Representatives
from a qualified governmental agency typically make those
determinations.
If the appropriate agency is unable to make such a
determination (e.g., due to lack of resources or personnel)
it may be appropriate for that agency to retain the services
of a private contractor or State regulatory agency to make
the determination.
Conversely, it would be inappropriate for the
owner/operator of a facility to retain the services of a
private contractor or use in-house professionals to make such
a determination because it would be in their best interest to
have the building categorized as being structurally unsound
in order to gain the exemptions and subsequent cost savings
from not having to adhere to all of the requirements of the
asbestos NESHAP.
V. Structurally Sound Facilities Undergoing
Normal (other than intentional burning) Demolition
[Refer to Flow Charts 3 & 4]
A. nxi&fection of a Facility
j
A majority of inspections will be of structurally sound
facilities undergoing normal (other than intentional burning)
demolition. Guidance for demolitions can be found in A Guide
to Normal Demolition Practices Under the Asbestos NESHAP (EPA
340/1-92-013, September 1992). Section 61.145 requires a
thorough inspection of the affected facility prior to
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demolition. The responsibility to thoroughly inspect lies
with the owner/operator of the affected facility.
A thorough inspection includes identifying all asbestos
containing materials present including Category I and II
nonfriable ACM and the quantities to be affected, the nature
of the demolition and the steps that will be taken to control
any release of fibers. Guidance for inspections can be found
in EPA's Guidelines for Asbestos NESHAP Demolition and
Renovation Inspection Procedures (EPA 340/1-90-007, November
1990, (Revision)).
EPA requires inspectors in the regulated community to
attend and pass the 3-day Building Inspectors Course under 40
CFR Part 763, the revised Asbestos Model Accreditation Plan
(MAP) as mandated by section 15(a)(3) of the Asbestos School
Hazard Abatement Reauthorization Act (ASHARA).
B . Material Identification and Analysis
Category I nonfriable material that has not been or will
not be subjected to sanding, cutting or abrading and will not
become friable during demolition and subsequent clean-up and
disposal is not subject to the handling requirements of the
asbestos NESHAP.
Category II nonfriable material that is not friable and
will not become friable (crumbled, pulverized, or reduced to
powder) during demolition and subsequent clean-up is not
subject to the handling requirements of the asbestos NESHAP.
Once all suspect RACM is identified, and it is
determined that the facility contains greater than the
threshold amount (260 linear feet, 160 square feet or 35
cubic feet), the material(s) should be assumed to be RACM, or
sampled and analyzed to verify that RACM is or is not
present.
If either the suspect amount of asbestos is below the
threshold amount or the asbestos content of the
representative sample(s) contain less than one percent, only
the notice requirements listed at 40 CFR 61.145(a)(3) apply.
C . Removal of RACM Prior to Demolition
If RACM exists in quantities above the threshold amount,
then all the RACM must be removed prior to demolition. RACM
may include Category I nonfriable material that is friable or
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is likely to be subjected to sanding, grinding, cutting,
abrading, or burning during demolition. Most normal
demolition techniques will not require the removal of
Category I nonfriable ACM that is not in poor condition and
is not friable prior to the demolition. However, waste
consolidation methods both at the demolition site and at the
disposal site may render these materials friable. RACM may
also include Category II nonfriable material that has a high
probability of becoming crumbled, pulverized or reduced to
powder by the forces expected to act on the material during
the course of the demolition. Most Category II nonfriable
ACM is expected to become RACM during demolition. EPA
recommends that all Category II nonfriable ACM be removed
prior to demolition to avoid any further requirements of the
asbestos NESHAP.
D. Discovery of RACM During Demolition
Suspect RACM that is discovered during demolition which
was previously inaccessible must be sampled and analyzed for
its asbestos content when the combined amount of suspect RACM
(the amount of RACM identified during the initial inspection
and the amount of newly discovered suspect material) is above
the threshold amount.
If the threshold amount is exceeded and the samples
tested contain more than one percent asbestos, all of the
RACM must be removed if possible. If the asbestos cannot be
safely removed, the asbestos-containing material must be kept
wet and the entire waste pile (or the portion that contains
asbestos-containing waste material) must be disposed of as
asbestos-containing waste material in accordance with 40 CFR
61.150. The cost of disposing of the entire contaminated
waste pile as asbestos waste should discourage contractors
from this as a means to avoid the removal requirements of the
asbestos NESHAP.
When the combined amount of suspect RACM (the combined
amount of RACM identified during the inspection and the
amount of newly discovered material) is less than the
threshold amount or the samples of intact material (not
samples£A»£ contaminated waste) contain less than one percent
of asbestos, only the notice requirements found in 40 CFR
61.145(a)(3) would apply to the demolition.
E . Evaluation of Unique Methods for Removing RACM
When newly discovered RACM is difficult or "impossible"
to remove, innovative methods of removal should be evaluated
and used if applicable. These unique methods might include
10
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the use of equipment such as cranes, a specially adapted
grappling bucket (Bainbridge Case Study, see Appendix A) or
temporarily shoring up a structure. If unique methods have
not been considered by the contractor, the demolition should
not continue while the RACM remains in place until unique
methods have been considered and determined to be infeasible.
When the asbestos cannot be safely removed, the asbestos-
containing material must be kept wet and the entire asbestos
contaminated waste pile (or the portion that is contaminated)
must be disposed of as asbestos-containing waste material in
accordance with 40 CFR 61.150.
F . Isolating RACM Contaminated Debris
Sometimes RACM is identified in only one room of a
facility or a wing of a facility. Contaminated debris that
can be isolated must still be disposed of in accordance with
40 CFR 61.150 of the asbestos NESHAP while the remainder of
the debris (non-contaminated) may be disposed of as normal
"clean" demolition debris. This determination should be made
based on a visual inspection and analyses of samples of the
waste. If any asbestos contamination is found in an area
(even below one percent) then the waste must be disposed of
in accordance with section 61.150, unless the owner/operator
of the affected facility can demonstrate that the intact
material contained less than one percent.
G. Site Assessment
Any facility that undergoes demolition without removing
all of the RACM should undergo a site assessment to determine
if the immediate area surrounding the facility has been
contaminated with asbestos.
A site assessment should include but is not limited to a
visual evaluation and a comprehensive soil sampling scheme to
determine compliance with the asbestos NESHAP. The degree of
testing should be evaluated on a case-by-case basis.
H. Decontamination of Demolition Site
If the surrounding soil has been contaminated by the
demolition activities at-the site, the site must be cleaned
up to background levels of asbestos contamination.
Alternatively, the site may be operated in accordance with
section 61.154 (Standard for active waste disposal sites) and
closed in accordance with section 61.151 (Standard for
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Regulatory Inspections
During several inspections of the BNTC site in 1991, EPA
inspectors observed that the demolition activities were being
conducted in violation of the notification, demolition, emission
control, and disposal requirements of the asbestos NESHAP. The
transite material found on the exterior and interior of most
buildings was initially thought by the State of Maryland and the
Navy to be exempt from the requirements of the asbestos NESHAP.
The intent of EPA to regulate the demolition of buildings
containing transite material (asbestos-cement material) is
expressed in the preamble to the final promulgation of the
asbestos NESHAP published November 20, 1990, 55 FR 48408. EPA's
applicability determination of January 8, 1992, was made to
further clarify what types of activities are likely to cause
Category II nonfriable ACM to become RACM.
The Navy then conducted an inspection of the BNTC and
concluded that all but four of the buildings were structurally
unsound. The buildings were inspected by the Navy and categorized
into four classes:
Remedial Class 1: a building requiring removal of all
friable asbestos (primarily insulation materials) but
which will not be demolished.
Remedial Class 2: a building requiring pre-demolition
"removal of friable asbestos from parts of the structure
that can be safely entered."
Remedial Class 3: a building that has collapsed or is
structurally unsound in its present condition and is to
be demolished "as is," with the debris treated as
asbestos-containing waste material.
Remedial Class 4: a building requiring no action.
The Navy Categorized most of the buildings as remedial
Class 3, therefore buildings were demolished "as is," with no
abatement prior to demolition and the debris was treated as
asbestos containing material.
Application-art Demolition Decision Tree to the BNTC
+
The Demolition Decision Tree is written in a generic format
so that it can be applied to various demolition scenarios. The
BNTC site because of the number and variety of buildings is a good
example of how the application of the Decision Tree may help
inspectors decide which of the NESHAP regulatory requirements are
applicable to a given demolition.
A-2
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In applying the decision tree to the BNTC site (beginning
with Flow Chart I), the inspector should first determine whether
the demolition is an ordered demolition. If the demolition is not
an ordered demolition, the facility is not exempt from any of the
requirements of the asbestos NESHAP. When demolitions are
"ordered," the inspector should determine if the order was made by
an appropriate governmental agency. Although EPA does not have
any criteria for such determinations, they should be made at the
request of the regulating agency by registered engineers or
building inspectors who are trained (qualified) to make such
decisions. Ordered demolitions typically come from a governmental
agency that regulates building safety. The fact that a facility
is off limits or has been declared unusable, is insufficient
grounds for allowing certain exemptions (section 61.145(a)(3)) to
the requirements of the asbestos NESHAP. Prior to the start of
demolition at the BNTC site, the Navy conducted their own survey
and concluded that the vast majority of the buildings were
structurally unsound. It should be obvious from Flow Chart 1,
that the initial survey which was conducted by the Navy was
inappropriate. The appropriate procedure in this situation would
have been for the State of Maryland, EPA, or an independent
contractor (agreed to by the regulatory agency and the Navy) to
conduct a comprehensive survey of the affected facilities.
Structurally Unsound Facilities (Flow Chart 2)
Facilities declared structurally unsound and in danger of
imminent collapse would move from Flow Chart 1 to Flow Chart 2.
The buildings declared structurally unsound at the BNTC site were
categorized as Remedial Class 3 buildings by the Navy.
Regulatory inspectors should then determine if it is possible
for the owner/operator to inspect a facility or the portion that
is safe for the presence of asbestos. If facilities or safe
portions of facilities contain suspect RACM in amounts greater
than the threshold amount, representative samples should be
sampled and analyzed for asbestos content. If the samples contain
more than one percent asbestos, inspectors should investigate the
possibilities of removing all the RACM or RACM from the safe
portions (Remedial Class 2) of the facility. Whenever possible,
all RACM should be removed prior to demolition. When RACM is
identified in facilities that have been declared unsafe,
inspectors sgjyttld evaluate unique methods for removing the RACM.
Unique method's may include the demolition of the portion deemed
unsafe or temporarily shoring up the unsafe portion of the
structure thereby creating a safe working environment allowing for
proper inspection and abatement as applicable. Other unique
methods might include the use of specially adapted demolition
equipment. The demolition contractor at the BNTC site attempted
to remove the transite siding with a modified grappling bucket.
This method proved ineffective, forcing the demolition contractor
A-3
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to remove as much of the transits material as deemed feasible by
hand. If unique methods have not been considered by the
contractor, the demolition should not continue while the RACM
remains in place until unique methods have been considered and
determined to be infeasible.
The lower portion of Flow Chart 2 should make it clear to an
inspector that demolition debris from facilities not thoroughly
inspected or debris from facilities demolished with RACM in place,
must be thoroughly inspected. Debris containing any amount of
asbestos (even below one percent) should be treated and disposed
of as RACM in accordance with section 61.150. Non-contaminated
material that can be isolated from asbestos contaminated waste may
be disposed of as "clean" demolition debris in any landfill that
normally accepts demolition material. Because the demolition
techniques used at the BNTC site caused most if not all transite
material (Category II nonfriable) to become RACM, the demolition
debris was assumed to be entirely asbestos contaminated and was
disposed of as RACM in accordance with the NESHAP. EPA inspectors
observed that the demolition activities were being performed in
violation of the emissions control requirements of the asbestos
NESHAP (section 61.145(c)). The observed visible emissions at the
BNTC site and the data obtained through air monitoring was enough
evidence to expect some degree of contamination to the environment
in and around the demolition sites. To fulfill its obligation to
"restore such property to a condition that meets all applicable
Federal and State of Maryland environmental protection
regulations," the Navy was required to submit a comprehensive soil
sampling protocol for determining possible site contamination
levels, at the BNTC site. The results of the soil sampling
revealed contamination at those sites demolished with transite
material in place. As a result of the contamination, the soil was
removed and disposed of as asbestos containing waste material.
Lessons Learned
The BNTC case is a good example of how the application of the
demolition decision tree would have prevented a lot of confusion as
to which of the regulatory requirements were applicable to the
demolition activities. Specifically, it could have made clear
EPA's intent on regulating the demolition of buildings containing
transite mafeea&ial.
A-4
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Appendix B.
CASE STUDY
Jewel Lake Condominium
Anchorage/ Alaska
Background
The Jewel Lake Condominium facility was a 20 unit, three-
story structure that suffered extensive fire damage. The third
floor and the main stairway were severely burned. Smoke and water
damage were prevalent throughout the remainder of the building.
It was declared a public nuisance and hazard by both the Alaska
Department of Occupational Health and Safety (ADOHS) and the
Municipality of Anchorage (MOA) Public Works Department, Division
of Building Safety. It was condemned (ordered) by the MOA and
declared unsafe due to the danger of imminent collapse.
A survey of the facility found extensive use of asbestos
containing materials within the surviving portions of the
building. The building contained 28 fire doors (containing
Amosite) and 12,000 square feet of asbestos containing sprayed-on
material (acoustical plaster).
The original demolition plan called for a complete knock-down
of the structure. The plan also called for a backhoe to break up
the debris before disposing of the entire debris pile as asbestos
contaminated waste.
The building was located in a densely populated neighborhood
and the work was to be conducted at temperatures below freezing
which would make the application of adequate amounts of water
impractical.
Application of Demolition Decision Tree
In applying the decision tree to the Jewel Lake Condominium
site, an inspector should first confirm that the demolition was
ordered by a qualified governmental agency. The Jewel Lake site
was "ordered" by the ADOHS and the MOA. Both the ADOHS and the
MOA conform with the definition of "qualified governmental
agency." The inspector should then determine if the order was
made because£^he facility is structurally unsound and in danger of
imminent collapse. The Jewel Lake facility suffered extensive
fire damage, causing the structure to become structurally unsound
and in danger of imminent collapse as determined by a construction
engineer working for the MOA.- In addressing structurally unsound
facilities in the Decision Tree move from Flow Chart 1 to Flow
Chart 2.
A thorough inspection of the facility confirmed the presence
of suspect asbestos containing materials in quantities above the
B-l
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threshold amount. Subsequent analyses of the suspect materials
confirmed the presence of asbestos. Using the middle section of
Flow Chart 2 (unique methods), .the inspector should determine if
the utilization of unique methods will facilitate the removal of
RACM before demolition. The "unique methods" used at the Jewel
Lake site, included the knock-down and removal of only the damaged
portion (unsafe portion) of the facility. This portion was
removed with adequate amounts of water and disposed of entirely as
asbestos contaminated material. The remaining intact portion of
the facility was demolished and disposed of as normal debris after
abatement of all the remaining RACM.
Lessons Learned
The application of the demolition decision tree to the Jewel
Lake site would have clearly defined which portions of the
asbestos NESHAP are applicable. The apparent confusion among the
regulated and regulatory communities caused a five month delay in
the demolition of the Jewel Lake facility. The Demolition
Decision Tree guidance clearly states that even in cases where a
facility is declared unsafe, all options of removing RACM should
be considered. In the Jewel Lake case, the upper floor (the
burned out portion) was removed, thereby creating a safe working
environment. This allowed for the proper abatement of all the
remaining RACM prior to the demolition. Removing the damaged
portion of the Jewel Lake facility avoided the near certain
contamination to the surrounding neighborhood that would have
occurred considering the proposed work plan.
B-2
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ITEM 7
Guidelines For Asbestos NESHAP Landfill Recordkeeping Inspections
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United States
Environmental Protection
Agency
Off ice of Air Quality
Planning and Standards
Washington. DC 20460
EPA-340/1-92-012
March 1992
Stationary Source Compliance Series
oEPA
Guidelines for
Asbestos NESHAP
Landfill Recordkeeping
Inspections
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EPA-340/1-92-012
Guidelines for
Asbestos NESHAP
Landfill Recordkeeping
Inspections
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington. DC 20460
March 1992
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DISCLAIMER
This manual was prepared by Alliance Technologies Corporation for the Stationary Source
Compliance Division of the U.S. Environmental Protection Agency. It has been completed in
accordance with EPA Contract No. 68-02-4465, Work Assignment No. 92-220. This document
is intended for information purposes ONLY, and may not in any way be interpreted to alter or
replace the coverage or requirements of the asbestos National Emission Standards for Hazardous
Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M.
A92-279.txt U
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TABLE OF CONTENTS
Section Page
INTRODUCTION v
1 LANDFILL RECORDKEEPING AND REPORTING REQUIREMENTS 1
Recordkeeping Requirements 1
Reporting Requirements 2
2 PRE-INSPECTION ACTIVITIES 5
Targeting Waste Disposal Sites 5
Planning the Waste Disposal Site Recordkeeping Inspection 5
3 FIELD INSPECTION ACTIVITIES 11
Preliminary Interview 11
Reviewing Records 12
Additional Activities 13
Quality Assurance Check 14
Post-Inspection Interview 14
4 POST-INSPECTION ACTIVITIES 15
Inspection Followup 15
Report Preparation 15
Data Management 15
Documentation 16
Records Maintenance 16
5 ASBESTOS NESHAP ENFORCEMENT 17
Landfill Recordkeeping Violations 17
Landfill Reporting Violations 17
Appendices Page
A Asbestos Waste Disposal Site WSR Recordkeeping Requirements A-l
B Asbestos Waste Disposal Site Records Inspection Checklist B-l
TABLES
Number Page
2-1 Determination of Minimum Sample Size 9
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IV
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INTRODUCTION
The purpose of this guidance document is to assist asbestos NESHAP compliance inspectors in
conducting active landfill recordkeeping inspections.
This manual details landfill recordkeeping requirements and includes step-by-step instructions for
every phase of a landfill recordkeeping inspection. Pie-inspection activities (disposal site
targeting, reviewing Agency records, developing an inspection plan), onsite inspection activities
(interviewing, reviewing and records' sampling), and post-inspection activities (writing the
inspection report, determining the need for enforcement action) are discussed. A landfill
recordkeeping flowchart and inspection checklist are also included.
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VI
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SECTION 1
LANDFILL RECORDKEEPING AND REPORTING REQUIREMENTS
The new requirements for waste disposal affect both generators of asbestos-containing waste
material (ACWM) and waste disposal site operators. Generators must provide the waste
disposal site a properly completed waste shipment form with every load of ACWM delivered,
inform EPA when they cannot determine the disposition of their waste, and maintain copies
of waste shipment records (WSRs) and associated correspondence in their files. Waste
disposal site operators are required to verify information contained in the WSRs, inform
generators that the ACWM has been received, inform EPA if efforts to resolve discrepancies
have failed, and also maintain waste shipment information.
The following discussion provides detailed information concerning both recordkeeping and
reporting requirements for owners/operators of asbestos landfills.
RECORDKEEPING REQUIREMENTS
The revised asbestos NESHAP requires waste disposal site operators to maintain both waste
shipment and ACWM deposition information.
Waste Shipment Records
Landfill operators must check the WSR that accompanies each asbestos waste shipment that
arrives at the facility to make sure that the information on the WSR accurately describes the
waste shipment The landfill operator must verify that the information in WSR Item 6
(Number and Type of Containers) coincides with the quantities reported in WSR Item 7
(Cubic meters or yards) and determine if the load contains a significant amount of improperly
enclosed or uncovered waste. Any discrepancy seen must be noted in Item 12 of the WSR.
Waste disposal site operators need not open bags or other containers to verify that they
contain ACWM; the WSR accompanying the load is sufficient verification. Once the load
has been examined, and discrepancies noted, the waste disposal site operator must complete
Item 13 (Certification of Receipt) of the WSR, return a copy to the generator (within 30
days), and maintain a file copy.
Copies of all WSR's must be kept for at least 2 years. To facilitate future reference, WSRs
should be kept in chronological order in a secure, water-tight file. Copies of WSRs must be
provided, upon request, to the agency(ies) responsible for implementation of the asbestos
NESHAP and the file must be made available for inspection during normal business hours.
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ACWM Deposition Information
Waste disposal site operators arc also required to maintain up-to-date, accurate records that
indicate the location, depth, area, and quantity of ACWM within the disposal site on a map or
diagram of the disposal area.
REPORTING REQUIREMENTS
The revised asbestos NESHAP also subjects waste disposal site owners/operators to several
new reporting requirements. Required reports concern stationary source information, WSR
discrepancies, improperly-contained waste, disturbance of disposed ACWM, and disposal site
closures.
Waste Site/Stationary Source Report (§§ 61.153, 61.10)
Within 90 days of the effective date of the revisions to the asbestos NESHAP (by February
18, 1991) for existing sources, or within 90 days of the initial startup date for sources having
a startup date after the effective date, disposal site operators are required to submit the
following information about their waste site operations to the agency responsible for
administration of the asbestos NESHAP program:
A brief description of the waste disposal site (location, size, etc.).
A description of the method or methods that will be used to comply with the asbestos
NESHAP, or a description of alternative methods that will be used. Methods to be
used may include covering asbestos waste daily with six (6) inches of nonasbestos
cover, or the use of a dust suppressant Other information that might be reported
includes procedures to prevent public access to the asbestos waste disposal area, such
as the use of warning signs and fencing. This information must be reported using the
format in Appendix A of Part 61 of Title 40 of the Code of Federal Regulations (40
CFR).
In addition to the information listed above, the waste disposal site operator also has to report
(within the same time period) the following information to comply with the source reporting
requirements of 40 CFR Part 61 Subpart A §61.10:
Name and address of the owner or operator.
Location of the source.
Type of hazardous pollutants emitted by the stationary source.
Brief description of the nature, size, design, and method of operation of the stationary
source, including the operating design capacity of the source. Identify each point of
emission for asbestos.
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The average weight per month of asbestos being processed by the source over the last
12 months preceding the date of the report
Whether the source can/cannot comply with the standard within 90 days of the
effective date.
If there is a change in any of the information listed above, the waste disposal site
owner/operator must report the changes to the appropriate agency within 30 days after they
occur as required by 40 CFR § 61.10(c).
Discrepancy Reports (§ 61.54 (e)(3))
If there is a discrepancy between the number of containers shown on the WSR and the
number counted in the load, waste disposal site operators must make note of this in Item 12
of the WSR and contact the generator to determine if there is a reasonable explanation for the
discrepancy. If the discrepancy is resolved, the waste disposal site operator must note this on
the WSR, send a signed copy of the WSR to the generator (within 30 days), and retain a file
copy.
If the discrepancy cannot be resolved within 15 days of receipt of the ACWM, the waste
disposal operator must send a written discrepancy report immediately to the agency which is
responsible for the generator of the waste and, if different, the agency in whose jurisdiction
the disposal site is located. The report must describe the discrepancy and steps taken to
resolve it Information provided should include how and when the waste disposal site
operator attempted to reach the generator and the results of these efforts. A copy of the WSR
in question must be submitted as well.
Improperly-Contained Waste Report (§ 61.154 (e)(l)(iv))
As disposal site operators check asbestos waste shipments that arrive at their facilities, they
are required to note whether a significant amount of improperly enclosed or uncovered waste
exists in the load. If such material is discovered, the waste disposal site operator must make
note of this in Item 12 of the WSR and send, by the following working day, a written report
of the problem to the agency responsible for administering the asbestos NESHAP program for
the jurisdiction where the job site is located (identified on the WSR). If the disposal site is in
a different jurisdiction than the job site, the written report must also be sent to the agency
responsible for the disposal site.
The written report must include a copy of the WSR and a detailed description of the
improperly enclosed or uncovered waste so that the Agency can determine the urgency of the
situation and the course of action to pursue.
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Excavation/Disturbance Report (61.151(d))
If an owner or operator of an asbestos landfill plans to excavate or otherwise disturb (e.g.,
drill methane vents) any ACWM that has been deposited and covered at a waste disposal site,
the Administrator must be informed, in writing, at least 45 days prior to the disruptive
activity. The following information must be contained in the notice:
Scheduled starting and completion dates.
Reason for disturbing the waste.
Procedures to be used to control emissions during the excavation, storage, transport,
and ultimate disposal of the excavated ACWM. (If deemed necessary, the
Administrator may require changes in the emission control procedures to be used.)
Location of any temporary storage site and the final disposition site.
If the excavation will begin on a date other than the one contained in the original notice,
notice of the new start date must be provided to the Administrator at least 10 working days
before excavation begins. In no event shall excavation begin earlier than the date specified in
the original notification.
Closure Report (§ 61.151(e))
Agency Notification
Upon closure of a facility, the owner or operator of the site must submit to the Administrator
a copy of the records of the location, depth and area and quantity (yd3 or m3) of ACWM
within the disposal site which have been maintained on a map or diagram of the disposal
area.
Deed Notation
In addition, within 60 days of closing a waste disposal site, the owner/operator must record,
in accordance with State law, a notation on the deed to the facility property, and on any other
instrument that would normally be examined during a title search, mat:
The land was used for the disposal of ACWM,
The survey plot and record of the location and quantity of ACWM disposed of within
the disposal site have been filed with the Administrator, and
The site is subject to the National Emission Standards for Hazardous Air Pollutants:
Asbestos (40 CFR pan 61 subpart M).
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SECTION 2
PRE-INSPECTION ACTIVITIES
In the 2 years following promulgation of the revised asbestos NESHAP, all waste disposal
sites which accept ACWM should be visited for a baseline inspection. This inspection will
provide the opportunity for disposal site operators to learn about reporting and recordkeeping
requirements, help publicize EPA's intention to enforce the waste disposal requirements, and
assist in the collection of information necessary for inspection targeting.
The following in-house activities should be conducted to ensure smooth performance of
landfill recordkeeping inspections.
TARGETING WASTE DISPOSAL SITES
Targeting of waste disposal sites should be based on their size, the amount of asbestos waste
accepted for disposal, other enforcement actions (i.e., RCRA), and exception reports, etc.
Such information may be obtained from a variety of sources:
Landfill lists. Lists of landfills may be obtained from EPA Regional Offices, States
and local agencies. Only some of these lists indicate whether ACWM is accepted by a
particular landfill; however, individuals noted on the lists may be contacted to provide
additional information.
Notifications. Information pertaining to landfills not previously known to accept
ACWM may be found in generator notifications. Additionally, any landfill noted
which is scheduled to receive large quantities of ACWM should be targeted for
inspection.
Previous inspection reports. Waste disposal sites identified in inspection reports
concerning demolitions or renovations performed out of compliance should be targeted
for inspection.
PLANNING THE WASTE DISPOSAL SITE RECORDKEEPING INSPECTION
A NESHAP inspector who takes the time to properly plan a field inspection will find that the
actual inspection will be accomplished more efficiently and will be more productive. In
preparation for an asbestos landfill recordkeeping inspection an inspector should:
Become familiar with the types of records a facility is required to maintain.
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Review agency files.
Determine whether the landfill whose records are to be inspected has been
identified as the waste disposal site on demolition/renovation notifications
received. Make copies of such notifications.
Determine if any reporting or recordkeeping problems have been reported for
the site (e.g., an unexpectedly large number of exception reports). If the
removal jobs and the disposal site are in the same regulatory jurisdiction this
will be easy to do, since generators are required to inform the regulatory
agency in charge if there are problems with the disposition of their ACWM. If
the disposal site is located outside the regulatory jurisdiction, however, such
information may not be available, for generators are not required to inform the
agency responsible for the waste disposal site. Make copies of such
information.
Examine landfill-generated reports (discrepancy, stationary source, improperly-
contained ACWM, closure and excavation/disturbance reports).
Review any complaints submitted.
Communicate with other agencies or departments. City building departments may
issue demolition/renovation and construction permits. Health departments may issue
landfill operating permits or have records of complaints. Review any pertinent
inspection reports filed by these agencies.
Acquire the following information:
-Where records are maintained.
-Directions to this location.
-The business hours where the records are kept
-Who is in charge of maintaining these records.
-The hours this person works.
-Directions to the landfill.
-Landfill operating hours.
-How much ACWM is accepted by the landfill.
-How often the landfill accepts ACWM.
-How often records are sent to the central storage area from the landfill
Plan for the efficient use of time. Inspectors will probably have to inspect records kept
both at the landfill and at an office or storage area elsewhere. Determine the traveling
distance/time between the locations and plan accordingly. A full day may be
necessary to properly inspect all records.
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Accumulate necessary inspection materials:
-copies of applicable notifications, exception reports, etc.
-employee identification
-copy of regulation
-bound notebook and writing implements
-manila folders
-large envelopes
-landfill recordkeeping checklist
-shipping supplies (if necessary)
-business cards
Try to plan the inspection for a day when asbestos is being accepted by the landfill so
that landfill deposition and recordkeeping operations may be observed first-hand.
Bring personal protective equipment, a camera, landfill inspection checklist and
asbestos sampling materials as needed.
If the landfill records are expected to be too numerous to review individually, devise a
sampling strategy which will fulfill the objectives of the inspection. The six basic
steps below are designed to help ensure that each sample selected is both appropriate
and defensible:
1) Determine the objective of the particular inspection step. What is the inspector
trying to determine and what needs to be reviewed to make the determination?
(e.g., compliance with the requirement to submit discrepancy reports - all
WSRs)
2) Identify the population under review. The population will vary depending on
the intent of the inspection, (e.g., all WSRs; all WSRs that contain discrepancy
information; WSRs for which exception reports have been filed, etc.)
3) Determine whether a judgmental or probabilistic sampling method should be
employed. A judgmental method is used when there is reason to suspect that a
violation or violations have occurred. Probabilistic (statistical) methods,
however, are more often used. (Keep in mind that the initial sampling strategy
selected may have to be altered during the actual inspection.)
Judgmental sampling is directed to the segments of the population where
problems or deficiencies are likely to exist For example, if the inspector is
responding to exception reports from a generator, only that generators' WSRs
may be examined.
Probabilistic sampling (statistical sampling) is an organized, methodical
process designed to select data which accurately represent the population of
interest Several varieties of such sampling are described below:
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-Random sampling: the objective is to select items purely by chance; pull
items at random, without prejudice, or number the documents and use a
random number table.
-Block sampling: the objective is to draw conclusions about the population by
examining certain segments or clusters of data that have been selected at
random; often used when the population is so large that random sampling
would produce too many subjects for review; can only be used when
population is expected to be consistent throughout.
For example, if the inspector is trying to determine whether discrepancy reports
are being filed appropriately, and information is available that no one was
assigned to that task for the first six months following promulgation of the
revisions to the Asbestos NESHAP, selecting a block of documents from that
time period would not be appropriate. The information gathered would not be
representative of the facility's compliance with these provisions.
-Stratification Sampling: the objective is to arrange items by important
categories or subsets; allows the inspector to categorize populations by groups.
For example, if the inspector is responding to numerous citizen complaints
concerning dust generated by dumping activities on Saturdays, only these
records may be selected for review.
'Interval Sampling: also known as systematic sampling; objective is to select
samples at various intervals (e.g., every tenth item); the first item must be
picked at random.
4) Determine the sample size. Sample sizes can be determined either statistically
or based on the inspector's judgment In all cases, the sample must be
representative of the total population selected. See Table 2-1.
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TABLE 2-1. DETERMINATION OF MINIMUM SAMPLE SIZE
5)
6)
Population
Size
2-8
9-15
16-25
26-50
51-90
91-150
151-280
281-500
501-1200
1201-3200
3201-10000
Conduct sampling.
Document the samplinj
Sample
Size
3
5
8
13
20
32
50
80
200
315
500
g strategy. In the field logbook describe the rationale for
selecting the sample and how the sample was selected.
Record known information. More efficient use of onsite inspection time is ensured if
preliminary information is recorded on the landfill recordkeeping inspection checklist
before arriving at the site.
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SECTION 3
FIELD INSPECTION ACTIVITIES
Onsite activities include a prc-inspection interview, records inspection and wrap-up interview.
PRELIMINARY INTERVIEW
During the preliminary interview, it is critical that discussions be properly documented for
they may later prove useful if violations are detected. The following steps should be
followed once an inspector arrives on site:
Show your identification and request to see the person in charge of maintaining the
records pertaining to ACWM disposal.
When this person arrives, introduce yourself and give him/her your business card.
Document the name and title of the person interviewed. Get his/her business card if
possible.
Explain the authority (Section 114 (a)(2) of the Clean Air Act), purpose (asbestos
NESHAP compliance), and components (records review) of the inspection.
Inform the representative that the facility may be required to provide the inspector
copies of records of interest
If records are being inspected at the landfill itself and offloading will be observed,
discuss safety requirements and emergency procedures and indicate that photographs
and/or samples may be taken.
Determine whether the landfill has a State-required permit to operate. If it does, check
the expiration date of the permit and record pertinent information on the inspection
form.
Ask the person to describe the recordkeeping procedures followed for WSRs and
ACWM deposited at the site.
Complete applicable sections of the Landfill Recordkeeping Inspection Checklist
If this is the facility's first Asbestos NESHAP compliance inspection, explain the
waste disposal requirements to the interviewee and answer any questions to the best of
your ability.
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Request the files you wish to review. If permission is denied, do not be forceful.
Simply explain again the authority of your visit and ask the person to contact his/her
supervisor regarding the situation. Either you or your agency's attorney may need to
contact the facility's attorney directly to resolve the difficulties.
REVIEWING RECORDS
The records of most interest at a waste disposal site are 1) WSRs for each shipment of
ACWM disposed of at the site, and 2) up-to-date records (on a map or diagram) that indicate
the location, depth and area, and quantity of ACWM within the site.
Waste Shipment Records
For all ACWM received, the owner or operator of the active waste disposal site must comply
with the following waste shipment recordkeeping provisions:
Record and maintain the following information on forms similar to that noted in the
regulation:
-waste generator's name, address and telephone number;
-transporter's name, address and telephone number,
-quantity of ACWM received (cubic yards or meters);
-presence of improperly-enclosed or uncovered waste, or any ACWM not sealed in
leak-tight containers; and
-date of receipt
Send a copy of the waste shipment record to the waste generator as soon as possible
but no longer than 30 days after receipt of the waste.
Attempt to reconcile differences in the amounts of ACWM received and that recorded
on the waste manifest form brought by the transporter. If the discrepancy is not
resolved within 15 days after receiving the waste, immediately submit a discrepancy
report which details the discrepancy and attempts made to reconcile it to the
governmental agency responsible for administering the asbestos NESHAP program for
the waste generator (identified in the waste shipment record), and, if different, the
governmental agency responsible for administering the asbestos NESHAP program for
the disposal site.
Retain a copy of all records and reports required by this paragraph for at least 2 years.
In inspecting the WSR file, note how the file is maintained and if the WSRs have been filled
out completely, including all of the required signatures. All signatures should be hand-
written.
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Note any WSRs that have an entry pertaining to discrepancies or improperly-contained waste
(Item 12 on the example WSR in the revised NESHAP) and ask how those discrepancies
were resolved. Ask to see copies of any discrepancy reports or reports of improperly-
contained waste submitted to the responsible agency for the WSRs in question.
Attempt to match information obtained during the pre-inspection agency file review
(notifications, exception reports, etc.) with records maintained by the waste disposal site.
Pay attention to the dates of shipment of ACWM and acceptance by the landfill. ACWM is
often stored by the transporter until a full load is accumulated.
Photocopy WSRs which lack the required information. If a photocopier is not available,
either 1) record the necessary information in sufficient detail or 2) remove the records from
the facility, photocopy them and return them later. (If records are to be removed from the
facility, sign a receipt indicating that they will be returned as soon as possible).
ACWM Deposition Records
Ask the site operator for the most recent tally of the total quantity of ACWM deposited at the
site. The operator should be able to provide you with a total that includes all but the most
recent shipments. Examine the records showing the location, depth and area, and quantity of
ACWM within the site to determine that they are up-to-date. Check to see that the proper
information is being collected and the backlog of information to be added to the records is
only for current waste shipments.
ADDITIONAL ACTIVITIES
If records are being reviewed at the landfill itself, you may be able to gain additional
information regarding compliance with the provisions of the Asbestos NESHAP by doing the
following:
Observe ACWM being off-loaded into the landfill. Note how the load is verified,
whether improperly-contained waste is present, and whether the vehicle is properly
marked during offloading. Take samples as necessary to help assess compliance with
the provisions of the waste disposal provisions of the asbestos NESHAP.
If offloading cannot be observed, interview the person directly in charge of waste
disposal site operations. Ask him/her to describe waste handling, load verification, and
recordkeeping activities.
Inspect the asbestos disposal site; compare your observations with information
recorded on the required site map.
Note the accessibility of the asbestos landfill area to the general public. If the landfill
operator claims that a natural barrier or fence is being used to deter access, determine
A92-279.txt 13
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if the Administrator has been informed and has agreed that access is sufficiently
restricted.
QUALITY ASSURANCE CHECK
Once you have finished reviewing pertinent records, check to see that the objectives of the
inspection have been met Have appropriate types and quantities of records been reviewed?
Have potential violations been thoroughly documented? Has the field inspection checklist
been completed?
POST-INSPECTION INTERVIEW
Once you have reviewed your inspection activities, conduct a quick, concise wrap-up
interview to obtain any additional information necessary and to convey to the owner/operator,
in general terms, the findings of the inspection. It is extremely important that you do not
make and convey a field decision concerning the facility's compliance for a number of
reasons which include the following:
You may later recall items you failed to mention and include them in your inspection
report; if an enforcement action is contested, your credibility and integrity could be
called into question.
Individuals other than yourself may make the final determination pertaining to the
facility's compliance status.
You may not be aware of other enforcement actions being taken.
In situations where potential violations have been identified, be sure to note (on your
checklist or in your field logbook) any observed or verbally-communicated responses of the
owner/operator. This documentation may prove to be of great importance where enforcement
actions are considered.
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SECTION 4
POST-INSPECTION ACTIVITIES
No matter how blatant a violation appears, or how thoroughly an inspection was done, an
enforcement case cannot be supported without proper records and documentation. It is
imperative that each agency in charge of administering the asbestos NESHAP program set up
and implement a system whereby supporting documentation is properly taken, controlled, and
maintained. Generated reports and checklists must be clear and concise and accurately
support the observations of the inspector. All records must be organized and properly
maintained to be accessible for future use.
The purpose of this section is to outline inspection followup procedures and provide general
guidance to aid in the process of report preparation, data management, document control, and
record maintenance and storage.
INSPECTION FOLLOWUP
When potential violations have been documented, the inspector should complete his/her
inspection report and brief his/her supervisor and/or attorney concerning the 1) need for
reinspection; 2) need for information request under Section 114 of the CAA; 3) enforcement
options available, etc.
REPORT PREPARATION
A comprehensive and properly completed checklist can serve as the inspection report The
following information should also be included:
Inspector observations;
Owner/operator admissions;
Description of evidence collected; and
Owner/operator response actions.
Since it may take several years before a lawsuit is filed, a detailed narrative of the inspection
will prove beneficial in refreshing the inspector's memory and will provide strong evidence
for the case.
DATA MANAGEMENT
Each violation of an asbestos landfill owner/operator should be entered into a computer
tracking system to provide a record of violations for the landfill.
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DOCUMENTATION
It is essential that all information gathered be properly documented, controlled and
maintained. Since checklists and reports generated by an inspector may be the basis of
affidavits for civil or criminal enforcement actions, they must be precise and legible. All
documents generated during the course of an inspection are considered part of the permanent
evidentiary file and should not be destroyed or thrown away, even if they become illegible or
if inaccuracies are discovered. Errors in documents should be noted and corrected.
RECORDS MAINTENANCE
Records need to be properly filed and maintained to allow for easy access of all case
documents. Records also need to be retained under storage conditions which minimize
deterioration or loss of data files.
Regardless of whether computer-based data management systems or manual procedures are
used, responsible individuals within a program office must be able to access and trace the
destination of project files. The inspector must be familiar with and use all filing procedures
appropriately.
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SECTION 5
ASBESTOS NESHAP ENFORCEMENT
EPA may take administrative and/or judicial actions against violators of the asbestos
NESHAP. Violations of asbestos landfill rccordkeeping and reporting requirements include,
but are not limited to the following.
LANDFILL RECORDKEEPING VIOLATIONS
Recordkeeping violations include failure to:
Maintain records of waste shipments.
Record information on location and amount of asbestos in disposal site.
Return a signed copy of the WSR to the generator.
Maintain records for sufficient time.
LANDFILL REPORTING VIOLATIONS
Reporting violations include failure to:
File discrepancy reports.
Report uncontained waste.
File reports within required time.
Report, upon closure, information to EPA (or its delegated authority) on location and
amount of waste.
Place, upon closure, a notification on deed to property concerning presence of asbestos
waste.
Notify EPA prior to excavating or disturbing buried asbestos-containing waste
material.
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Asbestos Waste Disposal Site
WSR Hecordkeeplng Requirements
Has a WSR
accompanied
the shipment of
ACWM?
61.150(d)(2)
Contact generator
to acquire
Information
Has ad required
information been
provided?
Contact generator
to acquire
Information
WSR- Waste Shipment Record
ACWM- Asbestos-Containing Waile Material,
WDS- Waste Disposal Site
Are amounts of
ACWM noted on
the WSR accurate?
Describe such
Inaccuracies in
Box 12 of the WSR
Contact waste
generator to resolve
inaccuracies.
61.154(e)(3)
b the problem
resolved within
15 days of receipt
of the ACWM?
8i.154(e)(3)
Immediately file a
discrepancy report
with the agency
responsible for
the generator
Is the agency
responsible for
the WDS different
from that of the
waste generator?
tmmedalely file a
discrepancy report
with the agency
responsible for
the WDS
Are significant
amounts of ACWM
improperly contained?
61.154(e)<1)(rv)
Describe such
deficiencies in
Box 12 of WSR
I
File an improperly-
contained waste report
by the following working
day with the agency
responsible for the
waste generator
61.t54(e)(1)
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APPENDIX B
ASBESTOS WASTE DISPOSAL SITE
RECORDS INSPECTION CHECKLIST
Site Name:
Site Address:
Agency Assigned Landfill Identification Number,
Inspectors):
Date of Inspection: Time of Inspection:
I. PRELIMINARY INTERVIEW
1. Owner Name:
2. Site Contact
a. Title:
b. Affiliation:
c. Mailing Address:,
d. Telephone Numben.
YES NO NA
3. Is the landfill approved by the State?
If yes, Operating Permit No.:_
Effective date: ' through.
4. Are waste shipment records maintained? (61.154(e)(l))
Where are WSRs filed? _^_
Do these records contain the following information?
a. Waste generator's information (61.154(e)(l)(i)):
1) name
2) address
3) telephone number
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YES NO NA
b. Transporter's information (61.154(e)(l)(ii)):
1) name _
2) address _
3) telephone number _ _
4) signature
c. Quantity of ACWM (cubic yards or meters)
d. Presence of improperly enclosed or uncovered
waste, or any ACWM not sealed in leak-tight
containers (61.154(e)(l)(iv)):
Has the landfill operator reported to the EPA, in
writing, by die following day, the presence of a
significant amount of improperly enclosed or
uncovered waste? (Record or photocopy WSRs
indicating improperly enclosed or uncovered waste.)
e. Date of receipt (61. 154(e)(l)(v))
f. Comments:. __ " _
5. Have signed copies of waste shipment records been sent
to the waste generator as soon as possible, but no longer
than 30 days after receipt of the waste? (61.154(e)(2))
Comments:
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6. Has the landfill operator attempted to reconcile differences
between the quantity of waste designated on the waste
shipment record and the quantity actually received?
(6U54(e)(3))
Explain:
YES NO NA
If the discrepancy is not resolved within 15 days after receiving
the waste, has a report been filed immediately with the
government agency responsible for administering the asbestos
NESHAP program for the waste generator
and
if different, the government agency responsible for
administering the asbestos NESHAP program for the
disposal site?
7. Are copies of all required records and reports retained for 2 years?
(61.154(e)(4)) _ __
8. Is a map or diagram of the disposal area being maintained?
(61.154(0) _ _
Does the map or diagram contain the following ACWM
information?
location
depth
area
quantity (cubic yards or meters)
9. Arc records available for inspection? (61.154(1))
10. Upon closure, has the disposal site operator informed
EPA as to the location and amount of waste? (61.154(g))
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11. Upon closure, has a notification concerning the presence of
asbestos waste been placed on the deed to the property?
12. Has written approval from the Administrator been obtained
prior to excavating or otherwise disturbing any ACWM
already deposited and covered? (61.154(j))
13. Has a stationary source report been filed with the
Administrator or government agency responsible for
administering the asbestos NESHAP program? (61.153.(a),
61.10)
14. When did construction of the disposal site commence?
(61.07)
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ITEMS
A Guide To Normal Demolition Practices Under The Asbestos NESHAP
-------
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Washington. DC 20460
EPA -340/1 -92-013
September 1992
Stationary Source Compliance Series
c/EPA
A Guide to Normal Demolition
Practices Under the Asbestos
NESHAP
-------
EPA-340/1-92-013
A Guide to Normal
Demolition Practices Under
the Asbestos NESHAP
(TRC Rcf. No. 1-456-019)
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planing and Standards
Stationary Source Compliance Division
Washington, DC 20460
September 1992
-------
DISCLAIMER
This manual was prepared by TRC Environmental Corporation for the Stationary
Source Compliance Division of the U.S. Environmental Protection Agency. It has
been completed in accordance with EPA Contract No. 68D20059, Work Assignment
No. IA2-19. This document is intended for information purposes ONLY, and may not
in any way be interpreted to alter or replace the coverage or requirements of the
asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), 40
CFR Part 61, Subpart M. Any mention of product names does not constitute
endorsement by the U.S. Environmental Protection Agency.
A92-1225.txt
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TABLE OF CONTENTS
Section Page
1 DEMOLITION PRACTICES AND NONFRIABLE MATERIALS 1-1
Introduction 1-1
Purpose 1-1
Definitions 1-2
2 PRE-DEMOLITION BUILDING STATUS 2-1
State and Local Regulations 2-1
Unsafe Building Declarations 2-1
Abatement Prior to Demolition 2-1
Intentional Burning 2-2
3 DEMOLITION PRACTICES BY TYPE OF ACM 3-1
Introduction 3-1
Resilient Floor Covering (Tiles) 3-1
Asphalt Roofing Products 3-3
Asbestos-Cement Products 3-3
4 DEMOLITION PRACTICES BY METHOD 4-1
Heavy Machinery Razing Operations 4-1
Explosions/Implosions 4-3
Hand Methods of Demolition 4-4
5 ONSITE WASTE HANDLING PROCEDURES 5-1
Introduction 5-1
Waste Consolidation 5-1
6 OFFSITE WASTE HANDLING PROCEDURES 6-1
Appendix I 1-1
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SECTION 1
DEMOLITION PRACTICES AND NONFRIABLE MATERIALS
INTRODUCTION
EPA revised the asbestos NESHAP regulations on November 20, 1990 (see 40 CFR Part 61
Subpart M). Although the NESHAP has not been revised to alter its applicability to friable
and nonfriable asbestos-containing materials (ACM), nonfriable asbestos materials are now
classified as either Category I or Category n material.
Category I material is defined as asbestos-containing resilient floor covering, asphalt roofing
products, packings and gaskets. Asbestos-containing mastic is also considered a Category I
material (EPA determination - April 9, 1991). Category n material is defined as all
remaining types of non-friable ACM not included in Category I that, when dry, cannot be
crumbled, pulverized, or reduced to powder by hand pressure. Nonfriable asbestos-cement
products such as transite are an example of Category n material.
The asbestos NESHAP specifies that Category I materials which are not in poor condition and
not friable prior to demolition do not have to be removed, except where demolition will be by
intentional burning. However, regulated asbestos-containing materials (RACM) and Category
n materials that have a high probability of being crumbled, pulverized, or reduced to powder
as part of demolition must be removed before demolition begins.
PURPOSE
EPA has identified a need to address how specific demolition practices affect Category 1 and
n nonfriable ACM. The purpose of this manual is to provide asbestos NESHAP inspectors
with such information.
This manual is intended to apply primarily to demolition and cleanup activities for buildings
that contain Category I nonfriable ACM. Although references will be made to Category n
nonfriable ACM, for the purposes of this document, it and all other RACM will be assumed
to have been removed prior to the start of actual demolition activities. Work practices
associated solely with building renovations will not be addressed.
This manual is designed to assist the asbestos NESHAP inspector in identifying practices that
normally do or do not make Category I nonfriable ACM become regulated asbestos-
containing material (RACM). Applicability determinations (both formal and informal)
provided by the Regional NESHAP Coordinators have been incorporated into the appropriate
sections of this document in an effort to promote nationwide consistency in applying the
asbestos NESHAP to these demolition practices.
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Activities associated with site cleanup such as segregation, reduction, and on and offsite
disposal of ACM are discussed because they may take place during or after the major
demolition activities at a site and consequently may influence a demolition contractor's choice
of methods.
DEFINITIONS
The following definitions taken from the November 20, 1990 revision of the asbestos
NESHAP regulation are provided for ease of reference.
Adequately wet means sufficiently mix or penetrate with liquid to prevent the release of
particulates. If visible emissions are observed coming from asbestos-containing material, then
that material has not been adequately wetted. However, the absence of visible emissions is
not sufficient evidence of being adequately wet
Asbestos-containing waste materials means mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to the provisions of this subpart.
This term includes filters from control devices, friable asbestos waste material, and bags or
other similar packaging contaminated with commercial asbestos. As applied to demolition
and renovations operations, this term also includes regulated asbestos-containing material
waste and materials contaminated with asbestos including disposable equipment and clothing.
Category I nonfliable asbestos-containing material (ACM) means asbestos-containing
packings, gaskets, resilient floor covering, and asphalt roofing products containing more than
one percent asbestos as determined using the method specified in appendix A, subpart F, 40
CFR part 763, section 1, Polarized Light Microscopy.
Category II nonfriable ACM means any material, excluding Category I nonfriable ACM,
containing more man one percent asbestos as determined using the methods specified in
appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy that, when
dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Cutting means to penetrate with a sharp-edged instrument and includes sawing, but does not
include shearing, slicing, or punching.
Demolition means the wrecking or taking out of any load-supporting structural member of a
facility together with any related handling operations or the intentional burning of any facility.
Facility means any institutional, commercial, public, industrial, or residential structure,
installation, or building (including any structure, installation, or building containing
condominiums or individual dwelling units operated as a residential cooperative, but
excluding residential buildings having four or fewer dwelling units); any ship; and any active
or inactive waste disposal site. For purposes of this definition, any building, structure, or
installation that contains a loft used as a dwelling is not considered a residential structure,
installation, or building. Any structure, installation or building that was previously subject to
this subpart is not excluded, regardless of its current use or function.
A92-1225.txt 1-2
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Facility component means any part of a facility including equipment
Friable asbestos material means any material containing more than one percent asbestos as
determined using the method specified in appendix A, subpart F, 40 CFR part 763 section 1,
Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to
powder by hand pressure. If the asbestos content is less than 10 percent as determined by a
method other than point counting by polarized light microscopy (PLM), verify the asbestos
content by point counting using PLM.
Grinding means to reduce to powder or small fragments and includes mechanical chipping or
drilling.
In poor condition means the binding of the material is losing its integrity as indicated by
peeling, cracking, or crumbling of the material.
Inactive waste disposal site means any disposal site or portion of it where additional asbestos-
containing waste material has not been deposited within the past year.
Installation means any building or structure or any group of buildings or structures at a single
demolition or renovation site that arc under the control of the same owner or operator (or
owner or operator under common control).
Nonfriable asbestos-containing material means any material containing more than one
percent asbestos as determined using the method specified in appendix A, subpart F, 40 CFR
part 763, section 1, Polarized Light Microscopy, that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.
Owner or operator of a demolition or renovation activity means any person who owns,
leases, operates, controls, or supervises the facility being demolished or renovated or any
person who owns, leases, operates, controls, or supervises the demolition or renovation
operation, or both.
Planned renovation operations means a renovation operation, or a number of such
operations, in which some RACM will be removed or stripped within a given period of time
and that can be predicted. Individual nonscheduled operations are included if a number of
such operations can be predicted to occur during a given period of time based on operating
experience.
Regulated asbestos-containing material (RACM) means (a) Friable asbestos material, (b)
Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will
be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category n
nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized,
or reduced to powder by the forces expected to act on the material in the course of demolition
or renovation operations regulated by this subpart.
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Remove means to take out RACM or facility components that contain or are covered with
RACM from any facility.
Renovation means altering a facility or one or more facility components in any way,
including the stripping or removal of RACM from a facility component. Operations in which
load-supporting structural members are wrecked or taken out are demolitions.
Resilient floor covering means asbestos-containing floor tile, including asphalt and vinyl floor
tile, and sheet vinyl floor covering containing more than one percent asbestos as determined
using polarized light microscopy according to the method specified in appendix A, subpart F,
40 CFR part 763, Section 1, Polarized Light Microscopy.
Strip means to take off RACM from any part of a facility or facility components.
Visible emissions means any emissions, which are visually detectable without the aid of
instruments, coming from RACM or asbestos-containing waste material, or from any asbestos
milling, manufacturing, or fabricating operation. This does not include condensed,
uncombined water vapor.
Waste generator means any owner or operator of a source covered by this subpart whose act
or process produces asbestos-containing waste material.
Waste shipment record means the shipping document, required to be originated and signed by
the waste generator, used to track and substantiate the disposition of asbestos-containing
waste material.
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SECTION 2
PRE-DEMOLITION BUILDING STATUS
This section discusses several factors that can affect the approach to demolition taken by a
demolition contractor. It is being included because events that have taken place prior to the
start of actual demolition work can influence the methodology(ies) chosen by demolition
contractors. These events can be evaluated by an inspector, allowing for prediction of
"hidden" potential problem areas. Reinforcement and clarification of applicable components
of the asbestos NESHAP regulations are also included in this section.
STATE AND LOCAL REGULATIONS
State and local asbestos regulations are sometimes more stringent than the asbestos NESHAP
regulations. This does not imply, however, that Category I nonfriable ACM is necessarily
removed from a building prior to demolition. Contractors surveyed during research conducted
in the preparation of this manual indicated that they typically treated Category I nonfriable
ACM as RACM only when the owner or operator of the building being demolished was a
state or local government agency or when project specifications explicitly specified that one
or more of the Category I nonfriable ACM materials be removed prior to the start of
demolition.
UNSAFE BUILDING DECLARATIONS
Several contractors surveyed utilized state or local mechanisms to have buildings declared
unsafe as a means to avoid NESHAP requirements during and after demolition activities.
However, a State or local agency should not issue a demolition order unless the facility is
structurally unsound and in danger of imminent collapse. These conditions should be
confirmed independently, and a demolition order should not be based solely on the
representation of the contractor or the contractor's agent Although issuance of a demolition
order may have an effect on notification requirements under the asbestos NESHAP (see
§61.145(a)(3)), it has no effect on requirements for disposal procedures for RACM after
demolition activities. Also, waste segregation/reduction activities, addressed in Section 5 of
this manual, are subject to the asbestos NESHAP provisions whether or not a building has
been declared unsafe.
ABATEMENT PRIOR TO DEMOLITION
Demolition contractors typically require that a building owner/operator accept responsibility
for the removal of all asbestos-containing materials found during the building inspection prior
to the start of demolition activities. Several contractors indicated that if suspect ACM
became exposed during demolition activities, and there was no prior knowledge of its
existence at the start of demolition activities, that potential asbestos NESHAP requirements
would be disregarded unless a change order was immediately processed by the owner/operator
A92-1225.txt 2-1
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requesting the time and materials necessary to achieve compliance with the asbestos
NESHAP. Such practices are in direct violation of the asbestos NESHAP.
INTENTIONAL BURNING
As stated in the November 1990 asbestos NESHAP revision (see §61.145(c)(10)):
"If a facility is demolished by intentional burning, all RACM, including Category / and
Category II nonfriable ACM, must be removed in accordance with the NESHAP before
burning."
Abandoned buildings utilized by fire departments for practice exercises involving partial
burning are subject to this requirement
For buildings which are still structurally sound but which have previously been subjected to
partial or total, intentional or unintentional burning, an inspection for the condition of all
ACM should be conducted. Category I ACM should be examined for friability and condition.
Friable materials or Category I materials that are friable and in poor condition must be
removed prior to any further demolition activity.
A92-1225.txt 2-2
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SECTION 3
DEMOLITION PRACTICES BY TYPE OF ACM
INTRODUCTION
For many years now the applicability of the asbestos NESHAP to demolitions involving
Category I nonfriable ACMs (packings, gaskets, resilient floor coverings and mastic, and
asphaltic roofing materials) has been the topic of much debate. Since significant amounts of
airborne asbestos fibers are not believed to be produced from such materials during normal
demolition activities, however, the asbestos NESHAP, in most cases, does not require their
removal prior to demolition.
Category I materials are considered RACM only when they "will be or have been subjected to
sanding, grinding, cutting, or abrading", they are in "poor condition" and "friable", or the
structure in which they are located will be demolished by burning. (Definitions for these
terms and additional information concerning Category I nonfriable ACM can be found in the
preamble to the November 1990 revised asbestos NESHAP (SUPPLEMENTARY
INFORMATION, Section IV - Significant Comments..., Demolition and Renovation,
Nonfriable ACM and Broken ACM).
The following information details specific pre-demolition and demolition practices and their
impact on Category I nonfriable ACM. The information has been compiled from telephone
surveys of demolition contractors, the viewing of activities at a number of demolition sites,
and formal and informal EPA applicability determinations. The effects of various demolition
practices on asbestos-cement products are also discussed. Since the applicability of the
asbestos NESHAP to Category n nonfriable materials is determined on a case-by-case basis,
it is hoped that this additional information will help foster nationwide consistency in the
application of the regulation to these materials.
As you will see, many of the various demolition techniques described do not, by themselves,
cause Category I nonfriable ACM to become RACM. However, in many cases, post-
demolition waste consolidation, cleanup, and recycling efforts can cause both .Category I
nonfriable ACM and Category n nonfriable ACM to become RACM. If that is likely to
happen, such materials must be considered RACM and be treated as such. Post-demolition
activities which can affect Category I and D materials will be detailed later in this manual.
RESILIENT FLOOR COVERING (TILES)
Depending on the types of activities occurring at a demolition site, floor tiles (and mastic)
may or may not become subject to the provisions of the asbestos NESHAP.
A92-1225.txt
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Pre-demolition Floor Tile Removal
Although not usually required by the asbestos NESHAP, removal of asbestos-containing
resilient floor tiles may occur prior to demolition. Such removal may be required when the
substrate to which the floor covering is attached (particle board, wood, concrete) is to be
recycled or salvaged.
Since the presence of mastic is not desirable on materials intended for resale or recycling,
contractors use a variety of methods to remove this material as well.
A wide variety of floor tile removal methods exists, some of which cause the floor tiles and
mastic to become RACM and subject to the provisions of the asbestos NESHAP. The
following describes various removal methods and the applicability of the asbestos NESHAP
to them.
Water/Amended Water/Solvents
Water, amended water, or solvents may be spread onto floor tiles in order to loosen them.
After a period of soaking, the tiles may be removed using long-handled scrapers (ice
cnippers), or gas- or electrically-powered mechanical chisels. In cases where tile breakage is
minimal, the floor tiles are not considered RACM. However, where breakage is extensive,
the tiles are RACM and arc subject to the provisions of the asbestos NESHAP.
Dry Ice
Although rarely used for this purpose nowadays, dry ice (frozen carbon dioxide) can be used
to remove floor tiles. When dry ice is applied to the tiles, the intense cold causes the tiles to
contract and detach from the substrate. As long as the tiles are not extensively damaged, they
are not considered RACM.
Infrared Machines
Infrared machines may be used in the removal of floor tiles. These machines heat the
flooring, thereby softening the tiles and adhesive, and allow for its easy removal. Since most
tiles detach intact, they are not friable, and therefore are not considered RACM.
Shot-blasters
Shot-blasters are sometimes used in the removal of floor tiles. These machines direct a
barrage of small pellets (shot) against the tiles and continually vacuum up and separate the
mixture of pulverized tile and pellets. The pellets are reused immediately and the pulverized
materials are segregated for disposal. EPA allows the use of shot-blasters only on wetted
floor tiles. Floor tiles and mastic removed by shot-blasters are considered RACM and are
therefore subject to the asbestos NESHAP.
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Demolition with Floor Tiles in Place
Since ordinary demolition activities do not include the sanding, grinding, cutting and abrading
of floor tiles, floor tiles and associated mastic that are not in poor condition and not friable
are not considered RACM and are allowed to remain in place during demolition.
ASPHALT ROOFING PRODUCTS
The pre-demolition terms and conditions (governmental regulations, contract specifications)
discussed in Section 2 also influence the handling of asbestos-containing roofing materials.
Pre-demolition Roof Removal
If preliminary assessment has determined that roofing materials contain asbestos, and
regulations or contract specifications dictate removal of such material prior to demolition,
h'censed abatement contractors may be required to do the removal. Alternatively, the
demolition contractor may undertake the operation.
Roofs may be removed in a variety of ways. Demolition personnel may use sledge hammers,
pry bars, axes, adzes, shovels, ice chippers and roof-cutting saws to remove the roofing
materials. They also may use tractor-mounted rotating blade cutters, power plows and power
slicers. Use of roof-cutting saws, either hand- or power-driven, or tractor-mounted, are of
great concern, since they can generate asbestos-containing dust from roofing materials. The
sawing of Category I nonfriable ACM roofing material and the debris created by the sawing
are regulated by the asbestos NESHAP. Since power plows and power slicers do not sand,
grind, cut or abrade the roofing materials, their use and resultant debris are not subject to the
asbestos NESHAP regulation. Category I nonfriable ACM roofing squares that have been
decontaminated may be disposed of with other demolition debris or at an asbestos landfill.
Demolition with Roofing Materials in Place
Since demolition activities do not include sanding, grinding, cutting, or abrading, Category I
asbestos-containing roofing materials not in poor condition and not friable are not considered
RACM and are allowed to remain in place during demolition.
ASBESTOS-CEMENT PRODUCTS
Asbestos-cement products (such as transite) are commonly used for duct insulation, pipes, and
siding. Being a Category II nonfriable ACM, asbestos-cement products need to be removed
prior to demolition if they have a high probability of becoming crumbled, pulverized, or
reduced to powder during demolition activities. EPA believes that most demolition activities
will subject such Category D nonfriable ACM to the regulation.
Whether asbestos-cement products are subject to the asbestos NESHAP should be determined
by the owner or operator on a case-by-case basis based on the demolition techniques to be
used.
A92-1225.txt 3-3
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In general, if contractors carefully remove asbestos-cement materials using tools that do not
cause significant damage, the materials are not considered RACM and can be disposed of
with other construction debris.
However, if demolition is accomplished through the use of cranes (equipped with wrecking
balls, clamshells or buckets), hydraulic excavators, or implosion/explosion techniques,
asbestos-cement products will be crumbled, pulverized or reduced to powder, and are subject
to the provisions of the asbestos NESHAP.
Some demolition contractors do not treat significantly damaged asbestos-cement products as
RACM; they mix it with other demolition debris and dispose of it in direct violation of the
waste-disposal provisions of the asbestos NESHAP.
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SECTION 4
DEMOLITION PRACTICES BY METHOD
Methods of destruction employed at demolition sites include the use of heavy machines,
explosions/implosions, and hand methods. All of these methods cause Category D nonfriable
ACM to become RACM; however, Category I nonfriable ACM (packings, gaskets, resilient
floor coverings, asphaltic roofing materials, mastic) that is not in poor condition and not
friable prior to the demolition operation may be subjected to most of these techniques without
becoming RACM. The following describes various demolition techniques and their effects on
nonfriable materials. All Category I nonfriable ACM referenced is presumed not to be in
poor condition and not friable prior to the demolition operation.
HEAVY MACHINERY RAZING OPERATIONS
For the purposes of this document heavy machinery (or equipment) includes large motorized
vehicles such as bulldozers with rakes, top loaders, backhoes, skid loaders/bobcats, hydraulic
excavators, and other similar machinery used for transporting, moving, or dislodging of
materials at a demolition site. Cranes equipped with wrecking balls, clamshells, or buckets
are also considered heavy machinery.
Heavy machinery is used at demolition sites for both razing operations and post-demolition
activities. "Razing", the process which reduces a building's structural skeleton to nibble,
typically occurs after the building's interior has been gutted by hand.
Use of heavy machinery during the razing process causes Category n nonfriable ACM, but
not Category I nonfriable ACM to become RACM. Use of such equipment during subsequent
operations, such as waste consolidation, however, is a major concern which will be addressed
in Section 5 of this document
Bulldozers and Similar Machinery
Included in this grouping of heavy machinery are all types of bulldozers, backhoes, top
loaders and skid loaders/bobcats commonly used in conjunction with hand methods to raze
buildings. Bulldozers move on tracks whereas backhoes, top loaders, and skid loaders operate
on rubber tires.
Only if a great deal of working space exists at a site, and a precisely-controlled demolition is
not necessary, can bulldozers such as 977 loaders and D-9s be used to demolish a building.
These bulldozers are typically equipped with giant rakes designed to ram building walls and
move debris.
977's or D-9s may be used to undermine a building, but hydraulic excavators (discussed later
in this section) are usually used for this purpose.
A92-1225.txt 4-1
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Backhoes and top loaders are mainly used for moving debris and tearing off sections of walls
and other building components.
Skid loaders, machines commonly used to load skids or pallets onto trucks, may be specially
equipped with a type of ram for use during demolitions and are usually of the "bobcat" type.
The razing of a building using the heavy machinery described above causes Category II
nonfriable ACM, but not Category I nonfriable ACM to become RACM.
Hydraulic Excavators
Hydraulic excavators, such as EL-300s, 225s or 215s, resemble a combination
bulldozer/backhoe and operate on tracks. They are easier to use and provide greater control
during demolition than the bulldozers described above. However, since they too raze
buildings by ramming and tearing, like bulldozers, their use in congested areas is limited.
Nearby buildings must be protected from the falling debris; plywood may be applied over the
windows and rubber tires may be used to cushion and prevent damage to walls of adjacent
structures.
On rare occasions, hydraulic excavators may be used to topple one- or two-story buildings by
means of an undermining process. The strategy is to undermine the building while
controlling the manner and direction in which it falls. The demolition project manager (who
in many jurisdictions must be licensed by the city or state) must determine where
undermining is necessary so that a building falls in the desired manner and direction. The
walls are typically undermined at a building's base, but this is not always the case as building
designs may dictate otherwise. Safety and cleanup considerations are also taken into account
in determining the methods to be used.
Since the toppling of a building constitutes a safety hazard and generates enormous quantities
of dust, many cities.and towns will not approve of this method of demolition. Where the
practice is allowed, the contractor may be required to keep the structure wet during
demolition. Hydrant permits may be required and, because of the wetting restrictions, such
demolitions may be impossible to accomplish during the winter.
Hydraulic excavators are also used to conduct cleanup activities such as excavation, fill
burial, material reduction, and material load-out
The use of hydraulic excavators during the razing process causes Category H nonfriable
ACM, but not Category I nonfriable ACM to become RACM.
Cranes (Wrecking Ball, Clamshell, Bucket)
Although often employed in the past, particularly during demolitions of high-rise structures,
cranes are now rarely used. They are expensive to operate and usually not necessary, since
renovation has displaced demolition as the method of choice in dealing with many out-of-date
A92-1225.txt 4-2
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structures. Cranes are currently used only in situations where other equipment cannot be
employed.
Cranes may be equipped with wrecking balls, clamshells or buckets, which are used in a
variety of ways. All three may be dropped or swung against the structure to demolish it
When employed in this manner, clamshells provide the greatest force of the three and result
in the fastest, most efficient demolition projects.
Buckets and clamshells allow a greater degree of control than wrecking balls. Buckets may
be raised to the level where internal demolition of the building is taking place and be used
merely to transport and segregate hand-loaded demolition materials collected from within.
Clamshells can take big bites out of the structure and facilitate the segregation of demolition
debris.
When demolition is accomplished by crane, the process can begin at the roof and progress
continually downward, or alternate up and down. Materials are segregated to the greatest
degree possible as the demolition progresses so that the need for post-demolition handling is
minimized. In the case of high-rise structures, the interiors are usually gutted by hand prior
to razing.
Effect on Category I Materials
The use of cranes during the razing process does not cause Category I nonfriable ACM to
become RACM; therefore, Category I materials which are not in poor condition and not
friable may remain in the building during such demolition.
Effect on Category II Materials
The use of wrecking balls on asbestos-cement (A/C) siding (a Category n nonfriable ACM)
on buildings is specifically addressed in the November 1990 asbestos NESHAP revision (see
SUPPLEMENTARY INFORMATION, Section IV - Significant Comments..., Demolition and
Renovation, Nonfriable ACM):
"...the A/C siding on a building that is to be demolished using a wrecking ball is very
likely to be crumbled, or pulverized with increased potential for the release of
significant levels of asbestos fibers. Such material in this instance should be removed
prior to demolition."
Therefore, A/C siding, although a nonfriable material, is considered RACM when a wrecking
ball is being used to demolish the structure. Whenever buckets and clamshells arc to be
swung like wrecking balls, A/C materials should also be considered RACM.
EXPLOSIONS/IMPLOSIONS
Building implosions utilizing explosive devices constitute a rarely-used demolition technique.
In simplest form, this method is accomplished through the use of explosive charges placed
A92-1225.txt 4-3
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strategically throughout a building so that the building collapses in on itself and debris does
not radiate outward to any appreciable distance. Relatively large quantities of dust are
created, however, and the direction and magnitude of transport are matters of concern.
Effect on Category I Materials
The asbestos NESHAP does not require the removal of Category I nonfriable ACM that is not
in poor condition and not friable prior to building implosions. Normal implosion techniques
do not cause nonfriable materials to become RACM. The destruction of buildings during
military target practice is considered to be another form of explosive demolition. Category I
materials may remain in place during target practice. However, if it can be expected that the
building and ACM will bum as a result of explosive demolition, the ACM must be removed
prior to demolition.
Recent examination of asbestos-containing floor tiles and roofing materials contained in a
large building demolished by implosion revealed that the floor tile was in fair to good
condition and had not become friable. Tiles had been broken up into small quantities of large
pieces as the individual floors collapsed upon each other. The roofing materials were
similarly affected; they too remained nonfriable following demolition by implosion.
EPA does not consider Category I material to be RACM as a result of building implosions.
If, however, Category I materials are to be subjected to sanding, grinding, cutting, or abrading
after demolition, they must be treated as RACM and be removed from the building before
demolition.
Effect on. Category D Materials
Category H materials, such as transite, found in or on buildings scheduled for
implosion/explosion destruction must be removed before such demolition. Such materials are
considered RACM because they have "a high probability of becoming crumbled, pulverized
or reduced to powder" during such activities. *
HAND METHODS OF DEMOLITION
This section of the manual addresses hand methods employed during demolition and includes
segregation activities which take place during demolition (as opposed to cleanup) and their
effects on Category I materials. "Hand methods", for the purposes of this manual, refer to the
use of motorized and non-motorized tools that can be operated by hand and are not used for
transportation. The methods discussed include not only those used in the gutting of building
interiors prior to razing, but also those used during razing itself. Unless otherwise noted,
"hand methods" refers to those methods that do not significantly damage the ACM and
therefore do not cause Category I nonfriable ACM to become RACM.
Most buildings of ten floors or less are currently razed at least partially, if not fully, by hand.
Hand methods allow much greater control over a building's collapse than other methods and
permit easier segregation of demolition materials for resale or recycling than other demolition
methods. In addition, hand methods may be required because of workspace limitations.
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Depending on the size of the job and demolition schedule, the size of a demolition crew may
vary from as few as five individuals to 30 or more. As a general rule, workers use relatively
inexpensive tools such as pry bars, hand-held saws, power saws, sledge hammers, axes, bolt
cutters, and acetylene torches during gutting and razing operations.
As the gutting/salvage activities progress, demolition debris is typically deposited into a trailer
or dumpster strategically placed outside a window of the building being demolished. The
window frame is removed and materials are loaded into the storage containers by hand, or,
where possible, by bobcats operating within the building. Many jobs require the use of dust-
tight chutes for the transport of such debris.
On the rare occasion where onsite burial of demolition debris is allowed, the first activity to
take place in the building is the removal of the first story's flooring. This is done so that as
waste materials accumulate on upper floors, they can be sent down into the basement through
the center of the building, typically through elevator shafts, for disposal. Chutes may be used
if elevator shafts are not available. Such onsite disposal typically is allowed only for
noncombustible materials such as cement and brick. Waste consolidation activities which
occur in the basement area are of great concern to EPA and are discussed in Section 5 of this
manual.
Excess demolition wastes are loaded out for transport to a landfill that accepts construction
debris. If no basement area exists, or if materials cannot be sent into dumpsters or trailers
immediately as previously described, debris may be stored in piles scattered around the site.
These materials may subsequently be moved by hand or through the use of light or heavy
machinery. Section 5 of this manual details such operations.
Floor Removal and Disposition
The techniques used in removing flooring depend upon its ultimate fate. Where it is in poor
condition and incapable of being reused or recycled, the flooring is typically ripped out using
pry bars and sledge hammers and sent offsite for disposal. Sometimes wood flooring and
other debris is burned to reduce the volume of waste. In this case, the asbestos must be
removed prior to burning the wood debris. Since demolition debris disposal costs are so high
($100 - $500 per 60-100 cubic yard load) as much salvage/recycling of materials is done as
possible.
Wood or particle board flooring is sometimes segregated and sold to recycling centers where
it is chipped up and sold as filler or mulch (composting, gardening, etc.). If resilient
asbestos-containing floor covering is attached to such flooring it is considered RACM and
must be removed prior to recycling. Tiles are often chipped or scraped off the substrate using
the methods described in Section 3.
Large planks and joists, and beams (both wooden and steel) may also be saved if they are in
good condition. Wooden planks are usually lifted with pry bars, whereas the larger joists and
beams are segregated for reuse following the razing of the structure.
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Where demolition debris will be recycled, any asbestos remaining on the debris must be
removed prior to any recycling that will sand, grind, cut, or abrade the asbestos or otherwise
cause it to become RACM.
Roof Removal and Disposition
On occasion one may find that the roof of a building being demolished is removed before the
building is razed. Such removal may be required when buildings are very close to one
another, or when the roofing contains asbestos-containing materials.
There are two major types of roofing: "built-up roofing" and "sheet goods". Built-up roofing
contains multiple layers of felt and asphalt Sheet goods typically consist of a single layer of
material.
Roofs are often taken out by hand, typically by using pry bars, sledge hammers, axes, adzes,
bolt cutters, ice chippers, shovels and roof-cutting saws. If the roof contains asbestos
materials (felt, cork, etc.), an asbestos removal contractor may be employed to remove it
Some abatement contractors wet the roof with plain or amended water and then use shrouded
power saws whose exhaust is HEPA-filtered to cut the roofing into manageable (often 2' x
3') pieces. After the pieces arc lifted, the edges may be encapsulated. Other abatement
contractors may build a full containment and establish a reduced pressure environment prior
to removing the roofing materials.
Depending upon the contractors involved and the condition of the asbestos-containing roof
debris, the debris may or may not be segregated from other demolition debris. Abatement
contractors may store roof debris in lined dumpsters onsite and dispose of it at an asbestos
landfill; if the asbestos-containing roofing material is not in poor condition and is not friable
however, it may be disposed of in a landfill which accepts ordinary demolition waste.
Asbestos-containing.roofing material may not be ground up for recycling into other products.
Work Progression
Demolition crews typically work downward, floor by floor. Materials such as doors,
windows, electrical and other fixtures which can be salvaged are removed first Interior
partitions are then ripped, cut, or knocked out using various hand-held tools including sledge
hammers, axes, adzes and pry bars. Brick is generally segregated immediately after being
knocked out of walls so it can be examined at the site by potential buyers. Ceilings are also
ripped out using pry bars, axes and sledge hammers. Steel and other metal materials are
typically placed in separate debris piles from other materials. Work proceeds in a similar
floor/wall, floor/wall pattern until the first floor is once again reached.
Sawing/Cutting Operations
In order to raze a building by hand, load-bearing members must be cut Based upon the
composition, thickness, and condition of the structural member being cut saws selected range
A92-1225.txt 4-6
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from hand saws to Sawz-alls and gas-driven carbide blade hand saws. Large bolt cutters
are also used to cut steel members. Category I materials subjected to sawing or cutting are
subject to the provisions of the asbestos NESHAP; however, typical demolition sawing/cutting
operations rarely involve such materials.
Grinding Operations
Grinding operations are not common occurrences at most demolition sites. On occasion,
however, asbestos-containing mastic and remaining pieces of floor tile may be ground off
concrete destined for recycling. Category I material so treated is RACM and is subject to the
provisions of the asbestos NESHAP.
Pulverizing Operations
On occasion, asbestos-containing floor tiles are removed from their substrate by hand, using
either hand-held ice choppers or electrically- or gas-powered mechanical chippers. If use of
such methods pulverizes, crumbles or reduces the floor tiles to powder, the tiles must be
considered RACM and must be handled in accordance with the requirements of the asbestos
NESHAP.
Summary
On rare occasions Category I nonfriable ACM may be subjected to hand methods involving
the uncontrolled drilling, cutting, sawing, grinding or abrading of such materials; under these
circumstances Category I materials are considered RACM.
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A92-1225.txt
4-8
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SECTION 5
ONSITE WASTE HANDLING PROCEDURES
INTRODUCTION
At the present time it is not demolition operations and ordinary cleanup activities but the
post-demolition activities involving waste consolidation and recycling of Category I and n
materials which are of greater concern. If such activities subject either Category I or n
nonfriable ACM to sanding, grinding, cutting or abrading, the materials become RACM and
are then subject to the provisions of the asbestos NESHAP.
In general, since cleanup activities such as loading waste debris onto trucks for disposal do
not subject nonfriable materials to sanding, grinding, cutting or abrading, such materials are
not considered asbestos-containing waste materials and are not regulated by the asbestos
NESHAP.
However, waste consolidation efforts which involve the use of jack hammers or other
mechanical devices such as grinders to break up asbestos-containing concrete or other
materials covered or coated with Category I nonfriable ACM, are subject to the regulation.
In addition, operations such as waste recycling which sand, grind, cut, or abrade Category I or
n nonfriable ACM are subject to the asbestos NESHAP. When these types of activities are
performed, Category I and II nonfriable ACM become RACM.
The following details the post-demolition activities of waste consolidation (segregation and
reduction), waste load-out and onsite waste disposal and their effects on nonfriable ACM.
WASTE CONSOLIDATION
Waste consolidation operations involve segregation and reduction activities that have as their
ultimate goal the resale, recycling, and disposal of demolition debris.
Segregation of Demolition Debris
Demolition contractors segregate demolition debris primarily to maximize their profits. As
much material as possible is collected for resale and recycling (e.g., wood, brick, steel and
concrete); the remaining debris is most often transported offsite for disposal.
Segregation may involve cutting and grinding operations, the breaking and tearing apart of
materials to separate them by material type, and the transport of materials within the
demolition site boundaries.
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Since segregation activities may be accomplished using hand methods and heavy equipment,
nonfriable ACM may or may not become friable in the process. The following text details
various segregation activities and describes their effects on nonfriable materials.
Segregation by Hand
Materials such as wood, brick and steel are generally separated from other demolition debris
using equipment such as sledgehammers, prybars, adzes and axes. If any hand equipment is
used to cut, sand, grind, or abrade Category I or II materials, RACM is thus created and the
provisions of the asbestos NESHAP apply.
Material Transport
Since heavy equipment is often used to move and segregate demolition debris, questions have
been raised concerning the effect of such transport particularly on Category I nonfriable
ACM.
If Category I nonfriable ACM is transported across a demolition site in the bucket of a top
loader, backhoe, hydraulic excavator or other similar vehicle, it is not considered RACM
since it is not subjected to sanding, grinding, cutting or abrading during this activity.
Use of bulldozers, on the other hand, is expected to have a greater impact on Category I
materials. However, EPA has stated that "...if the bulldozer is moving the debris or picking it
up to be put in a vehicle and inadvertently runs over Category I material, then it is not
subject to the NESHAP standard" (see Appendix I). Consequently, the moving of debris by
bulldozers, whether by carrying it in a bucket or pushing it along the ground does not in itself
cause Category I nonfriable ACM to become RACM.
Category n nonfriable ACM subjected to sanding, grinding, cutting or abrading during
collection and transport is considered RACM and thus subject to the asbestos NESHAP.
Vehicular Traffic Impact
Rubber-tired Vehicles
If nonfriable ACM is intentionally run over by rubber-tired vehicles as a means of
segregation, it does not automatically become RACM but must be examined for damage. If it
has become extensively damaged, i.e., it was sanded, ground, cut or abraded during
segregation, it becomes RACM and is subject to the NESHAP regulation.
Tracked Vehicles
Although tractor treads present greater risks of causing extensive damage to nonfriable ACM,
limiting their use at demolition sites is not considered practical. Intentionally running over
nonfriable ACM with tractor treads as a means of segregation is considered grinding; material
thus treated becomes RACM.
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Intentional segregation in this manner is addressed in the preamble to the revised asbestos
NESHAP (SUPPLEMENTARY INFORMATION, Section IV, Significant Comments and
Changes to the Proposed Revisions, Demolition and Renovation, Nonfriable ACM):
"Examples of practices...included the breaking ofnonfriable insulation from steel
beams by repeatedly running over the beams with a crawler tractor...these and other
similar practices involving nonfriable asbestos material were considered to render
nonfriable ACM into dust capable of becoming airborne."
Reduction of Demolition Debris
Reduction activities are of the greatest concern to EPA, since they are most likely to cause
both Category I and Category 13 nonfriable ACM to become RACM.
Category I Reduction
The use of bulldozers to reduce the volume of Category I materials causes them to become
RACM as discussed elsewhere in this manual and in the following EPA correspondence:
"If, after a demolition, material left in the facility... is intentionally ground up (such as
repeatedly running over the debris with a bulldozer to compact the material), then
6J.150(a)(3) applies. The material must be adequately wetted and kept adequately wet
during collection and transport to a site or facility operated in accordance with
61.154 or 61.155." (See Appendix I).
Reduction by the use of sledgehammers does not normally cause Category I nonfriable ACM
to become RACM. The use of pneumatic hammers, however, whether hand-operated or
attached to heavy machinery, does cause these materials to become RACM. The use of
cranes with clamshells or other heavy machinery with rakes or buckets to partially reduce
Category I nonfriable ACM is permissible if the material is left recognizable in its original
form. Extensively damaged Category I ACM (that which has been sanded, ground, cut, or
abraded) becomes RACM. Consolidating waste materials containing Category I nonfriable
ACM in the hole (basement) of a building and subsequently grinding or crushing it via
bulldozer subjects the operation to the asbestos NESHAP.
For wood/tile debris, demolition crews sometimes use tree chippers to grind the material up.
Any Category I nonfriable ACM subjected to this treatment becomes RACM.
Category II Reduction
Reduction of Category n materials such as asbestos-cement pipe and concrete following
demolition is also a matter of concern.
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Asbestos-Cement Pipe
EPA considers asbestos-cement pipe to be a "facility component" (as defined in 40 CFR
§61.141) of the facility which owns or utilizes the pipe. In addition, EPA considers asbestos-
cement pipe to be Category n nonfriable asbestos containing material. This material becomes
"regulated asbestos containing material" (RACM), as defined in 40 CFR §61.141, when it
becomes "friable asbestos material" or when it "has a high probability of becoming or has
become crumbled, pulverized or reduced to powder by the forces expected to act on the
material during the course of demolition or renovation operations regulated by [40 CFR Part
61 Subpart M]." Consequently, the crushing of asbestos-cement pipe with mechanical
equipment will cause this material to become RACM. The demolition and renovation
provisions in 40 CFR §61.145 and the waste disposal provisions in 40 CFR §61.150 apply to
asbestos-cement pipe where the pipe is considered RACM, and the amount of pipe being
removed and crushed is at least 260 linear feet for a single renovation project or during a
calendar year for individual nonscheduled operations.
Concrete
At certain demolition sites demolition contractors may rent and operate large concrete-
pulverizing machines called PC-400s. Since the asbestos content of concrete is rarely known,
use of such machines is a matter of concern to EPA. Under no circumstances should
asbestos-containing concrete, or concrete to which asbestos-containing resilient flooring is
attached, be subjected to such treatment
Onsite Waste Disposal
As mentioned in other sections of this manual, using heavy machinery to crush demolition
debris containing Category I or n nonfriable ACM in place prior to or during burial, can
cause the ACM to become RACM subject to the provisions of sections §61.150 (waste
disposal) and §61.151 (inactive waste disposal sites) or §61.154 (active waste disposal sites).
If Category I or n materials are not rendered friable, they are not subject to the asbestos
NESHAP.
EPA has recently responded to a question regarding the onsite disposal of crushed asbestos-
cement pipe, a Category II material. The response is applicable as well to the burying of
Category I material which has been sanded, ground, cut or abraded. In its correspondence
EPA stated that the practice of backfilling and burying crushed asbestos-cement pipe in place
causes these locations to become active waste disposal sites subject to the requirements of
§61.154. Furthermore, if no additional asbestos-containing waste material is buried at that
location for a year, the site becomes an inactive waste disposal site subject to the
requirements of §61.151(e) and §61.154(h).
Consequently, the owner of the land would be required to comply with the requirements for
active and inactive waste disposal sites.
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In order to avoid the creation of a waste disposal site which is subject to the Asbestos
NESHAP, it was suggested that the owners or operators of the pipe consider other options for
dealing with it If the pipe is left in place or removed in such a way that it is not crumbled,
pulverized or reduced to power, it would not be subject to the NESHAP. If the pipe must be
crushed, the creation of an active waste disposal site can be avoided by removing the pipe
from the site and transporting it to a landfill which accepts asbestos waste material.
An alternative method suggested involved the pumping of grout into the buried lines which
are no longer in service.
Waste Load Out
As mentioned previously, waste load out activities generally do not cause Category I
nonfriable ACM to become RACM. Top loaders are typically used to deposit demolition
debris containing Category I nonfriable ACM into trucks for hauling to landfills that accept
construction debris.
Recent EPA correspondence discusses the hauling and ultimate disposal of both Category I
and Category n ACM as follows:
It is required under §61,150(a)(3) that asbestos-containing waste material be kept
adequately wet. Asbestos-containing waste material as applied to demolitions and
renovations includes RACM waste and materials contaminated with asbestos including
disposable equipment and clothing. Category I or Category II nonfriable ACM that
has been contaminated by RACM, and cannot be decontaminated (e.g., building debris
in a pile contaminated with RACM) must be treated as asbestos-containing waste
material. Category I or Category II ACM that does not meet the definition of RACM
after a demolition or renovation, and is not contaminated with RACM, is not asbestos-
containing waste material and is not subject to the wetting requirement of
§61.150(a)(3.).
Category I or 77 nonfriable ACM that is not subject to §61J50(a)(3) would still have
to be disposed of in a landfill that accepts building debris, in a landfill that operates
in accordance with §61.154, or at a facility that operates in accordance with §61.155.
This waste material would not be allowed to go to any facility that would sand, grind,
cut or abrade the non-RACM waste or otherwise turn it into RACM waste (such as a
cement recycling facility). In addition, if Category I or II nonfriable ACM is sanded,
ground, cut or abraded during disposal at a landfill, before it is buried, it is subject to
the NESHAP. (See Appendix I).
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5-6
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SECTION 6
OFFSITE WASTE HANDLING PROCEDURES
The issues discussed in this section include landfills, recycling centers, conversion facilities,
and renovation activities. Since EPA has taken a "cradle to grave" approach regarding the
disposition of ACM, responsibility for the ultimate fate of Category I ACM rests with all
individuals involved in handling the material.
Landfills
Category I and n ACM that has become RACM must be disposed of in a landfill that
operates in accordance with §§61.150 and 61.154, or in an EPA-approved conversion facility
described in §61.155 of the asbestos NESHAP.
Category I and II nonfriable ACM which has not become RACM during demolition may be
disposed of in a landfill that normally accepts construction debris. However, if Category I or
n nonfriable ACM is sanded, ground, cut or abraded before it is buried at the landfill, it is
subject to the asbestos NESHAP.
Recycling Centers
At the present time, EPA does not allow either Category I or H nonfriable demolition debris
to go to any facility (e.g., a cement recycling facility) that will sand, grind, cut or abrade it or
otherwise turn it into RACM waste. Recycling facilities which cause non-RACM waste to
become RACM waste are subject to the provisions of the asbestos NESHAP (See
Appendix I).
Conversion Facilities
Conversion facilities are addressed in Section 61.155 of the November 1990 revised asbestos
NESHAP. Owners/operators of such facilities must handle ACWM according to the
provisions of the asbestos NESHAP.
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ITEM 9
Guidelines For Catastrophic Emergency Situations Involving Asbestos
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&EPA
United States
Environmental Protection
Agency
Air And Radiation
(EN-341W)
EPA 340/1-92-010
February 1992
Guidelines For Catastrophic
Emergency Situations
Involving Asbestos
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Guidelines for Catastrophic Emergency Situations
Involving Asbestos
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
September 1991
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TABLE OF CONTENTS
I. INTRODUCTION 1
A. Background 1
B. Purpose 1
H. RECENT EMERGENCIES 3
A. Gramercy Park 3
B. Hurricane Hugo 3
C. San Francisco Earthquake 4
m. OTHER APPLICABLE STATUTES 6
A. AHERA 6
B. EPCRA 6
C. CERCLA 7
D. OSHA 7
TV. ASBESTOS NESHAP APPLICABILITY 8
A. Definitions (61.141) 8
B. Demolition and Renovation Provisions (61.145) 9
1. Emergency Renovation Operations 9
2. Government-Ordered Demolitions 10
C. Waste Disposal (61.150) 11
D. Active Waste Disposal Sites (61.154) 12
V. PRE-EMERGENCY PLANNING 13
A. Emergency Response Organization 13
B. Coordination With Local Emergency and Related Organizations 13
1. The Problem 18
2. Strategy 18
C. Mapping Asbestos Locations 20
1. Asbestos Milling, Manufacturing, and Fabricating 20
2. Asbestos in Facilities 21
a. Surveys of Buildings for Asbestos 21
b. Schools 23
c. Local Building Permit Agencies 23
d. Notifications 25
D. Cleanup and Disposal 25
1. Water Supply 26
2. Chemical Contamination 26
3. Waste Disposal 27
4. Backup Personnel 27
5. Laboratory Capabilities 27
6. Emergency Exemptions 28
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VH. CONCLUSIONS 30
REFERENCES 32
APPENDIXES
A Asbestos NESHAP Checklist for Catastrophic Emergency Situations 33
B FEMA Regional Directors 35
C State Official Responsible for Disaster Operations 39
D Regional Asbestos Coordinators 54
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GUIDELINES FOR CATASTROPHIC EMERGENCY SITUATIONS
INVOLVING ASBESTOS
I. INTRODUCTION
A. Background
In 1989, the California earthquake and Hurricane Hugo resulted in the destruction of
or damage to numerous buildings, many of which contained asbestos. Badly damaged or
destroyed structures had to be demolished quickly to reduce the threat of injuries from the
damaged structures and to aid in restoring the affected areas. In the same year, a steam pipe
explosion in Gramercy Park, NY spread asbestos over a wide area with the potential to
expose a large number of people to asbestos.
These recent natural and man-made disasters and others that have damaged or destroyed
structures containing asbestos have served to focus attention on the need to consider asbestos
along with other emergency response activities. Understandably, the emphasis in an
emergency or disaster situation is on efforts to mitigate the immediate threats to public health
and safety and to return the stricken area to its former condition as quickly as possible. Also,
the organizations that typically respond to emergency or disaster situations, such as fire
departments and emergency management agencies, do not deal with asbestos as part of their
normal duties. As a result, there may be a tendency to overlook potential public health
threats like asbestos, which do not pose an immediate, life-threatening hazard.
B. Purpose
These guidelines are intended to assist Regional, state, and local agencies in
managing potential asbestos hazards resulting from a catastrophic accident or disaster. The
guidelines may be used as a reference for advanced planning or, once the emergency presents
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itself, to help ensure that, to the extent feasible and compatible with other emergency
measures, all appropriate steps are taken to safely handle and dispose of all asbestos, while
avoiding unnecessary exposures to asbestos. The guidelines provide information that may be
helpful to EPA Regional offices and delegated NESHAP agencies that must respond to
emergencies involving asbestos.
The guidelines review the experiences of EPA Regional and state enforcement agencies
in dealing with asbestos during recent emergencies. Information is included on statutes and
regulations that may be applicable in emergency situations, including the emergency
provisions of the asbestos NESHAP. Lines of communication within EPA and between EPA
and emergency management agencies are discussed. A list of contacts responsible at the state
level for emergency and disaster activities is provided, as is a protocol for coordinating
asbestos NESHAP activities with local fire and building departments. Information is provided
to help identify potential sources of asbestos releases, and factors are identified that should be
considered in planning for the cleanup and disposal of asbestos.
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H. RECENT EMERGENCIES
Three emergencies occurred in 1989 that focused EPA's attention on the handling of
asbestos. One was a technological failurea Consolidated Edison steam pipe explosion at
Gramercy Park in N.Y. City; the other two were natural phenomena-Hurricane Hugo and the
San Francisco earthquake. These emergencies are reviewed here for lessons that may help
plan for and deal with similar problems in the future.
A. Gramercv Park
On August 19, 1989, an underground Consolidated Edison steam pipe exploded in
Gramercy Park in New York City, discharging 400°F steam, asbestos and mud into the air
and onto and into nearby buildings. The explosion killed three people, injured 24, and forced
the evacuation of 200 residents. Two-hundred pounds of asbestos from pipe insulation were
released with the explosion. The cleanup and decontamination of the contaminated structures
required several months. The asbestos-contaminated waste was collected and transported to
the Meadowfill Landfill, Clarksburg, West Virginia for disposal. The cleanup was supervised
by the New York City Department of Environmental Protection, with oversight by EPA. This
cleanup effort was not regulated under the asbestos NESHAP, because it was neither a
demolition nor a renovation.
B. Hurricane Hugo
In September 1989, Hurricane Hugo made a landfall on the South Carolina coast at
Charleston destroying many buildings, damaging many others, and creating vast amounts of
debris, some of it contaminated by asbestos. The City of Charleston was declared a disaster
area and the South Carolina Department of Health and Environmental Control (SCDHEC) was
asked to assist with the cleanup of debris. To deal with a problem of such great magnitude,
SCDHEC adopted the following procedures:
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Buildings destroyed by Hugo were considered to be demolished by natural
causes and notification requirements were waived. Removal contractors
were not required for the cleanup; however, wetting and proper disposal of
asbestos-containing material were required.
Remaining, uncontaminated building debris was disposed of in accordance
with solid waste regulations.
Open burning was permitted in the disaster area to clear it of trees and
wood products without using landfills.
Partially destroyed buildings could be demolished without notifications
after asbestos materials were removed by abatement contractors.
A problem that emerged in South Carolina was that of unscrupulous contractors preying
on unsuspecting home owners by telling them that they were subject to $25,000 a day in fines
unless their roofs were repaired by licensed asbestos contractors, when, in fact, SCDHEC
regulations did not apply to private residences unless the homeowner selected a licensed
asbestos contractor. A one-page Guidelines for Homeowners with Damaged Asbestos
Roofing was issued by SCDHEC to outline requirements for homeowners.
Emergency preparedness representatives, presumably unaware of the presence of
asbestos, complicated asbestos NESHAP enforcement by instructing people to go ahead and
knock down damaged buildings.
C. San Francisco Earthquake
On October 17, 1989, an earthquake registering 7.1 on the Richter scale shook San
Francisco. According to the Region 9 asbestos NESHAP coordinator, many demolition
contractors thought the NESHAP regulations did not apply following the earthquake and
many buildings were demolished without regard to asbestos. At a minimum, the NESHAP
coordinator feels that wetting should be employed and the debris disposed of properly.
Based on the Region 9 experience, the NESHAP coordinator suggested the following to
prepare for emergencies:
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Create an emergency phone list
Coordinate with nearby Regions
Tie into existing emergency communication plans
Set up an emergency protocol for buildings and fire departments
Set up emergency protocols with delegated agencies
Prepare and pie-position press releases regarding NESHAP and asbestos
risks
Contact the Federal Emergency Management Agency (FEMA) regarding
asbestos risks and NESHAP
Contact state emergency planners
Set up an informal network of volunteer inspectors.
The NESHAP coordinator also noted that there was a shortage of inspectors available to
determine whether asbestos was present in the damaged buildings and that obtaining
additional help was a problem.
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m. OTHER APPLICABLE STATUTES
In addition to the asbestos NESHAP, there are other Federal statutes that provide
planning information and/or cleanup authority applicable to catastrophic emergencies
involving asbestos. They include the Asbestos Hazard Emergency Response Act (AHERA);
the Emergency Planning and Community Right-to-Know Act (EPCRA); the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA); and the
Occupational Safety and Health Act (OSHA).
A. AHERA
Regulations promulgated under the authority of AHERA require the preparation of
management plans for asbestos in school buildings (40 CFR 763.93). Plans must be prepared
by an accredited management planner and include:
The name and address of each school building and whether it contains
friable asbestos.
A blueprint, diagram or written description that identifies the location and
approximate square or linear feet of asbestos.
Thus, a data base on asbestos in school buildings already exists in the administrative offices
of school systems in many communities. This data base is potentially useful either for
emergency response planning or for identifying asbestos-containing structures following the
occurrence of a catastrophic emergency.
B. EPCRA
Since asbestos is not listed as an extremely hazardous substance, emergency plans
developed under EPCRA do not address asbestos. However, the Act also requires routine
toxic chemical release reporting and friable asbestos is a reportable emission (40 CFR
372.65). Information collected in this way is entered into a computer file known as the Toxic
Release Inventory System (TRIS) which can be accessed to identify asbestos sources in SIC
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codes 20 through 39. TRIS would seem to be a useful database for either emergency
response planning or identifying facilities where friable asbestos might be expected following
an emergency.
C. CERCLA
Hazardous air pollutants regulated under the Clean Air Act (CAA) are also
regulated as hazardous substances under CERCLA. CERCLA provides the authority and
funds for emergency government response to hazardous substance releases into the
environment, including the ambient air and allows the federal government to recover the costs
of responding to and cleaning up hazardous substance releases.
Emissions of reportable quantities (RQs) of listed substances must be reported to the
National Response Center in Washington. The RQ for asbestos is 1 Ib. (0.454 kg) of pure
asbestos (40 CFR 302.4).
As noted earlier, the Gramercy Park response was conducted under New York City law
and was not regulated under the asbestos NESHAP. A federal response could have been
carried out under CERCLA, however, if that had been needed.
D. OSHA
The OSHA rules on asbestos (29 CFR 1910.1001 and 29 CFR 1926) are applicable
in catastrophic emergencies. OSHA rules specify a permissible exposure limit for asbestos,
respiratory protection, work practices, and engineering controls for worker protection. There
are no exemptions for emergencies in the Act.
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IV. ASBESTOS NESHAP APPLICABILITY
The applicability of the asbestos NESHAP (40 CFR Part 61, Subpart M) in emergency
situations is discussed here. Whenever asbestos will be damaged or disturbed as part of a
demolition or renovation and a threshold amount (160 square feet, or 260 linear feet, or 35
cubic feet) is exceeded, or whenever a building is demolished, the asbestos NESHAP applies.
There are no provisions that stay the applicability of the NESHAP as a result of disaster,
although there are emergency-related provisions. The relevant sections of the NESHAP
include Definitions (61.141), Standard for Demolition and Renovation (61.145), Standard for
Waste Disposal for Manufacturing, Fabricating, Demolition, Renovations, and Spraying
Operations (61.150), and Active Disposal Sites (61.154).
A. Definitions (61.141)
The only definition mat is specifically applicable to emergencies is "emergency
renovation operation." The NESHAP defines the term as follows:
"Emergency renovation operation" means a renovation operation that was not
planned but results from a sudden, unexpected event mat, if not immediately
attended to, presents a safety or public health hazard, is necessary to protect
equipment from damage, or is necessary to avoid imposing an unreasonable
financial burden. This term includes operations necessitated by nonroutine failures
of equipment.
The repair or replacement of an apartment building's asbestos-insulated boiler that fails
during the winter may be considered an emergency renovation, since to delay repair or
replacement could expose residents of the apartment building to dangerously cold
temperatures. Or, the repair of asbestos-insulated equipment mat suddenly fails at a power
plant could result in prolonged power outages and affect many essential services if not
attended to immediately. These are examples of asbestos removal operations that might be
considered emergency renovations. It is usually the responsibility of the building owner or
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operator to demonstrate that the renovation was an emergency. The implications for an
emergency renovation in the context of the NESHAP requirements are discussed below.
B. Demolition and Renovation Provisions (61.145)
The demolition and renovation provisions of the NESHAP contain specific
requirements that may apply in certain emergency situations and include the provisions for
emergency renovation operations and government-ordered demolitions.
1. Emergency Renovation Operations
In order for a renovation to be considered an emergency renovation operation
and be subject to the NESHAP, it must satisfy the definitional requirements of an emergency
renovation operation and it must also meet the applicability requirements of Section 61.145
(a)(4)(iv). Section 61.145 (a)(4)(iv) specifies that for an emergency renovation to be subject
to the notification and control provisions of the NESHAP, the combined amount of regulated
asbestos-containing material (RACM) that is to be stripped or removed as a result of the
emergency, must equal or exceed 260 linear feet of asbestos on pipes or 160 square feet on
other facility components, or 35 cubic feet if the asbestos material is already off the facility
component and the length or area could not be determined previously.
Notifications for emergency renovation operations that are subject to the NESHAP must
be given as early as possible before the renovation begins, but no later than the next working
day following the day the emergency renovation begins (61.145 (bX3)(iii)). As for all
notices, they must be in writing and may be delivered by U.S. Postal Service, commercial
delivery service, or hand delivery. The NESHAP does not permit notification by telephone or
telephone facsimile (fax) machines. The information contained in the notice for an
emergency renovation is the same as that required for all notices, except that the following
additional information is also required:
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The date and the hour that the emergency occurred,
A description of the sudden, unexpected event, and
An explanation of how the event caused an unsafe condition, or would cause
equipment damage or an unreasonable financial burden (61.145 (b)(4)(xv)).
Emergency renovation operations are subject to the emission control procedures of
section 61.145 (c). These procedures include removal of asbestos from the facility before any
activity that would disturb or break up the asbestos, wetting the asbestos during stripping,
keeping the asbestos that has been removed or stripped wet until collected or contained for
disposal, and having an individual on-site who is trained in the provisions of the NESHAP.
There are no exemptions from emission control procedures for emergency renovation
operations.
2. Government-Ordered Demolitions
The NESHAP exempts certain types of demolitions from some of the
notification and emission control requirements. The applicability provisions in section 61.145
(a)(3) state that a facility that is being demolished as a result of a government order that is
issued because the facility is structurally unsound and in danger of imminent collapse, is
exempt from the following:
Notification requirement to provide 10 working days advance notice. Notice for
such demolitions must be provided as early as possible before demolition and not
later than the following working day.
Notification requirement to include the scheduled starting and completion dates of
asbestos removal.
All other notification requirements apply. In addition, the notice for government-ordered
demolitions must include the name, title, and authority of the State or local government
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representative who ordered the demolition, die date the order was issued, and the date on
which the demolition is ordered to begin.
As specified in the applicability provisions of 61.145 (a)(3), government-ordered
demolitions are exempt from all but the following emission control procedures:
The requirement to strip or place in leak-tight wrapping all asbestos covered or
coated facility components that were removed in sections or units (61.145 (c)(4)).
The requirements for large facility components to be removed where the asbestos
will not be disturbed (61.145 (c)(5)).
The requirements for RACM that has been stripped or removed (61.145 (c)(6)).
The requirements during periods of freezing temperatures (61.145 (c)(7)).
The requirement for a person trained in the provisions of the NESHAP to be on site
(61.145 (c)(8)).
The requirement that all government-ordered demolitions adequately wet the portion
of the facility that contains RACM during the wrecking operation (61.145 (c)(9)).
C. Waste Disposal (61.150)
For facilities that have been demolished in response to government orders, Section
61.150 (a)(3) requires that the resulting asbestos-containing waste be adequately wetted at all
times after demolition and kept wet during the handling and loading for transport to a
disposal site. Such waste may be transported and disposed of in bulk. All the rest of the
waste disposal provisions in section 61.150 apply, including the requirements to dispose of
the waste as soon as practical at an appropriate site, to properly mark vehicles used to
transport the waste, to maintain waste shipment records, to provide a copy of the waste
shipment record to the disposal site, and to report any waste for which a copy of the waste
shipment record signed by the disposal site owner or operator is not received from the
disposal site within the prescribed amount of time.
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D. Active Waste Disposal Sites (61.154)
There are no special provisions or exemptions from the NESHAP for any
asbestos-containing waste material that is subject to the asbestos NESHAP.
Asbestos-containing waste from emergency renovations, government-ordered demolitions, or
from any source covered by the NESHAP must be disposed of in compliance with all the
provisions of 61.154.
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V. PRE-EMERGENCY PLANNING
In advance of a catastrophic emergency, Regional, state and local NESHAP coordinators
should take certain steps to ensure that potential asbestos hazards can be adequately managed
and asbestos exposures minimized. The following sections identify activities that, if
performed prior to an emergency, should help to ensure an adequate response in the event of
a catastrophic emergency.
A. Emergency Response Organization
Each Regional office should prepare a flow chart for their Region (similar to
Figure 1) with the names and telephone numbers of contact persons and backups. Copies of
the completed flow chart should be provided to neighboring Regions.
An organizational flow chart showing in parallel the levels of government engaged in
enforcing the asbestos NESHAP and responding to catastrophic emergencies is given in
Figure 1. Normal channels for the flow of information, requests for assistance, etc. are shown
as solid lines connecting the government agencies, while channels that need to be established
in order to plan for and respond to asbestos encountered in forced demolitions resulting from
emergencies are shown as dashed lines. Example emergency telephone lists for Regional,
state, and local asbestos NESHAP coordinators are presented in Figures 2, 3, and 4. The lists
are presented for illustrative purposes only; they are not intended to be comprehensive. The
telephone lists needed by a NESHAP coordinator will depend on several factors including, for
example, the extent to which NESHAP authority has been delegated.
B. Coordination With Local Emergency and Related Organizations
The responsible NESHAP coordinators should establish contact with responsible
emergency agencies and inform them of the NESHAP requirements.
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EPA
Regional Administrator
Other EPA Regions
Asbestos NESHAP
Coordinators
Press Officer
Division Director
Section Chief
Asbestos NESHAP
Coordinator
Delegated
State
Air Pollution Control
Agency
State
Emergency Management
Agency
Delegated
Local
Air Pollution Control
Agency
Local
Emergency Management
Agency
1
Buildings
Department
Fire
Department
Figure 1. Emergency response structure.
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Contact Telephone number
Other EPA Regional asbestos NESHAP
coordinators
State asbestos NESHAP coordinators
Figure 2. Example emergency telephone list for
Regional .asbestos NESHAP coordinator.
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Contact Telephone number
Regional asbestos NESHAP
coordinator
Asbestos NESHAP
coordinators of adjacent
states
Local asbestos NESHAP
coordinators
Local air pollution control
agencies
State emergency management
agency
Landfill operators
Laboratories
Emergency response
organizations
Figure 3. Example emergency telephone list for
state asbestos NESHAP coordinator.
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Contact Telephone number
State asbestos NESHAP
coordinator
Other local asbestos NESHAP
coordinators
Local emergency management
agency
Building department
Fire department
Landfill operators
Laboratories
Emergency response organization
Figure 4. Example emergency telephone list for
local asbestos NESHAP coordinator.
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1. The Problem
In the aftermath of catastrophic events that result in significant structural
damage to buildings, fire and buildings departments personnel typically are called upon to
identify those structures that are in imminent danger of collapse. Recent experience with
Hurricane Hugo and the San Francisco earthquake indicates that these personnel are often not
conscious of the presence of asbestos and the hazard it represents. Nor are they aware that
the NESHAP prescribes minimum work practices that must be followed even in an ordered
demolition resulting from a catastrophic emergency. The first part of the problem then is one
of a lack of awareness of the applicable asbestos regulations on the parts of some local
government personnel. It can be remedied by a conscious effort to inform them of the
NESHAP. The second part of the problem is that local emergency personnel, even if they are
aware of asbestos and the NESHAP, may not be qualified to determine whether asbestos is
present in a structure. Accordingly, an asbestos NESHAP inspector needs to be on the scene.
2. Strategy
As a courtesy, Regional asbestos NESHAP coordinators should contact the
FEMA Regional Directors to explain EPA's interest in asbestos, the NESHAP requirements
applicable to catastrophes, and EPA's plan to inform state and local emergency preparedness
agencies of the NESHAP requirements. Copies of the regulation and A Guide to the
Asbestos NESHAP. As Revised November 1990 with the relevant portions highlighted should
be made available to FEMA. Names, addresses, and telephone numbers of FEMA Regional
Directors are given in Appendix B.
Then the Regional asbestos NESHAP coordinators should recommend that the state air
pollution control agencies in their regions contact their counterpart state emergency
preparedness agencies to inform them of the NESHAP requirements. Again, copies of the
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regulation and Guide should be provided. The state emergency preparedness agency should
be asked to inform local emergency preparedness agencies that they will be contacted by their
local air pollution control agency, as appropriate. The state air pollution control agency
should then contact local air pollution control agencies and recommend that they contact the
appropriate local emergency preparedness agencies. Names, addresses, and telephone
numbers of state officials responsible for disaster operations are given in Appendix C.
By working through the local emergency preparedness agency, the local air pollution
control agency can reach fire and building department personnel and share the message with
them. The asbestos NESHAP coordinator should discuss with heads of fire and building
departments their procedures for identifying buildings that need to be demolished and develop
procedures whereby the NESHAP agency can be kept apprised of the location of buildings
that are ordered demolished during emergency situations.
Many state and local emergency preparedness agencies utilize emergency operations
centers to coordinate emergency response and relief activities in times of disaster. These
operations centers frequently have communications systems designed to remain intact during
disasters when normal systems, such as telephone lines, may be inoperative. In their contacts
with state and local emergency preparedness agencies, NESHAP coordinators should discuss
the possibility of having access to these systems if their normal communication links are
disrupted in an emergency.
At the local level, plans can be prepared that provide for making asbestos NESHAP
inspectors available to assist in evaluating asbestos problems in buildings following disasters.
State and Regional NESHAP enforcement agencies should plan to respond by providing
additional inspectors if requested and public information services. A checklist is provided in
Appendix A summarizing suggested lines of communications along with other planning aids.
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C. Mapping Asbestos Locations
State and local NESHAP coordinators should, to the extent feasible, determine the
presence and location of asbestos-containing facilities before a catastrophic emergency occurs.
During an emergency, knowing which structures in the community contain asbestos and
which do not could save time, reduce the risk associated with entering unsafe structures, and
avoid the unnecessary cost of treating the building as though it contained asbestos when in
fact it did not. Even at the facility level, knowing what equipment, for example, is insulated
with asbestos could be useful in responding to an accident involving that equipment. Sources
of location information are discussed below and are separated into those for asbestos milling,
manufacturing, and fabricating; and demolition and renovation.
! Asbestos Milling. Manufacturing, and Fabricating
The most obvious source of information on the location of asbestos mills,
manufacturers, and fabricators is EPA's own compliance inspection records for these sources.
Where enforcement of the NESHAP has been delegated, the responsible state or local
government should have in its files the names and locations of these sources.
Additional information on asbestos sources may be available from agencies responsible
for enforcement of occupational safety and health regulations. OSHA enforcement agencies
will have information on many of the same sources covered by asbestos air pollution
regulations. Typically, however, OSHA rules cover a much wider range of sources than those
covered by the asbestos NESHAP. Many of these additional sources may not be of as great a
concern because they frequently include sources that handle small amounts of asbestos or
asbestos-containing products, such as automobile brake servicing shops and the field
fabrication of asbestos products for construction.
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Another source of information on asbestos milling, manufacturing, and fabricating
facilities is the Toxic Chemical Release Inventory System (TRIS), a computer system
designed by EPA to track the annual emission of toxic chemicals into the environment. TRIS
compiles toxic emissions information submitted by facilities, including asbestos processing
facilities, regulated under the Superfund Amendments and Reauthorization Act (SARA).
TRIS can be accessed by the name of the pollutant and provide a list of the names and
locations of sources in the data base. Facilities are required to report under TRIS if they
release above a certain amount of the toxic pollutant. If the estimated emissions fall below a
certain level, a facility is not required to submit information and will not be picked up by
TRIS. TRIS can be accessed by EPA employees and other Federal, state, and local
government officials on EPA's National Computer Center (NCC) in Research Triangle Park,
North Carolina. The user must have an NCC user ID and authorization to access the system.
To obtain a user ID, contact TRIS User Support at (202) 475-9419.
2. Asbestos in Facilities
Facility refers to any institutional, commercial, public, industrial, or residential
structure, installation, or building (excluding residential buildings having four or fewer
dwelling units). There are several potential sources of information that may be used to help
locate asbestos-containing structures within a community.
a. Surveys of Buildings for Asbestos
The results of an EPA survey of buildings for the presence of asbestos may
be helpful in identifying asbestos-containing facilities.1-2 In addition to estimating the number
of buildings that contained asbestos, the survey also looked at the presence of asbestos in
relation to various building characteristics, including height and age of the building. The
findings of the EPA survey represent the situation on a national basis. The presence of
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asbestos in buildings may vary from these national averages from one part of the country to
another for various reasons, such as climate and age of cities.
Overall, the survey found that 20 percent of all buildings contained asbestos-containing
friable material, either in the form of sprayed- or trowelled-on asbestos, asbestos ceiling tile,
asbestos pipe and boiler insulation, or a combination of two or all three types. Pipe and
boiler insulation was more common (found in 16 percent of the buildings) than sprayed- or
trowelled-on asbestos (found in 5 percent of the buildings). Asbestos ceiling tile was rarely
found. Pipe and boiler insulation was generally limited to machine rooms, while sprayed- or
trowelled-on material was usually found exposed to areas of public use rather than behind
drop ceilings or otherwise concealed.
Relative to the age of buildings, the study found that in buildings built prior to 1960,
most of the asbestos was found as boiler and pipe insulation; after 1960, most of the friable
asbestos was sprayed or trowelled onto ceilings and steel beams, a practice which continued
until 1973 when most sprayed-on uses of asbestos were banned by EPA. Decorative
sprayed-on asbestos was banned in 1978.
The study also found that taller buildings are more likely to have asbestos-containing
friable material. Of the 19 high-rise buildings (8 or more floors) surveyed, all contained
asbestos pipe and boiler wrap and 41 percent contained sprayed- or trowelled-on asbestos
material.
As stated above, the EPA survey results represent national averages of asbestos-
containing buildings. The results may be significantly different in different parts of the
country. For example, in a survey of buildings in New York City for the presence of
asbestos, the results varied significantly from the national averages presented in the EPA
study.3 Overall, 68 percent of buildings in New York City have some form of asbestos. The
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New York City survey showed that tall office buildings most frequently contained asbestos
and also contained the greatest amount of asbestos. Table 1 presents a summary of the
survey results regarding the percent of buildings with asbestos and the amount of asbestos per
building.
b. Schools
Information on asbestos in schools is available at the local level as well as
at the state level. Under AHERA, schools are required to inspect their facilities for the
presence of asbestos, document the location of the asbestos and keep mis information on site
as well as forward a copy to the responsible state agency. In some states, the state
department of education will retain copies of mis information, while in other states, the state
agency responsible for asbestos programs is the designated state agency responsible under
AHERA. Each school must also keep a copy of the inspection results in its files. The
Regional Asbestos Coordinators for each region can provide information on state contacts for
information on asbestos in schools. A list of the addresses and telephone numbers for the
Regional Asbestos Coordinators is given in Appendix D.
c. Local Building Permit Agencies
In most communities, a building permit is required prior to any new
construction. As part of the application for a building permit, the building plans are reviewed
by the permitting agency to determine that the structure is designed and will be constructed in
accordance with applicable building codes. Building plans usually specify that a particular
code or standard will be met which, for example, relates to a certain fire rating. The
specifications which accompany the building plans state what materials are to be used to meet
the code specified in the plans. If asbestos was recommended for a certain application in
order to meet the relevant codes, the specifications would contain that information. A copy
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Table 1. New York City Survey Results Percentage
of Buildings Containing Asbestos and Average
Amount of Asbestos Per Building
Percent of
Buildings
Average Amount of
Asbestos per
Building with
Building Category with Asbestos Asbestos (sq. ft.)
Tall office buildings
Educational structures
Hotels
Walk-up apartments
Hospitals
Elevator apartments
Churches
One and two family
Outdoor recreation
Short office buildings
Stores
Factories
Theaters
Govt . /transportation
War ehous e s / 1 o f t s
Garages /gas stations
Source: City of New York Dep;
84
83
78
74
72
72
71
8
64
64
62
61
57
43
40
17
artment
64,341
3,233
3,802
457
6,929
4,832
919
167
969
2,109
363
1,759
4,438
8,282
2,393
419
of Environmental
Protection. Final Report. Assessment of the Public's
Risk of Exposure to In-Place Asbestos. New York, New
York. December 1, 1988.
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of approved building plans is usually kept by building permit agencies. Where a copy of the
specifications is also kept by the permitting agency, it could be used to help identify buildings
that contain asbestos.
d. Notifications
A number of large industrial facilities, such as petroleum refineries and
chemical plants, contain large amounts of asbestos in the form of thermal insulation. Many
of these facilities remove asbestos as part of nonscheduled renovation operations in addition
to scheduled renovations and demolitions. Nonscheduled renovations are typically
maintenance-related or repair-related renovations for which the exact date of occurrence
cannot be predicted, but based on previous experience, are likely to occur. Because the dates
of these renovations cannot be predicted, facilities where these operations occur often submit
annual, semiannual, or quarterly notices to EPA or its delegated authority describing how
these nonscheduled renovations will be handled to control asbestos emissions. Notices of
nonscheduled renovations and scheduled renovations and demolitions received from large
industrial facilities identify where asbestos is to be found and in what amounts.
D. Cleanup and Disposal
The responsible NESHAP coordinator should identify critical activities and
resources and develop contingency plans for augmenting or replacing them in an emergency.
Operations to clean up and dispose of asbestos during emergencies may be hampered by
unusual conditions resulting from the disaster. Often during disaster-related emergencies, the
normal provider/supplier relationships are disrupted so that business as usual is difficult, if not
impossible. Identified below are some circumstances that could complicate cleanup and
disposal operations and some suggested approaches to planning for such contingencies. The
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list of considerations is not intended to be complete since any number of complications could
arise.
1. Water Supply
Water supplies may be disrupted during disasters making it difficult to wet
asbestos during the demolition or abatement of asbestos-containing structures. This is likely
to be more of a problem where relatively large quantities of water are needed, for example,
when a building is being demolished upon a government order and the asbestos cannot be
removed prior to demolition. Large quantities of water will be needed to keep the debris wet
during demolition and during the loading for transport to a disposal site. However, during an
emergency, adequate water may not be readily available. If possible, such demolitions should
be delayed until the water supply can be restored or until an alternate supply can be obtained.
2. Chemical Contamination
Where accidents or emergencies involve industrial facilities, there is the
possibility that any asbestos that is involved may be contaminated with process chemicals. In
some instances, the chemicals may be hazardous. Where asbestos is contaminated with toxic
chemicals, other regulations may also apply to their handling and disposal. For hazardous
chemicals regulated under RCRA, for example, the disposal site requirements are more
stringent than those for asbestos. In some instances, it may not be advisable to apply water to
the contaminated asbestos waste. Usually the emergency response teams that deal with
accidents involving hazardous chemicals will know the best procedures for handling those
chemicals. Coordination with emergency response teams in these situations should help
ensure that the hazards associated with asbestos are adequately addressed.
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3. Waste Disposal
Where a large number of asbestos-contaminated facilities are damaged and need
to be demolished without prior removal of the asbestos, a large amount of
asbestos-contaminated waste will be generated. The existing capacity of the landfills that are
available to accept asbestos waste may be inadequate. Another problem may arise if the
landfill is not accessible as a result of the disaster. Under these conditions, alternative
disposal sites would be needed. In some cases, it may be possible to arrange with another
local landfill to accept the waste, or it may be necessary to transport the waste to more distant
sites. Alternative sites should be identified in advance, if possible. To the extent possible,
uncontaminated demolition waste should be segregated from the asbestos-contaminated debris
to reduce the volume that has to be disposed of in accordance with the NESHAP. NESHAP
coordinators should establish emergency contacts for landfills and agree on emergency
procedures in advance for accepting and handling asbestos-containing waste.
4. Backup Personnel
It may be necessary to have additional enforcement personnel available to
oversee asbestos cleanup and disposal operations, since decisions may have to be made at the
same time at numerous locations regarding appropriate actions to take. Cleanup operations
that go on around the clock may require inspections after normal working hours to make sure
work is being done properly. Additional NESHAP inspectors may be available from other
NESHAP delegated local agencies, the state, the Region, or from other states.
5. Laboratory Capabilities
Large numbers of bulk samples may require quick analysis before NESHAP
enforcement personnel can make decisions on appropriate actions to take. Arrangements
should be made for additional laboratory support to handle a potentially large number of
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samples. In addition, consideration should be given to arranging for overnight analysis of
bulk samples. This would allow for the results from the analysis of samples collected one
day to be available to enforcement personnel at the beginning of the next day.
6. Emergency Exemptions
Although the NESHAP contains provisions for emergency renovations and
ordered demolitions, the nature of the emergency may require some flexibility in enforcing
the NESHAP. For example, the NESHAP requires a written notice beforehand, but in no
case later than the following working day, for ordered demolitions. It is conceivable that,
under catastrophic emergency conditions, normal mail delivery services and transportation
systems would be so disrupted as to make it impossible to deliver a written notice in the time
period specified by the NESHAP. The responsible NESHAP coordinator should be aware
that situations may arise that make strict application of the NESHAP difficult, if not
impossible. While it is not possible to know in advance all the scenarios that may require
v
flexibility in applying the NESHAP, it would be advisable to discuss predictable problems
with agency management as well as with other NESHAP enforcement agencies at the
appropriate Regional, state, or local level.
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VI. EMERGENCY PERIOD
When a catastrophic emergency occurs, the responsible NESHAP coordinator should
implement those plans developed prior to the emergency. Listed below are some of the more
significant actions to be taken. Specific actions to be taken will, of course, depend on the
nature of the emergency.
Contact those agencies listed in the emergency response structure (see Figure 1).
Assess the need to issue press release(s).
Through contact with building and fire departments, determine magnitude of the
problem, Le., number of damaged structures.
Activate previously established procedures with fire and building departments to be
kept informed of buildings that are ordered to be demolished.
Assess need for additional resources, e.g., inspectors, laboratory capabilities, etc. and
take steps, as necessary, to augment existing resources.
Provide guidance to delegated agencies, as appropriate.
Assess need to allow selected exemptions to the NESHAP requirements.
Make periodic contacts with agencies listed in the emergency response structure, as
needed.
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vn. CONCLUSIONS
Efforts to restore the damaged areas to their predisaster condition often involve removing
or repairing damaged structures. There may be a natural tendency at this stage to overlook
certain hazards, such as asbestos, that are not immediately life threatening. However, such
hazards are serious and may manifest themselves many years from the time of exposure and
should be taken into consideration. Given the health hazards associated with asbestos
exposure, it is reasonable that adequate measures be taken during emergency situations to
minimize exposure to asbestos from the demolition or renovation of buildings. The
applicability of the asbestos NESHAP is not altered as the result of a disaster. With a few
exceptions for emergency renovations and government-ordered demolitions, all of the
NESHAP requirements are applicable in emergency situations.
One of the key factors in effectively dealing with asbestos in emergency situations is
communications. Communications are needed between the asbestos NESHAP coordinator and
the other emergency response agencies and related agencies. The first step is for the
Regional asbestos NESHAP coordinator to discuss this matter with Regional FEMA personnel
and assure them of EPA's desire to cooperate with FEMA and other emergency response
agencies. The next step is for the Regional EPA offices to inform their respective state
NESHAP enforcement agencies of the need to coordinate efforts. The delegated state
NESHAP agency should then contact the state emergency preparedness office to discuss the
need to consider asbestos in emergency situations. Finally, the same communications should
occur at the local level.
This guidance document is intended to assist asbestos NESHAP coordinators in dealing
with asbestos during catastrophic emergency situations. It provides suggestions for
coordinating with other local and state emergency-related agencies, information on applicable
30
-------
statutes and regulations, possible sources of information to help locate asbestos in a
community, and special considerations relevant to clean up and disposal. This document will
be most useful for advanced planning for emergency situations, although it will still find use
when a disaster strikes.
31
-------
1. U.S. Environmental Protection Agency. Asbestos in Buildings: A National Survey of
Asbestos-Containing Friable Materials. EPA 560/5-84-006. Washington, DC. June
1984. 260 p.
2. U.S. Environmental Protection Agency. Additional Analysis of EPA's 1984 Asbestos
Survey Data. EPA 560/5-88-010. Washington, DC. September 1988. 87 p.
3. New York City Department of Environmental Protection. Assessment of the Public's
Risk of Exposure to In-place Asbestos. New York, NY. December 1, 1988.
32
-------
APPENDIX A
ASBESTOS NESHAP CHECKLIST FOR
CATASTROPHIC EMERGENCY SITUATIONS
33
-------
Appendix A
ASBESTOS NESHAP CHECKLIST FOR
CATASTROPHIC EMERGENCY SITUATIONS
1. Regional Coordination Activities
Regional FEMA
Other regional NESHAP coordinators
Delegated state NESHAP agencies
2. State Coordination Activities
State emergency preparedness agencies
Delegated local NESHAP agencies
3. Local Coordination Activities
Local emergency preparedness agencies
Local building departments
Local fire departments
4. Link with Emergency Communication System
5. Emergency Telephone List
6. Alternate Water Supplies
7- Coordination with Emergency Response Agency for Hazardous Chemical Contamination
8. Alternate Waste Disposal Sites
9. Additional Asbestos Inspectors
10. Laboratory Support
11. Press Releases
34
-------
APPENDIX B
FEMA REGIONAL DIRECTORS
35
-------
Appendix B
FEMA REGIONAL DIRECTORS
Region I
Mr. Richard H. Strome
Regional Director
Federal Emergency Management Agency
J.W. McCormack, Post Office and
Court House, Room 442
Boston, Massachusetts 02109
FTS: 223-9540; Commercial: (617) 223-9540; FAX: 223-9519
Region n
Mr. Phillip Mclntire
Regional Director (Acting)
Federal Emergency Management Agency
26 Federal Plaza, Room 1338
New York, New York 10278
FTS: 649-8208; Commercial: (212) 238-8202; FAX: 238-8245
Region in
Mr. Paul Giordano
Regional Director
Federal Emergency Management Agency
Liberty Square Building (Second Floor)
105 S. Seventh Street
Philadelphia, Pennsylvania 19106
FTS: 489-5608; Commercial: (215) 931-5608; FAX: 489-5513
Region IV
Mr. Major P. May
Regional Director
Federal Emergency Management Agency
1371 Peachtree Street, N.E., Suite 700
Atlanta, Georgia 30309
FTS: 230^200; Commercial: (404) 853-4200; FAX: 230-4230
36
-------
Region V
Mr. Ariyn F. Brower
Regional Director
Federal Emergency Management Agency
175 W. Jackson Boulevard (Fourth Floor)
Chicago, Illinois 60604
FTS: 363-5501; Commercial: (312) 408-5501; FAX: 363-5521
Region VI
Mr. Bradley M. Harris
Regional Director
Federal Emergency Management Agency
Federal Regional Center
800 N. Loop 288, Room 206
Demon, Texas 76201-3698
FTS: 749-9104; Commercial: (817) 898-9104; FAX: 749-9290
Region VH
Mr. S. Richard Mellinger
Regional Director
Federal Emergency Management Agency
Old Federal Office Building
911 Walnut Street, Rom 200
Kansas City, Missouri 64106
FTS: 759-7061; Commercial: (816) 283-7061; FAX: 759-7504
Region Vin
Dr. Marian L. Olson
Regional Director
Federal Emergency Management Agency
Denver Federal Center, Building 710
Box 25267
Denver, Colorado 80225-0267
FTS: 322^812; Commercial: (303) 235-4815; FAX: 322-4976
37
-------
Region DC
Mr. William M. Medigovich
Regional Director
Federal Emergency Management Agency
Building 105
Presidio of San Francisco
San Francisco, California 94129
FTS: 469-7100; Commercial: (415) 923-7100; FAX: 469-7157
Region X
Mr. Raymond C. Williams
Regional Director (Acting)
Federal Emergency Management Agency
Federal Regional Center
130 228th Street, S.W.
Bothell, Washington 98021-9796
FTS: 390-4604; Commercial: (206)487-4604: FAX: 390-4707
Source: Directory of Governors, State Officials and Adjutants General Responsible for
Disaster Operations and Emergency Planning, FEMA-9. Washington, D.C.: Federal
Emergency Management Agency, July 1990.
38
-------
APPENDIX C
STATE OFFICIAL RESPONSIBLE FOR
DISASTER OPERATIONS
39
-------
Appendix C
STATE OFFICIAL RESPONSIBLE
FOR DISASTER OPERATIONS
STATE STATE EMERGENCY DIRECTOR
ALABAMA Mr. William O. Brock
Director, Alabama Emergency
Management Agency
520 South Court Street
Montgomery, Alabama 36130
(205) 834-1375
ALASKA Mr. Ervin P. Martin
Director, Division of Emergency
Services, Dept. of Military
and Veterans Affairs
3501 E. Bogard Road
Wasilla, Alaska 99687-2689
(907) 376-2337
AMERICAN
SAMOA
Mr. Maiava (Oliver) F. Hunkin
Disaster Program Coordinator
Department of Public Safety
American Samoa Government
P.O. Box 1086
Fagatogo, American Samoa 96799
011-684-633-2331
ARIZONA Mr. William D. Lockwood
Director, Arizona Division of
Emergency Services
National Guard Building
5636 East McDowell Road
Phoenix, Arizona 85008
(602) 244-0504
RESPONSIBLE SENIOR
OFFICIAL
same
Maj. Gen. John W.Schaeffer
The Adjutant General
Dept of Military
Veterans Affairs
1800 E. Dimond Boulevard
Suite 3-450
Anchorage, Alaska
99515-2097
(907) 249-1565
Mr. Tuilefano M. Vaela's
Acting Commissioner of
Public Safety, Depart-
ment of Public Safety
American Samoa Government
P.O. Box 1086
Fagatogo, American Samoa
96799
011-684-633-1111
Maj. Gen. Donald L. Owens
The Adjutant General
National Guard Building
5636 East McDowell Road
Phoenix, Arizona 85008
(602) 273-9710
40
-------
ARKANSAS
CALIFORNIA
COLORADO
Mr. James Lee Witt
Director, Office of Emergency
Services
P.O. Box 758
Conway, Arkansas 72032
(501) 329-5601, Ext. 201
(501) 374-1201 (Little Rock)
Mr. Donald R. Irwin
Director, Office of Emergency
Services, State of California
2800 Meadowview Road
Sacramento, California
95832-1499
(916) 427-4201
Mr. Richard E. Hatten
Director, Disaster Emergency
Services
EOC, Camp George West
Golden, Colorado 80401
(303) 273-1624
Same
CONNECTICUT Mr. Frank Mancusco
State Director, Office of
Emergency Management
360 Broad Street
Hartford, Connecticut 06105
(203) 566-3180/4338
FAX (203) 247-0664
DELAWARE
Mr. James W. Hoffman
Director, Division of Emergency
Planning and Operations
P.O. Box 527
Delaware City, Delaware 19706
(302) 834-4531
Same
Mr. David J. Thomas
Executive Director
Colorado Department of
Public Safety
700 Kipling Street
Suite 3000
Lakewood, Colorado
80215-5865
(303) 239-4398
Same
Mr. Patrick W. Murray
Secretary of Public Safety
Department of Public Safety
Highway Administration
Building
Dover, Delaware 19901
(302) 736-4321
41
-------
DISTRICT
OF
COLUMBIA
FLORIDA
GEORGIA
GUAM
HAWAE
Mr. Joseph P. Yeldell
Director, Office of Emergency
Preparedness
2000 14th Street, NW, Eighth FL.
Washington, DC 20009
(202) 727-6161
Mr. Gordon L. Guthrie
Director, Division of Emergency
Management
2740 Centerview Drive
Tallahassee, Florida 32399
(904) 487-4918
Mr. Billy J. Clack
Executive Director, Georgia
Emergency Management Agency
P.O. Box 18055
Atlanta, Georgia 30316-0055
(404) 624-7000
Mr. Jose T. Terlaje
Director, Civil Defense/Guam
Emergency Services Office
Territory of Guam
P.O. Box 2877
Agana, Guam 96910
011-671-477-9841
Mr. Roy C. Price, Sr.
Vice Director of Civil Defense
Department of Defense
3949 Diamond Head Road
Honolulu, Hawaii 96816
(808) 734-2161
Same
Mr. Tom Pelham
Secretary, Department of
Community Affairs
2740 Crestview Drive
Tallahassee, Florida 32399
(904) 488-8466
*Maj. Gen. Joseph W. Griffin
The Adjutant General and
Director, Georgia Emergency
Management Agency
P.O. Box 18055
Atlanta, Georgia 30316-0055
(404) 624-6000
Same
*Maj. Gen. Alexis T. Lum
The Adjutant General of the
National Guard and Director
of Civil Defense
Department of Defense
3949 Diamond Head Road
Honolulu, Hawaii 96816
(808) 734-2195
42
-------
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
Mr. Dairell G. Waller
Coordinator, Bureau of
Disaster Services
Military Division
650 West State Street
Boise, Idaho 83720
(208) 334-3460
Mr. John Plunk, Acting Director
Illinois Emergency Services
and Disaster Agency
110 East Adams Street
Springfield, Illinois 62706
(217) 782-6818 - FTS 372-7851
Mr. Jerome Hauer, Director
Indiana State Emergency
Management Agency
State Office Building, Room 315
100 North Senate Avenue
Indianapolis, Indiana 46204
(317) 232-3830 - FTS 372-7852
Ms. Ellen Gordon
Administrator, Disaster Services
Division
Hoover State Office Bldg.
Level A, Room 29
Des Moines, Iowa 50319
(515) 272-5211
Vacant
Deputy Director, Division
of Emergency Preparedness
P.O. Box C-300
Topeka, Kansas 66601
(913) 233-9253 X 301
Maj. Gen. Darrell V.
Manning
The Adjutant General
Military Division
P.O. Box 45
Boise, Idaho 83707
(208) 385-5242
Same
Same
Maj. Gen. Warren G. Lawson
The Adjutant General and
Executive Director
Department of Public
Defense
Camp Dodge
7700 N.W. Beaver Drive
Johnston, Iowa 50131-1902
(515) 278-9211
Maj. Gen. Phillip B. Finley
The Adjutant General and
Director, Division of
Emergency Services
P.O. Box C-300
Topeka, Kansas 66601
(913) 233-7560 X 101
43
-------
KENTUCKY
LOUISIANA
MAINE
MARSHALL
ISLAND
Mr. James H. "Mike" Molloy
Executive Director, Kentucky
Disaster and Emergency Services
Boone Center, Parkside Drive
Frankfort, Kentucky 40601
(502) 564-8680
Mr. Robert Warren, Director
Office of Emergency Preparedness
Department of Public Safety
P.O. Box 66536, Audubon Station
Baton Rouge, Louisiana 70896
(504) 342-5470
Mr. David D. Brown
Director, Maine Emergency
Management Agency
State Office Bldg., Station 72
Augusta, Maine 04333
(207) 289-4080
FTS: 289-4080
Mr. PhilKabua
Disaster Control Officer,
Republic of the Marshall
Islands
Majuro, Marshall Islands 96960
93-011-692-9-3234
Brig. Gen. Michael W.
Davidson
The Adjutant General and
State Director of Disaster
and Emergency Services
Boone National Guard Center
Frankfort, Kentucky 40601
Attn: James H. Molloy
(502) 564-8558
Col. (Ret.) Marlin A.
Flores
Deputy Secretary
Department of Public Safety
P.O. Box 66614
Baton Rouge, Louisiana
70896
(504)925-6117
Gen. Ernest Park
The Adjutant General and
Commissioner, Department
of Defense and Veterans
Services
Maine National Guard
Camp Keyes
Augusta, Maine 04333
(207) 626-4225
Mr. Phil Kabua
Republic of the Marshall
Islands
Majuro, Marshall Islands
96960
44
-------
MARYLAND Mr. David A. McMfflion
Director, Maryland Emergency
Management Agency
Two Sudbrook Lane, East
Pikesvffle, Maryland 21208
(301) 486-4422
FTS 486-4422
MASSACHUSETTS
Mr. Robert J. Boulay
Director, Massachusetts Civil
Defense Agency and Office of
Emergency Preparedness
400 Worcester Road
Framingham, Massachusetts
01701
MICHIGAN
MICRONESIA
(508) 820-2000
Dave Chamey
State Director
Emergency Management Division
Michigan State Police
300 S. Washington Square,
Suite 300
Lansing, Michigan 48913
(517) 373-6271 - FTS 372-7853
Mr. Ehson D. Johnson
Director, Disaster Control
Officer
The Federated States
of Micronesia 96941
(011)691-9228
Brig. Gen. John Barshay
Maryland Military
Department
National Guard
5th Regiment Armory
29th Division Street
Baltimore, Maryland 21201
(301) 764-4004
Mr. Charles V. Barry
Secretary, Department of
Public Safety
One Ashburton Place,
Room 2133
Boston, Massachusetts
02108
(617) 727-7775
Col. R. T. Davis
Acting Director, Department
of State Police and State
Division of Emergency
Services
714 S. Harrison Road
East Lansing, Michigan
48823
(517) 337-6157
Same
45
-------
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
Mr. Thomas Motherway
Director, Division of Emergency
Services
Department of Public Safety
State Capitol, B-5
St. Paul, Minnesota 55155
(612) 296-2233 - FTS 372-7854
Mr. James E. Maher
Director, Emergency Management
Agency
P.O. Box 4501, Fondren Station
Jackson, Mississippi 39216
(601) 352-9100
Mr. Richard D. Ross
Director, State Emergency
Management Agency
P.O. Box 116
Jefferson City, Missouri
6S102
(314) 751-9571
Mr. F. Guy Youngblood
Administrator, Disaster
and Emergency Services
Division
Department of Military Affairs
P.O. Box 4789
Helena, Montana 59604-4789
(406) 444-6911
Mr. Richard L. Semm
Assistant Director, Nebraska
Civil Defense Agency
National Guard Center
1300 Military Road
Lincoln, Nebraska 68508
(402) 473-1410
Mr. Paul Tschida
Commissioner, Department
of Public Safety
211 Transportation Bldg.
St. Paul, Minnesota 55155
(612) 296-6642
Same
Maj. Gen. Charles Kiefner
The Adjutant General
1717 Industrial Drive
Jefferson City, Missouri
65101
(314) 751-9710
Maj. Gen. James W. Duffy
The Adjutant General
Department of Military
Affairs
P.O. Box 4789
Helena, Montana 59604
(406) 444-6910
Maj. Gen. Stanley M. Heng
The Adjutant General and
Director, Nebraska Civil
Defense Agency
National Guard Center
1300 Military Road
Lincoln, Nebraska 68508
(402)473-1100
46
-------
NEVADA
NEW
HAMPSHIRE
NEW JERSEY
NEW MEXICO
Mr. Robert R. King
Director, Nevada Division
of Emergency Services
Military Department
2525 S. Carson Street,
Capitol Complex
Carson City, Nevada 89710
(702) 885-4240
Colonel George Iverson
Director, Governor's Office
of Emergency Management
State Office Park South
107 Pleasant Street
Concord, New Hampshire 03301
(603) 271-2231
FAX (603) 225-7341
Maj. Joseph J. Craparotta
Deputy State Director
Office of Emergency Management
New Jersey State Police
P.O. Box 7068
West Trenton, New Jersey 08628
(609) 882-2000
Mr. Thomas H. Johnson
Director, Technical and
Emergency Support Division
Department of Public Safety
4491 Cerrillos Road
P.O. Box 1628
Santa Fe, New Mexico 87504
(505) 827-3375
Maj. Gen. Robert Dwyer
The Adjutant General
Military Department
2525 S. Carson Street,
Capitol Complex
Carson City, Nevada 89710
(702) 887-7302
Same
Justin J. Dintino
Superintendent of State
Police
P.O. Box 7068
West Trenton, New Jersey
08628
(609) 882-2000
Col. Robert Kemble
Secretary, Office of the
Secretary
Department of Public Safety
4491 Cerrillos Road
P.O. Box 1628
Santa Fe, New Mexico 87504
(505) 827-3370
47
-------
NEW YORK
NORTH
CAROLINA
NORTH
DAKOTA
NORTHERN
MARIANA
ISLANDS
Mr. Donald A. DeVito
Director, State Emergency
Management Office
Division of Military and
Naval Affairs
Public Security Bldg.
State Campus
Albany, New York 12226-5000
(518) 457-2222
Mr. Joseph F. Myers
Director, North Carolina
Division of Emergency
Management
Administration Building
116 West Jones Street
Raleigh, North Carolina 27611
(919) 733-3867
Mr. Ronald D. Affeldt
Director, North Dakota Division
of Emergency Management
P.O. Box 5511
Bismarck, North Dakota
58502-5511
(701) 224-2111
Mr. Felix A. Sasamoto
Disaster Control Officer
Office of the Governor
Commonwealth of the Northern
Mariana Islands
Saipan, Mariana Islands 96950
011-670-322-9529/9572
Maj. Gen. Lawrence P. Flynn
Adjutant General, NYS
Division of Military and
Naval Affairs
330 Old Niskayuna Road
Latham, New York
12110-2224
(518) 786-4502
Mr. Joseph W. Dean
Secretary, Department of
Crime Control and
Public Safety
P.O. Box 27687
Raleigh, North Carolina
27611
(919) 733-2126
Maj. Gen. Alexander
MacDonald
The Adjutant General
P.O. Box 5511
Bismarck, North Dakota
58502-5511
(701) 224-5102
Same
48
-------
OHIO
OKLAHOMA
OREGON
Mr. Dale W. Shipley
Deputy Director, Ohio
Emergency Management
Agency
2825 West Granville Road
Columbus, Ohio 43235-2712
(614) 889-7155
FTS 372-7855
Mr. Woodrow Coins
Director, Oklahoma Civil
Defense Agency
P.O. Box 53365
Oklahoma City, Oklahoma 73152
(405) 521-2481
Ms. Myra T. Lee
Administrator, Emergency
Management Division
Executive Department
603 Chemeketa Street, NE
Salem, Oregon 97310
(503) 378-4124
PENNSYLVANIA
PUERTO
RICO
Mr. Joseph LaFleur
Director, Pennsylvania
Emergency Management Agency
Transportation and Safety
BuHding, B-151
Harrisburg, Pennsylvania 17120
(717) 783-8150
Mr. Heriberto Acevedo
Director, State Civil
Defense Agency .
P.O. Box 5127
San Juan, Puerto Rico 00906
(809) 724-0124
Adjutant General's
Department
Ohio Emergency Management
Agency
2825 West Granville Road
Columbus, Ohio 43235-2712
Ann: Dale W. Shipley
(614) 889-7150
Same
Mr. Fred Miller, Director
Executive Department
15 Cottage Street, NE
"Salem, Oregon 97310
(503) 378-3104
Lt. Gov. Mark S. Singel
Chairman, Pennsylvania
Emergency Management
Council
State Capitol
Harrisburg, Pennsylvania
17120
(717) 787-3300
Same
49
-------
RHODE
ISLAND
SOUTH
CAROLINA
SOUTH
DAKOTA
Mr. Edward A. Cotugno
Executive Director, Rhode Island
Emergency Management Agency
State House
Providence, Rhode Island 02903
(401) 421-7333
FAX (401) 751-0827
Mr. Paul Lunsford
Director, Emergency Preparedness
Division
1429 Senate Street
Columbia, South Carolina 29201
(803) 734-8020
Mr. Gray N. Whitney
Director, Division of Emergency
and Disaster Services
Department of Military Affairs
EOC-State Capitol
Pierre, South Dakota
57501-5060
(605) 773-3231
Mr. Lacy E. Suiter
Director, Tennessee Emergency
Management Agency
3041 Sidco Drive
Nashville, Tennessee 37204
(615) 252-3300
Maj. Gen. Andre Trudeau
The Adjutant General and
Director, Rhode Island
Emergency Management
Agency
Armory of Mounted Commands
1051 North Main Street
Providence, Rhode Island
02904
(401) 277-2100
Maj. Gen. T. Eston Marchant
The Adjutant General
Rembert C. Dennis Building
1000 Assembly Street
Columbia, South Carolina
29201
(803) 748-4200
Maj. Gen. Harold J. Sykora
The Adjutant General
State Director of Civil
Defense
State Capitol
Pierre, South Dakota
57501-5060
(605) 773-5340
Maj. Gen. Carl Wallace
The Adjutant General
3041 Sidco Drive
Nashville, Tennessee 37204
(615) 252-3001
50
-------
TEXAS
TRUST
TERRITORY
OF THE
PACIFIC
UTAH
VERMONT
Mr. Robert A. Lansford
State Coordinator, Division of
Emergency Management
Texas Department of Public
Safety
Box 4087, N. Austin Station
Austin, Texas 78773
(512) 465-2000 x 2138
Mr. Charles Jordan
Chief, Office of Planning
and Statistics
Office of the High Commissioner
Trust Territory Headquarters
Saipan, Mariana Islands 96950
011-670-322-9333
Mrs. Lorayne Frank
Director, Division of
Comprehensive Emergency
Management
Department of Public Safety
1543 Sunnyside Avenue
Salt Lake City, Utah 84105-0136
(801) 533-5271
Mr. George Lowe
Director, State of Vermont
Department of Public Safety
Division of Emergency Management
Waterbury State Complex
103 S. Main Street
Waterbury, Vermont 05676
(802) 244-8721
FAX (802) 244-8655
Mr. Joe E. Milner
Director, Texas Department of
Public Safety and Division
of Emergency Management
Box 4087, N. Austin Station
Austin, Texas 78773
(512) 465-2000 x 370
Same
Mr. D. Douglas Bodiero
Commissioner, Department
of Public Safety
4501 South 2700 West
Salt Lake City, Utah 84119
(801) 965-4463
Mr. Charles E. Bristow
Commissioner, Department of
Public Safety
103 S. Main Street
Waterbury, Vermont 05676
(802) 244-8718
51
-------
VIRGINIA Mr. Addison E. Slayton, Jr.
State Coordinator
Office of Emergency Services
310 Turner Road
Richmond, Virginia 23225
(804) 674-2497
VIRGIN Mr. William S. Harvey
ISLANDS Director, Virgin Island
Territorial
VTTEMA
#3-4 King Street
Christiansted, US VI 00820
(809) 774-2244
WASHINGTON Ms. Kate Heimbach
Assistant Director,
Division of Emergency Management
Dept of Community Development
4220 East Martin Way, PT-11
Olympia, Washington 98504-8611
(206) 753-5255
WEST
VIRGINIA
WISCONSIN
Mr. Bill R. Joplin
Acting Director, West Virginia
Office of Emergency Services
State Capitol Complex, EB 80
Charleston, West Virginia 25305
(304) 348-5380
BG Richard I. Braund, USNG (Ret.)
Administrator, Division of
Emergency Government
Department of Administration
4802 Sheboygan Avenue, Rm. 99A
Madison, Wisconsin 53707
(606) 266-3232 - FTS 372-7856
Col. Robert Suthard
Secretary, Department of
Public Safety
Ninth Street Office Bldg.
Sixth Floor
Richmond, Virginia
23225-6491
(804) 786-5351
Maj. Gen. Charles Hood
The Adjutant General
Virgin Islands Territorial
Emergency Management Agency
Foreign Arrivals Bldg.
Alexander Hamilton Airport
St. Croix, US 00850
(809) 772-7443
Mr. Chuck Clarke
Director, Department of
Community Development
State of Washington
Ninth & Columbia Building,
MS/GH-51
Olympia, Washington
98504-4151
(206) 753-5625
Same
BG Jerald D. Slack
The Adjutant General
Wisconsin National Guard
3020 Wright Street
Madison, Wisconsin 53708
(608) 241-6312
52
-------
WYOMING Mr. Edwin S. Usui Maj. Gen. Charles Wing
Coordinator, Wyoming Disaster The Adjutant General
and Civil Defense Division P.O. Box 1709
P.O. Box 1709 Cheyenne, Wyoming 82003
Cheyenne, Wyoming 82003
(307) 772-6233
(307) 777-7566
Source: Directory of Governors, State Officials and Adjutants General Responsible for Disaster
Operations and Emergency Planning, FEMA-9. Washington, DC: Federal Emergency
Management Agency, July 1990.
53
-------
APPENDIX D
REGIONAL ASBESTOS COORDINATORS
54
-------
Appendix D
REGIONAL ASBESTOS COORDINATORS
Regional Asbestos Coordinator
US EPA, Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3835
Regional Asbestos Coordinator
US EPA, Region 2
Woodbridge Avenue
Edison, NJ 08837
(201) 321-6671
Regional Asbestos Coordinator
US EPA, Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-3160
Regional Asbestos Coordinator
US EPA, Region 4
345 Courtland Street
Atlanta, GA 30365
(404) 347-5014
Regional Asbestos Coordinator
US EPA, Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-6003
Regional Asbestos Coordinator
US EPA, Region 6
Allied Bank Tower
1445 Ross Avenue
Suite 1200
Dallas, TX 75720
(214) 655-7244
Regional Asbestos Coordinator
US EPA, Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7381
Regional Asbestos Coordinator
US EPA, Region 8
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1442
Regional Asbestos Coordinator
US EPA, Region 9
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5406
Regional Asbestos Coordinator
US EPA, Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-4762
«U.S. Governmen
J12-0l4/400i6
55
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ITEM 10
Asbestos Sampling Bulletin
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ASBESTOS SAMPLING BULLETIN
September 30, 1994
Supplementary Guidance on Bulk Sample Collection and Analysis
U.S. EPA, OPPT/CMD (7404)
I, Introduction
Recent Notices in the Federal Register (59 FR 542, Jan. 5, 1994; and (59 FR 38970, Aug. 1, 1994),
announced clarifications regarding the analysis of bulk samples obtained from multi-layered systems' to
determine the presence of asbestos. As part of a public outreach effort, the Environmental Protection Agency
(EPA) developed this supplemental guidance bulletin. The public should take note that the contents are
presented as guidance. This guidance does not change current regulatory requirements of the 1987
Asbestos in Schools Rule (AHERA). Local education agencies (LEAs) may choose to adopt the recommended
guidance as a matter of policy offering added precaution and protection for workers and building occupants, and
also to avoid the possibility of non-compliance with EPA's National Emission Standards for Hazardous Air
Pollutants (NESHAP) regulations.
This bulletin was developed by EPA primarily for two reasons:
1) to provide guidance regarding the adoption and use of an. improved method for the analysis of asbestos in
bulk samples ("Test Method - Method for the Determination of Asbestos in Bulk Building Materials,"
EPA/600/R-93/116, July 1993). The improved method is especially useful for detecting the presence of
asbestos in asbestos-containing floor tiles, but it also provides better analytical results in building materials that
may contain asbestos at low concentrations.
2) to clarify EPA's guidance and requirements for the collection and analysis of bulk samples of multi-layered
materials, particularly in schools. EPA recommends that multi-layered samples that have been found to be non-
asbestos-containing for the EPA "Asbestos in Schools Rule" (AHERA) be resamoled before disturbing them.
unless lab reports arc available documenting that all layers were previously sampled and analyzed. Resampling
(if elected) should be done according to the guidelines set forth previously in a January 5, 1994 NESHAP
Federal Register Notice, an Aug. 1, 1994 AHERA Federal Register Notice, and in the improved analytical
method to avoid potential violation of the asbestos NESHAP regulations.
Note that under the AHERA and NESHAP regulations, LEAs can assume that certain materials are
asbestos-containing and manage them as such. This continues to be an acceptable alternative to sampling or
resampling.
Both EPA's AHERA program for schools and the EPA asbestos NESHAP program recommend the
adoption of the improved bulk sample analysis method published by EPA's Office of Research and Development
in July 1993 (EPA/600/R-93/116). EPA developed the improved analytical method to address certain materials: '
- that are known to contain asbestos fibers, but in which the asbestos percentage is "low"
« 10%);
- where the presence of asbestos is obscured by a matrix binder of some kind (e.g., vinyl or
asphalt floor tiles);
- in which small, thin fibers are present, but are frequently not detected at the magnification
and resolution limits of polarizing light microscopes.
The improved method builds on the previous (1982) "Interim" polarizing light microscope (PLM)
method. As before, it begins with a careful examination of the sample using a stereo-microscope, then proceeds
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(as before) to the examination of sample specimens under a polarizing light microscope. In most cases, these
steps will be sufficient to characterize a sample as asbestos-containing (asbestos present > 1 %) or non-asbestos-
containing (no asbestos detected, or 1 % or less in the sample).
The improved method includes additional procedures required for the reliable analysis of certain bulk
building materials, such as steps for the elimination of the obscuring matrix materials (quantitative analysis of
the sample is improved by the use of comparative standard samples having known quantities of asbestos matrix
materials), as well as specifying use of transmission electron microscopy (TEM). These additional steps
comprise the chief improvements in the new method. The Agency believes that adoption of the improved
method should remedy the analytical problems frequently encountered when testing materials such as resilient
floor tile (vinyl or asphalt), mastic, and "layered" building materials using the 1982 "Interim" PLM method.
Finally, the results obtained from following recent guidance on "layered samples" and use of the
improved sampling procedures for certain problem materials should, where it is possible to do so, facilitate
following EPA's "manage in place" guidance for asbestos operations and maintenance (O&M) programs, (EPA
"Green Book," July 1990).
n. Issues of Concern
There are two principal issues addressed in this guidance.
Issue 1. The possible misidentification of certain "problem" materials as non-asbestos-containing,
with subsequent failure (o include them under a surveillance and O&M program. These "problem
materials" include asbestos-containing floor tiles, and certain multi-layered building materials.
The 1982 EPA "Interim Method for the Determination of Asbestos in Bulk Insulation Samples" (40
CFR 763, Appendix A to Subpart F) was limited in that it did not provide guidance for analyzing materials that
contain thin (i.e., <0.25 micrometer) asbestos fibers. As a consequence, floor tiles analyzed according to the
1982 method and for which negative results were reported may actually contain undetected asbestos in the form
of thin fibers below the limits of resolution of the polarized light microscope.
The improved method provides acceptable procedures for reducing matrix materials so that fibers may
be made available for microscopic analysis. It also addresses the thin fiber limitation of the 1982 method by
providing directions for the use of transmission electron microscopy (TEM) as needed.
The improved method also directs laboratories to analyze the individual layers or strata of a multi-
layered sample and to report a single result for each layer. The 1982 "Interim Method," in contrast, provided
that the analytical result for a multi-layered sample with discrete layers be reported as one result across all
layers. (Although the analyst was directed to identify the presence of discrete layers as seen under stereo-
microscopic examination of the bulk sample, and to identify and quantify asbestos fiber content in each layer.)
Because the 1982 method allowed the result to be reported as one number, multi-layered samples which may
have contained asbestos in a single layer may have been reported by laboratories as non-asbestos-containing.
Thus, under the recommended improved test method, more than one result will be reported for multi-
layered samples, and a multi-layered sample which previously was determined to be non-asbestos-containing
may actually have layers which will be classified as asbestos-containing based on the presence of asbestos in
greater than one percent. The January 5, 1994 NESHAP notice in the Federal Register directs the attention of
the regulated community to their requirement to analyze multi-layered samples in this manner for compliance
with NESHAP.
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The recognition, sampling, and analysis of 'layered" building materials may be of particular importance
when known or assumed asbestos-containing building materials (ACBM) are left in place. AHERA requires the
management of known or assumed ACBM under a school's asbestos operations and maintenance program. EPA
issued guidance in July, 1990 ("Managing Asbestos in Place," the "green book") that recommends similar
programs in any building or facility where asbestos-containing materials (ACM) are present.
For example, if a planned renovation or remodelling is scheduled, and if the outer surface (i.e., the
surface exposed to the room's interior) of a wall or ceiling system is an asbestos-containing layer, that fact
should be known prior to some disturbance such as sanding in preparation for painting. Similarly, if an
underlying layer of a wall or ceiling system is going to be disturbed (e.g., making a penetration to install light
fixtures or heating/cooling ducts), that fact should be known before a service or maintenance worker cuts or
drills into the wall or ceiling, and should affect how that work is performed. (See the 1992 guidance manual,
"Asbestos Operations & Maintenance Work Practices," published by the National Institute of Building
Sciences.)
Issue 2. Possible (unknowing) violations of the asbestos NESHAP by LEAs.
EPA's asbestos NESHAP program has also made "applicability determinations" regarding
plaster/stucco or skim coat layers applied over wallboard systems. As stated above, the EPA Asbestos
NESHAP position was summarized in a notice of clarification recently published in the Federal Register
(January 5, 1994). That notice in the Federal Register directs the attention of the regulated community to the
NESHAP requirement to analyze multi-layered samples and report results for discrete layers.
Schools operating under the requirements of AHERA have been, and continue to be, subject to EPA's
asbestos NESHAP compliance requirements, when involved in renovation or demolition activities where RACM
(regulated ACM) will be disturbed. EPA believes that the August 1994 Federal Register notice clarifies LEA
responsibilities under the asbestos NESHAP, and that this guidance regarding the use of the improved sampling
and analysis method will further clarify the situation and reduce the potential for possible violations of the
asbestos NESHAP.
m. Examples of Materials of Concern
Building materials typically containing thin asbestos fibers (e.g., floor tiles) or asbestos in low
concentration « 10%) are the subject of this guidance.
Also, plaster wall or ceiling systems, resilient flooring systems (flooring, mastic, underlayment), and
wallboard systems are examples of layered building materials subject to this guidance.
EPA does not regard a sheet of "plasterboard" by itself ("sheetrock." "wallboard.' "gypsum board") as
a multi-layered material. EPA is not adding a requirement to sample a section of plasterboard as such (see
definition in APPENDIX) as a "layered" material under either AHERA or NESHAP regulations.
Lack of knowledge about the possible asbestos content of different strata in layered materials can lead
to increased exposure risk under certain circumstances. In this guidance bulletin, EPA is attempting to address
the concern for sampling layered materials in a manner so as to reduce risk, as well as the need to comply with
recent NESHAP interpretations. The Jan. 5, 1994 Federal Register asbestos NESHAP clarification should be
consulted with regard to materials such as joint compound, texturing materials, etc. added to the surface of
wallboard, and when those materials would be subject to EPA's NESHAP regulation.
NOTE: Section V of this guidance bulletin offers a suggested strategy for distinguishing between joint
compound found at joints in wallboard systems or when the material was applied as a skim coat; i.e., for
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determining whether "joint compound" has been applied as a "skim coat" over a wall surface (as referred to in
the NESHAP Jan. 5, 1994 FR notice.)
IV. Helpful Sampling Techniques
LEA "designated persons," accredited asbestos Building Inspectors, consultants, and others should
follow previous EPA published requirements and guidance with regard to techniques for obtaining bulk samples
of building materials in order to analyze them for the presence of asbestos. This information was presented
both in guidance documents (such as the 1985 Pink Book and the Purple Book), and in the 1987 AHERA
"Asbestos in Schools' Rule Sec. 763.86, 763.87 (see "References.") The techniques are also discussed in
approved training courses for accrediting Building Inspectors.
To clarify EPA's guidance, it is important for the sampling device (core borer, knife, etc.) to penetrate
all layers of the sample to the substrate. As discussed in Section II, it may be important to know whether
discrete layers of a multi-layered sample contain asbestos. Service and maintenance workers may need to
perform their work on exposed surface layers that contain asbestos. Or, their task may require them to
penetrate non-asbestos layers into or through underlying asbestos-containing layers. Knowledge of where
asbestos occurs in a multi-layered sample is important as a means of reducing the potential for asbestos
exposure, and in selecting proper work practices to do so. It is also important to know the asbestos content of
individual layers, of course, for NESHAP compliance purposes.
Thus, the person who obtains the sample for analysis may need to use professional judgement based on
an on-stte situation. If a bulk sample remains intact through all layers, and the inspector judges that the sample
will remain intact until it reaches the analytical laboratory, the sample may not need to be separated into its
respective layers until the laboratory analyst does so. However, if a bulk sample crumbles or breaks down at
the..ti.m.e of sample collection, the sample collector may be required to take separate samples from discrete
layers at the site, and carefully identify them and their position in the multi-layered system for proper and useful
reporting by the laboratory.
EPA guidance regarding the need to keep layers separate as a particular sample is collected, therefore,
depends on several factors. They include the professional judgement of the accredited individual who takes the
sample, the physical condition and integrity of the material making up discrete layers of a multi-layered sample,
the possible importance of reporting asbestos content of an exposed surface layer vs. inner layers of a system
(depends on planned activity, such as in O&M tasks), and being in compliance with regulatory requirements.
The 1993 bulk sample guidance bulletin stresses the need for taking sufficient sample volumes of the
material to be analyzed. Sufficient sample volumes differ for different material types. Since the quantity of the
sample can affect the analytical sensitivity, EPA's recommendations in the July 1993 method should be noted.
V. Suggested Sampling Strategy for Dealing with Joint Compound vs. a Skim Coat/Add-on Application
(NESHAP Compliance issue: Sampling needs to be conducted to determine if materials are joint compound or a
skim coat application of the compound over a wall surface.) Be aware that materials applied to ceilings might
differ from materials used on walls, and that original construction and later renovations can result in the
application of different materials at different times. Joint compound applied to drywall installations prior to
1980 is more likely to contain asbestos than with installations after that date.
A. SAMPLING STRATEGY -
1. JOINT COMPOUND: Sample where joints are expected (take a minimum of 3 samples). For example,
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a. Inside or outside comers
b. Wallboard joint intervals; i.e., 4 feet from comers on wall stud. Use stud locator or knock
on wall to locate stud (listen for 'solid" sound). Look at walls above suspended ceiling
panels; unpainted joints covered by joint compound are often discemable there.
c. Note that joint compound is often applied to fill depressions around nailheads; consider
the "spottiness" of that type of application.
2. ADD-ON MATERIALS: Sample where joints are NOT expected (take a minimum of 3 samples). For
example,
a. Between corners and wallboard joint intervals. Locate by knock on wall, listen for
"hollow" sound.
3. KEEP GOOD RECORDS of sample locations for later evaluation of results. Note: A laboratory
cannot distinguish joint compound at joints from the same material used as a skim coat. Therefore, it
is very important that individuals collecting samples clearly describe the sample composition so that
the analytical laboratory knows whether to report the results as individual layers or as a "composite"
result for non-layered material. (See B-l, B-2 below.)
B. ANALYSIS OF SAMPLES IN LABORATORY, and DATA ANALYSIS BY THE
SAMPLER/ASSESSOR
All samples with-outer layer having > 1 % asbestos on wallboard will be noted. When this situation
applies, then the following must be considered:
1. If only joint sampling areas show layers with > 1 % asbestos, then material is joint compound.
a. Combine (weighted) analytical results into composite result for each sample.
1) If result is <,\%, no management is necessary.
2) If result is > 196, the material is RACM (NESHAP) and management is necessary.
2. If samples from both joint sampling area and non-joint areas show layers with > \% asbestos, then
the material should be considered "skim coat" or add-on material.
a. Do not composite (average) the results; report the results for each layer. Provide a
description of each layer in the report, to include their location in relation to each other.
b. Material so located should be treated as separate RACM layers according to the asbestos
NESHAP, and management is necessary.
VI. References
1. Advisory Regarding Availability of an Improved Bulk Sample Analysis Test Method; Supplementary
Information on Bulk Sample Collection and Analysis; 59 FR 38970, Federal Register, Aug. 1, 1994.
2. Asbestos-Containing Materials in Buildings: Simplified Sampling Scheme for Friable Surfacing
Materials (pink book), U.S. EPA 560/5-85-030a, October 1985.
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3. Asbestos-Containing Materials in Schools; Final Rule and Notice (AHERA Rule), 40 CFR Part 763,
October 1987.
4. Asbestos NESHAP Clarification Regarding Analysis of Multi-layered Systems. 59 FR 542, Federal
Register Jan. 5, 1994.
5. Guidance for Controlling Asbestos-Containing Materials in Buildings (purple book), U.S. EPA
560/5-85-024, 1985.
6. Guidance Manual: Asbestos Operations and Maintenance Work Practices, National Institute of
Building Sciences (NIBS), Washington, D.C., September 1992.
7. Managing Asbestos in Place: A Building Owner's Guide to Operations and Maintenance Programs
for Asbestos-Containing Materials (green book), U.S. EPA 20T-2003. July 1990.
8. National Emission Standards for Hazardous. Air Pollutants for Asbestos (Asbestos NESHAP Rule),
40 CFR 61, subpart M, November 1990.
9. Test Method: Method for the Determination of Asbestos in Bulk Building Materials, U.S. EPA
600/R-93/116,July 1993.
APPENDIX: Definitions
Binder: With reference to a bulk sample, a component added for cohesiveness, such as plaster, cement, glue,
vinyl, asphalt, etc.
Bulk sample: For the purposes of this guidance, representative portion of building material taken at one
distinct location for qualitative and quantitative identification of asbestos. In a multilayered system,
one needs a representative portion of each layer.
Discrete: Individually distinct, visually recognizable.
Layer: Stratum; one thickness of some material laid or lying over or under another thickness of the same or
different material.
Material: The substances or constituents of which something is composed or can be made. Various
materials are used in building construction, such as sand, wood, metal, plaster, cement, asbestos, etc.
Matrix: Material in which asbestos fibers are enclosed or embedded.
NESHAP: "National Emission Standards for Hazardous Air Pollutants;" EPA's asbestos NESHAP
regulation, at 40 CFR 61 Subpart M (especially for demolition and renovation activities).
Plaster: A pasty composition comprised largely of water, lime, and sand, that hardens on drying and is used
for coating building components such as walls; ceilings, and partitions. Asbestos fibers or other
fibrous materials sometimes have been mixed into the plaster to give particular properties.
* "acoustical" plaster plaster specially formulated and applied (sprayed or trowelled on) so as
to deaden or absorb sound.
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* "browncoaf plaster - also called "scratch coat;" a base coating of plaster, usually applied
over perforated plaster board, wooden lath or wire mesh.
* "topcoat" plaster a surface finish layer of plaster, usually white and smooth; may contain
sand to produce a grainy surface.
Plasterboard: A board used in large sheets as a backing or as a substitute for plaster in walls and consisting
of several plies of paper, fiberboard, or felt, usually bonded to a hardened gypsum plaster core.
("gyptsum] board," "drywall," "wallboard," "sheetrock")
PLM: Polarized light microscopy; a technique for analyzing bulk building material samples for presence of
asbestos. The sample is illuminated by polarized light and viewed under an optical microscope.
Sample: To take a sample of or from some material, especially to judge the quality or composition of that
material.
Separable: Capable of being separated.
Skim coat: A thin layer or coating of one material (e.g., plaster, stucco, joint compound) applied over
another.
Stratum: Layer; one of a series of layers, levels, or gradations in an ordered system; a bed or layer.
Stucco: A fine plaster used in the decoration and ornamentation of interior walls. (Also, a material usually
made of Portland cement, sand, and a small amount of lime, applied to form a hard covering for
exterior walls.) ' '
Substrate: The underlying support, foundation, or base (wood lath, wire screen, concrete, etc.) to which
something else (e.g., plaster) is applied.
System: An integrated group of building components which form an organized functional unit, such as a
wall system, or ceiling system, or floor system.
TEM: Transmission Electron Microscopy and related techniques; will enable specific identification of thin
asbestos fibers.
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