DRAFT
                          DEVELOPMENT DOCUMENT FOR



                         EFFLUENT LIMITATIONS GUIDELINES



                        AND STANDARDS OF PERFORMANCE
                           ASBESTOS MANUFACTURING
                                     Prepared By
                                       For



                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY




                          UNDER CONTRACT NUMBER 68-01-1505
                                  DATED: June, 1973

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                                  NOTICE

       The attached document is a DRAFT CONTRACTOR'S REPORT. It includes
 technical  information and recommendations submitted by the Contractor to the
 United States  Environmental Protection  Agency  ("EPA")  regarding  the subject
 industry.  It  is being distributed for review and comment only. The report is not
 an official EPA publication and it has not been reviewed by the Agency.

       The report, including the recommendations, will be  undergoing extensive
 review by EPA, Federal and Stale agencies, public interest organizations and other
 interested groups and persons during the coming weeks. The report and in particular
 the  contractor's   recommended effluent  limitations  guidelines and standards of
 performance is subject to change in any and all respects.

       The regulations to be published by EPA under Sections  304(b) and 306 of
 the Federal Water Pollution  Control Act, as amended, will be based to a large extent
 on the report and the comments received on it. However, pursuant to Sections 304(b)
 and 306  of the  Act,  EPA  will  also consider additional pertinent technical  and
 economic information which is developed in the course of review of this report by
 the public and within EPA. EPA is currently performing an economic impact analysis
 regarding  the subject industry, which will be taken into account as part of the review
 of the report. Upon completion of the review process, and prior to final promulgation
 of regulations, an EPA  report will be issued setting forth EPA's conclusions con-
 cerning the  subject  industry, effluent  limitations  guidelines and  standards  of
 performance applicable  to such industry.  Judgments necessary to promulgation of
 regulations under Sections  304(b) and 306 of the  Act, of course, remain the
 responsibility of  EPA.   Subject to these  limitations, EPA is  making this draft
•contractor's  report available in order to encourage the  widest possible  participation
 of interested persons in the decision  making process at the earliest possible time.

       The report shall  have standing in any EPA proceeding or  court  proceeding
 only to the  extent that it represents the  views of the Contractor who studied the
 subject industry and prepared the information and recommendations. It cannot be
 cited, referenced, or represented in any respect in any such proceedings as a statement
 of EPA's  views regarding the subject industry.
                                          U. S. Environmental Protection Agency
                                          Office of Air and Water Programs
                                          Effluent Guidelines Division
                                          Washington, D. C. 20460

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                                             DRAFT
        DEVELOPMENT DOCUMENT FOR
     EFFLUENT LIMITATJONS GUIDELINES
      AND STANDARDS OF PERFORMANCE
        ASBESTOS MANUFACTURING
          DRAFT FINAL REPORT
                   TO
    ENVIRONMENTAL PROTECTION AGENCY
              PREPARED BY
SVERDRUP & PARCEL AND ASSOCIATES,  Inc.
          ST. LOUIS,  MISSOURI

               JUNE 1973

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                                                            DRAFT
                            ABSTRACT
This document presents the findings of an extensive study of the
asbestos manufacturing industry by the Environmental Protection
Agency for the purpose of developing effluent limitations guide-
lines, Federal standards of performance, and pretreatment standards
for the industry, to implement Sections 304, 306 and 307 of the "Act."

Effluent limitations guidelines contained herein set forth the degree
of effluent reduction attainable through the application of the best
practicable control technology currently available and the degree of
effluent reduction attainable through the application of the best
available technology economically achievable which must be achieved
by existing point sources by July 1, 1977 and July 1, 1983 respect-
ively.  The Standards of Performance for new sources contained herein
set forth the degree of effluent reduction which is achievable through
the application of the best available demonstrated control technology,
processes, operating methods, or other alternatives.

The proposed regulations require 95 percent or better removal of the
significant wastewater pollutant constituents by the principal point
sources in the industry by July 1, 1977.

The proposed regulations further require that there be no discharge
by any point sources in the industry by July 1, 1983.  With the excep-
tion of two subcategories, this regulation also applies to new sources.

Pretreatment Standards for "new sources" discharging to municipal
sewerage systems are set forth in "Pretreatment of Discharges to
Publicly Owned Treatment Works," 	C.F.R. 	.

Supportive data and rationale for developments of the proposed effluent
limitations guidelines and standards of performance are contained in
this report.
NOTICE;  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA
                                iii

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                                                            DRAFT
                         TABLE OF CONTENTS


SECTION                                                      PAGE

    I      Conclusions                                         1

   II      Recommendations                                     3

  III      Introduction                                        5

                Purpose and Authority                          5
                Summary of Methods                             6
                General Description of Industry                7
                Manufacturing Locations                        9
                Current Status of Industry                    14

   IV      Industry Categorization                            17

                Introduction                                  17
                Factors Considered                            17
                Asbestos-Cement Products                      20
                Asbestos Paper                                27
                Asbestos Millboard                            31
                Asbestos Roofing                              34
                Floor Tile                                    36

    V      Water Use and Waste Characterization               39

                Introduction                                  39
                Asbestos-Cement Pipe                          40
                Asbestos-Cement Sheet                         44
                Asbestos Paper                                45
                Asbestos Millboard                            47
                Asbestos Roofing                              48
                Asbestos Floor Tile                           50

   VI      Selection of Pollutant Parameters                  53

                Selected Parameters                           53
                Rationale for Selection                       54
                Critical Parameters                           56

  VII      Control and Treatment Technology                   57

                Introduction                                  57
                In-Plant Control Measures                     58
                Treatment Technology                          62
                                 v

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                       CONTENTS (Continued)
                                                            DRAFT
SECTION

 VIII
   IX
    X
   XI
  XII

 XIII

  XIV
                                                  PAGE
Cost, Energy, and Non-Water Quality Aspects        67

     Cost and Reduction Benefits                   67
     Energy Requirements                           73
     Non-Water Quality Aspects                     73
     Discharge to Public Sewers                    75

Best Practicable Technology Currently Available
  Effluent Limitations Guidelines                  77

     Introduction                                  77
     Effluent Reduction Attainable                 78
     Identification of Control Technology          79

Best Available Technology Economically Achievable
  Effluent Limitations Guidelines                  83

     Introduction                                  83
     Effluent Reduction Attainable                 84
     Identification of Control Technology          84

New Source and Pretreatment Performance Standards  87
     Introduction
     New Source Performance Standards
     Pretreatment Standards

Acknowled gment s

References

Glossary
87
87
87

89

91

95
                                vi

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                                                            DRAFT
                              FIGURES


NUMBER                                                       PAGE

1     Asbestos-Cement Sheet Manufacturing Operations,          22
        Dry Process

2     Asbestos-Cement Sheet Manufacturing Operations,          23
        Wet Process

3     Asbestos-Cement Sheet Manufacturing Operations,          24
        Wet Mechanical Process

4     Asbestos-Cement Pipe Manufacturing Operations,           25
        Wet Mechanical Process

5     Asbestos Paper Manufacturing Operations                 28

6     Asbestos Millboard Manufacturing Operations             32

7     Asbestos Roofing Manufacturing Operations               35

8     Asbestos Floor Tile Manufacturing Operations            37

9     Water Balance Diagram for a Typical                     41
        Asbestos-Cement Pipe Plant
                              TABLES


      Locations of Asbestos Manufacturing Plants               10
                                vii

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                                                             DRAFT
                            SECTION I

                           CONCLUSIONS
That part of the asbestos manufacturing industry covered in this
document (Phase I) is classified into five categories,  two of which
are each divided into two subcategories.  The categorization is
based on (a) distinct product lines and (b) applicability of waste
control technology.  Factors such as age and size of manufacturing
plants, processes employed, and geographic location do  not provide
significant bases for differentiation.

The categories, with subcategories indicated, are as follows:

1.  Asbestos-cement products
    a.  Pipe
    b.  Sheet; flat and corrugated
2.  Asbestos paper
    a.  Starch binder
    b.  Elastomeric binders
3.  Asbestos millboard
4.  Asbestos roofing products
5.  Asbestos floor tile

Phase II will include the following asbestos products:   friction
materials, textiles and fabrics, and gaskets and packings.

Recommended effluent limitations and waste control technologies to
be achieved by July 1, 1977, and July 1, 1983, are summarized in
Section II.  It is estimated that the investment cost of achieving
the 1977 limitations and standards by all plants in the industry
is less than $3 million, excluding costs of additional land acquisi-
tion.  The cost of achieving the 1983 level is estimated to be about
$6 million for the industry, i.e., an additional $3 million over the
1977 level.
NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.

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                                                            DRAFT
                            SECTION II

                          RECOMMENDATIONS
The recommended effluent limitations for the parameters of major
significance are summarized below for the categories of asbestos
products included in this document.

Using the best practicable control technology currently available,
the limits are as follows:

                              Suspended         BOD           pH
                               Solids         (5-day)       (Max.)
                                kg/MT          kg/MT

Asbestos-cement pipe            0.19           0.09           9.0
Asbestos-cement sheet           0.23           0.11           9.0
Asbestos paper                  0.35           0.35           8.5
Asbestos millboard                        zero discharge
Asbestos roofing                0.006          0.006          8.3
Asbestos floor tile             0.04*          0.02*          8.3

*Units:  kilogram per 1,000 pieces

Using the best available control technology economically achievable,
no discharge of wastewaters to navigable water is recommended as the
effluent limitation guideline and standard of performance for all of
the above categories of asbestos products.  With the exception of
asbestos-cement pipe and asbestos paper containing elastomeric bind-
ers, this limitation and standard of performance is recommended for
all new point sources.  These two excepted products should meet the
limitations outlined as best practicable control technology currently
available.

Sources discharging to municipal sewerage systems should limit all
noncompatible constituents to the levels recommended for discharges
from plants using the best practicable technology currently avail-
able.
NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.

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                                                            DRAFT
                            SECTION III

                            INTRODUCTION
PURPOSE AND AUTHORITY

Section 301(b) of the Act requires the achievement by not later
than July 1, 1977, of effluent limitations for point sources,
other than publicly owned treatment works, which are based on the
application of the best practicable control technology currently
available as defined by the Administrator pursuant to Section 304(b)
of the Act.  Section 301(b) also requires the achievement by not
later than July 1, 1983, of effluent limitations for point sources,
other than publicly owned treatment works, which are based on the
application of the best available technology economically achiev-
able which will result in reasonable further progress toward the
national goal of eliminating the discharge of all pollutants, as
determined in accordance with regulations issued by the Administra-
tor pursuant to Section 304(b) to the Act.  Section 306 of the Act
requires the achievement by new sources of a Federal standard of
performance providing for the control of the discharge of pollutants
which reflects the greatest degree of effluent reduction which the
Administrator determines to be achievable through the application
of the best available demonstrated control technology, processes,
operating methods, or other alternatives, including, where prac-
ticable, a standard permitting no discharge of pollutants.

Section 304(b) of the Act requires the Administrator to publish
within one year of enactment of the Act, regulations providing
guidelines for effluent limitations setting forth the degree of ef-
fluent reduction attainable through the application of the best
practicable control technology currently available and the degree
of effluent reduction attainable through the application of the
best control measures and practices achievable including treatment
techniques, process and procedure innovations, operation methods
and other alternatives.  The regulations proposed herein set forth
effluent limitations guidelines pursuant to Section 304(b) of the
Act for the asbestos manufacturing source category.

Section 306 of the Act requires the Administrator, within one year
after a category of sources is included in a list published pur-
suant to Section 306(b) (l) (A) of the Act, to propose regulations
establishing Federal standards of performances for new sources with-
in such categories.  The Administrator published in the Federal
Register of January 16, 1973 (38 F. R. 1624), a list of 27 source
categories.  Publication of the list constituted announcement of the
Administrator's intention of establishing, under Section 306, stand-
ards of performance applicable to new sources within the asbestos

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                                                            DRAFT
manufacturing source category, which was included within the list
published January 16, 1973.

SUMMARY OF METHODS USED FOR DEVELOMENT OF THE EFFLUENT LIMITATIONS
GUIDELINES AND STANDARDS OF PERFORMANCE

The effluent limitations guidelines and standards of performance
proposed herein were developed in the following manner.  The point
source category was first categorized for the purpose of determin-
ing whether separate limitations and standards are appropriate for
different segments within a point source category.  Such subcate-
gorization was based upon raw material used, product produced,
manufacturing process employed, and other factors.  The raw waste
characteristics for each subcategory were then identified.  This
included an analyses of (l) the source and volume of water used in
the process employed and the sources of waste and wastewaters in
the plant; and (2) the constituents (including thermal) of all
wastewaters including toxic and other constituents that result in taste,
odor, and color in water or aquatic organisms.  The constituents
of wastewaters which should be subject to effluent limitations
guidelines and standards of performance were identified.

The full range of control and treatment technologies existing with-
in each subcategory was identified.  This included an identifica-
tion of each distinct control and treatment technology, including
both inplant and end-of-process technologies, which are existent
or capable of being designed for each subcategory.  It also in-
cluded an identification in terms of the amount of constituents
(including thermal) and the chemical, physical, and biological
characteristics of pollutants, of the effluent level resulting
from the application of each of the treatment and control techno-
logies.  The problems, limitations and reliability of each treat-
ment and control technology and the required implementation time
was also identified.  In addition, the non-water quality environ-
mental impact, such as the effects of the application of such
technologies upon other pollution problems, including air, solid
waste, noise and radiation were also identified.  The energy re-
quirements of each of the control and treatment technologies was
identified as well as the cost of the application of such techno-
logies.

The information, as outlined above, was then evaluated in order to
determine what levels of technology constituted the "best practic-
able control technology currently available," "best available
technology economically achievable" and the "best available demon-
strated control technology, processes, operating methods, or other
alternatives."  In identifying such technologies, various factors
were considered.  These included the total cost of application of
technology in relation to the effluent reduction benefits to be
achieved from such application, the age of equipment and facilities
involved, the process employed, the engineering aspects of the ap-
                                 6

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                                                            DRAFT
plication of various types of control techniques process changes,
non-water quality environmental impact (including energy require-
ments) and other factors.

The data for identification and analyses were derived from a number
of sources.  The sources included published literature, previous
EPA technical publications on the industry, a voluntary question-
naire distributed through the Asbestos Information Association of
North America, qualified technical consultation, information con-
tained in Corps of Engineers discharge permit applications, and on-
site visits and interviews at exemplary asbestos manufacturing
plants throughout the United States.  All references used in develop-
ing the guidelines for effluent limitations and standards of per-
formance for new sources reported herein are included in Section XIII
of this document.

GENERAL DESCRIPTION OF THE INDUSTRY

Although known as a curiosity since biblical times, asbestos was
not used in manufacturing until the latter half of the 19th century.
By the early years of the 20th century, much of the basic tech-
nology had been developed and the industry has grown in this country
since about that time.  Canada is the world's largest producer
of asbestos, with the USSR and a few African countries as major sup-
pliers.  Mines in four states; Arizona, California, North Carolina,
and Vermont, provide a relatively small proportion of the world's
supply.

Asbestos is normally combined v/ith other materials in manufactured
products, and consequently, it loses its identity.  It is a natural
mineral fiber which is very strong and flexible and resistant to
breakdown under adverse conditions, especially high temperatures.
One or more of these properties are exploited in the various manu-
factured products that contain asbestos.

Asbestos is actually a group name that refers to several serpentine
minerals having different chemical compositions, but similar charac-
teristics.  The most widely used variety is chrysotile.  Asbestos
fibers are graded on the basis of length, with the longest grade
priced 10 to 20 times higher than the short grades.  The shorter
grades are normally used in the products covered in this document.

On a world-wide basis, asbestos-cement building materials and pipe
currently consume about 70 percent of the asbestos mined.  In the

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                                                            DRAFT
United States  in 1971,  the  consumption pattern was reported  to "be:

                 Asbestos-cement products     25%
                 Floor  tile                  18
                 Papers and felts             14
                 Friction products            10
                 Textiles                      3
                 Packing and gaskets           3
                 Sprayed insulation            2
                 Miscellaneous uses           25

These figures  do not accurately reflect the production levels of
these products because  the  asbestos content varies from about 10
to almost 100  percent among the different manufactured products.

This document  covers the first three groups in the above  list.
These groups were selected  because they represent a major segment
of the industry; water  is an ingredient in the manufacturing pro-
cess, with two exceptions;  and they were regarded as the most im-
portant sources of water pollutants in this industrial category.

Asbestos-Cement Products

Asbestos fibers in asbestos-cement products serve the same role as
steel rods in  reinforced concrete, i.e., they add strength.  Port-
land cement and silica  are  the major ingredients, with asbestos,
of these products.

Asbestos-cement pipe is  manufactured for use in high pressure and
low, pressure applications in diameters from 7.6 to 91.5 cm (3 to
36 inches) and in lengths up to 4 meters (13 feet).  It is used to
carry wastewaters, water supplies, and other fluids and in venting
and duct systems.  Asbestos-cement flat and corrugated sheets are
used for exterior sheathing, siding and roofing, interior parti-
tions, packing in cooling towers, laboratory bench tops, and many
other specialty applications.

Asbestos Floor Tile

The shortest grades of asbestos fibers are used in vinyl and asphalt
floor tile manufacture.  The fibers are used to provide dimensional
stability.  Today, vinyl asbestos floor tile accounts for most of
the asbestos used in this category, with asphalt tile serving some
special applications and where darker shades are permissible.

Asbestos Papers and Felts

Asbestos papers have a high  fiber content and are manufactured with
a variety of binders and other additives for many applications.
These include pipe coverings, gaskets, thermal linings in heaters
and ovens, and wicks.  Heavier papers are commonly used for roofing

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                                                            DRAFT
materials and shingles.  Millboard is a heavier, stiffer form of
paper that includes clays, cement, or other additives.  It is used
for stove lining, filament supports in toasters, and several other
high temperature applications.

Asbestos Molded Insulation

A product category that would logically be included with the above
groups is asbestos molded, or block, insulation; e.g., 85 percent
magnesia.  This was used for covering steam pipes, boilers, etc.
In recent years, asbestos has been replaced by other materials by
almost all of the major insulationxmanufacturers.  Several sources
predicted that no significant quantity of asbestos molded insula-
tion will be produced in the very near future.  Because of its
very limited production level at present and its predicted disap-
pearance, this product category was not studied in depth.  Waste-
waters from the manufacture of molded insulation should respond
to the same forms of control technology that apply to other asbes-
tos products.

MANUFACTURING LOCATIONS

The locations of the plants that manufacture the products covered
in this document are listed in Table 1.  This listing includes all
the plants as reported by the major manufacturers.  It is known
that there are a few plants, mostly in the roofing and floor tile
categories, that are not included.  All of the available known
information from the plants at these locations was collected for
use in this study.  At several plants, no information about waste-
water volumes or characteristics was known.

At most of the plants, only one asbestos product is manufactured.
There are three reported locations that manufacture more than one
category of asbestos product in the same plant in a manner that
results in a combined wastewater flow.  Since the wastewaters from
all the asbestos products categories, except roofing and floor
tile, have many common characteristics, they are generally treat-
able by the same types of control technology.  Consequently, the
combined wastewaters from the manufacture of multiple asbestos
products do not present significant additional problems in control.

Of more significance from a water pollution control point of view
is the manufacture of non-asbestos products with confluent waste
streams at some of the locations.  The most common combinations are
the manufacture of plastic pipe at asbestos-cement pipe plants and
the manufacture of "organic" (cellulose fiber) paper at asbestos
paper plants.  Plastic pipe manufacture is not likely to result in
the discharge of significant pollution, other than waste heat.  Or-
ganic paper manufacturing wastewaters, however, are significantly
stronger and of different character than those from asbestos paper
production.  The raw materials are often paperstock (salvaged paper)

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                  TABLE 1




LOCATIONS OF ASBESTOS MANUFACTURING PLANTS

State
Alabama

Arkansas
California










Florida
Georgia
Illinois


Location
Ragland
Mobile
Van Buren
La Mirada
South Gate
Riverside
Santa Clara
Los Angeles
Long Beach
Long Beach
Los Angeles
Pittsburg

Stockton
Green Cove Springs
Savannah
Kankakee
Chicago
Joliet
Company
Cement Asbestos Products Co.
GAF Corporation
Cement Asbestos Products Co.
American Biltrite Rubber
Armstrong Cork Company
Certain-Teed Products Corp.
Certain-Teed Products Corp.
The Flintkote Company
GAF Corporation
J ohns-Manville
J ohns-Manville
Johns-Manville

J ohns-Manville
Johns-Manville
Johns-Manville
Armstrong Cork Company
The Flintkote Company
GAF Corporation
Products
A-C Pipe
A-C Sheet
A-C Pipe
Floor Tile
Floor Tile
A-C Pipe
A-C Pipe
Floor Tile
Floor Tile
A-C Pipe
Roofing
A-C Sheet,
Paper
A-C Pipe
A-C Pipe
Roofing
Floor Tile
Floor Tile
Floor Tile

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                                           TABLE 1 (contd)

                             LOCATIONS OF ASBESTOS MANUFACTURING PLANTS
    State
     Location
            Company
 Products
Illinois (contd)
Waukegan
J ohns-Manville
Louisiana




Massachusetts


Mississippi

Missouri


New Hampshire



New Jersey
New Orleans
Marrero

New Orleans

Millis
Billerica

Jackson

St. Louis
St. Louis

Nashua
Tilton
Linden
South Bound Brook
The Flintkote Company
Johns-Manville

National Gypsum Company

GAF Corporation
Johns-Manville

Armstrong Cork Company

Certain-Teed Products Corp.
GAF Corporation

J ohns-Manville
J ohns-Manville
Celotex Corporation
GAF Corporation
A-C Pipe,
A-C Sheet,
Paper,
Millboard,
Roofing

Floor Tile
A-C Sheet,
Roofing
A-C Sheet

Roofing
Millboard

Floor Tile

A-C Pipe
A-C Sheet

A-C Sheet
Paper,
Millboard

Paper
A-C Sheet,
Roofing

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                                      TABLE  1  (contd)




                         LOCATIONS  OF ASBESTOS  MANUFACTURING PLANTS
State
Location
Company
Products
New Jersey (contd)




New York


Ohio




Pennsylvania









Manville



Millington
Fulton
Vails Gate
Brooklyn
Cincinnati


Ravenna
Hamilton
Lancaster
Ambler
Erie

Erie
Whitehall
Ambler

Norristown

Johns-Manville



National Gypsum Company
Armstrong Cork Company
GAF Corporation
Kentile Floors, Inc.
Celotex Corporation


The Flintkote Company
Nicolet Industries, Inc.
Armstrong Cork Company
Certain-Teed Products Corp.
GAF Corporation

GAF Corporation
GAF Corporation
Nicolet Industries, Inc.

Nicolet Industries, Inc.

A-C Pipe,
A-C Sheet,
Paper,
Roofing
A-C Sheet
Paper
Floor Tile
Floor Tile
A-C Sheet,
Paper ,
Millboard
A-C Pipe
Paper
Floor Tile
A-C Pipe
Paper,
Millboard
Roofing
Paper
A-C Sheet,
Millboard
Paper,
Millboard

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              TABLE 1 (contd)




LOCATIONS OF ASBESTOS MANUFACTURING PLANTS

State Location
Texas Hills"boro
Houston
Denison
Fort Worth
Company
Certain-Teed Products Corp.
GAF Corporation
Johns-Manville
Johns-Manville
Products
A-C Pipe
Floor Tile
A-C Pipe
Paper,
Roofing
Puerto Rico
Ponce
Boringuen Asbestos Cement Corp.
                                                               A-C Sheet

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                                                            DRAFT
as well as virgin pulp and the wastes are highly colored, turbid,
and high in oxygen demand.

CURRENT STATUS OF THE INDUSTRY

Until recently, little attention has "been directed toward the waste-
waters associated with asbestos manufacturing.  The number of plants
is not large, the volumes of the wastes are relatively small, and
the waste constituents do not exert a heavy oxygen demand on re-
ceiving waters.  There is significant internal recirculation of pro-
cess waters incorporated in the manufacturing operations,and most
of the plants provide at least some form of waste treatment; although
rudimentary at some locations.  Many of the roofing and floor tile
plants are situated where they can discharge the process wastewaters
to municipal sewers with minimal pretreatment.  There is virtually
no information in the literature on wastewaters from asbestos manu-
facturing.  What little technical information that is available is
from only a few plants and is of recent vintage.

The asbestos industry has long been concerned about the industrial
hygiene aspects of the dust and fiber emitted to the air in mining,
processing, transportation, and manufacturing operations.  This
concern has recently been expanded to include the general public.
Asbestos is among the first materials to be declared a hazardous
air pollutant under the Clean Air Act amendments of 1970.  Strin-
gent regulations have also been promulgated to control exposure
to workers in the industry.

The increased concern with the health effects of asbestos fibers
in the air has produced changes that affect, to some degree, the
water pollution control aspects of the industry.  The principal
change has been conversion of dry processes into wet processes and
the use of water sprays to allay dust from mining operations and
slag piles.  This shifting is expected to continue in the future.

While there has been considerable interest and much research on
the health effects of asbestos in air, there has been almost no
study of the effects of fibers in water.  The situation is compli-
cated by the lack of a standard method for detecting and enumerat-
ing the fibers in water.  The levels in natural waters resulting
from manufacturing operations are not known.  It is believed that
they are lower, however, than the levels in ground waters flowing
from serpentine rock formations.  In summary, there is no evidence
today to indicate that asbestos fibers in natural waters are harm-
ful to man or aquatic life.  This, on the other hand, does not as-
sure that they produce no health effects.

The asbestos manufacturing industry grew rapidly in the first two-
thirds of the 20th century.  Many observers expect that growth will
be less rapid in the future.  Environmental and health considerations,

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                                                            DRAFT
       plus competition from fiberglass, silicone products, alumi-
num sheet, and other materials, are among the factors contributing
to the slowdown in growth.  Many of the plants visited in this
study were not operating at full capacity.  New uses and markets
for asbestos may be more difficult to develop in the future.  De-
spite the decline in the rate of growth, asbestos has unique
characteristics, and its use in manufacturing can be expected to
continue to a significant degree in the forseeable future.
                                15

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                                                            DRAFT
                            SECTION IV

                      INDUSTRY CATEGORIZATION
INTRODUCTION

In developing effluent limitation guidelines and standards of per-
formance for new sources for a given industry, a judgment must be
made "by EPA as to whether different effluent limitations and stand-
ards are appropriate for different segments (categories) within the
industry.  The factors considered in determining whether such cate-
gories are justified in the asbestos manufacturing industry are:

               1.  Product
               2.  Raw Materials
               3.  Manufacturing Process
               4.  Treatability of Wastewaters
               5.  Plant Size
               6.  Plant Age
               7.  Geographic Location

Based on review of the literature, plant visits and interviews, and
consultation with industry representatives, the above factors were
evaluated and it was concluded that the asbestos manufacturing in-
dustry should be divided into five product categories and four sub-
categories.  The categories are:

             Asbestos cement products
                  a.  pipe
                  b.  sheet; flat and corrugated
             Asbestos paper and felts
                  a.  starch binder
                  b.  elastomeric binders
             Asbestos millboard
             Asbestos roofing products
             Asbestos floor tile

FACTORS  CONSIDERED

All of the factors listed above are briefly discussed below, even
though most of them did not serve as bases for categorization.

Product

Despite some basic similarities in the manufacturing processes used
to make the products in the first three categories above, the final
products are distinct and are well defined and recognized within the
                               17

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                                                            DRAFT
industry.  In most cases, only one asbestos product is made in a
given plant.  Categorization by product is a logical and useful means
of classification.

Raw Materials

Many of the raw materials used in asbestos products are natural
materials such as clay, portland cement, and starch.  It is sus-
pected that variations in these raw materials result in opera-
tional differences that influence the wastewater volume and
strength.  Changes within a product category at a given plant may
occur regularly and the amounts and types of raw materials may
also be changed.

While variations in raw material quality and usage do exert some
influence on the wastewater characteristics, there is no quanti-
tative information in the industry about these influences.  This
may account for some of the differences between plants in the same
category.  It should not result in serious effluent limitation con-
trol problems, however.

Manufacturing Process

Within a given product category, the basic manufacturing processes
are very similar.  Any differences that do exist do not greatly in-
fluence the quantity or quality of the effluent.  Differences in the
number and size of auxiliary manufacturing units, such as save-alls,
can greatly affect the wastewater effluent, both in volume and strength,
however.

Treatability of Wastewater

While seemingly similar when described by the common collective para-
meters (suspended solids,'oxygen demand, etc.), the wastewaters from
the different product categories exhibit some important differences.
These are described in detail in Section V of this document.  The dif-
ferences relate both to the in-plant and end-of-pipe control measures
and to the speed with which the category can be brought to the point
where pollutants are not discharged.

Plant Size

Plant size was not found to be a factor in categorizing the asbestos
manufacturing industry.  All of the plants visited had either one
or two "machines."  The machines are roughly of about the same capa-
city; and, consequently, all of the plants in a given category, or
subcategory, do not range widely in size.   The operational efficiency,
quality of housekeeping, labor availability, and wastewater charac-
teristics of the plants do not differ because of size differences.
The largest plants in the industry are actually multi-product plants
and are, in reality, assemblages of individual product category manu-
facturing units.


                               18

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                                                            DRAFT
Plant size does not affect the type or performance of effluent con-
trol measures.  As described in Section VII, the basic waste treat-
ment operation for this industry is sedimentation.  Design is based
on hydraulic flow rate and plants with smaller discharges can use
smaller and somewhat less costly treatment units.

There are a few specialty plants with reported production levels
that are very low.  From the data provided, however, no significant
differences in effluent characteristics of these plants could he
detected.  Not including these small plants, the approximate reported
daily production ranges for the product categories are as follows:

     Asbestos-cement pipe        135 to 320 MT (150 to 350 tons)
     Asbestos-cement sheet        90 to 230 MT (100 to 250 tons)
     Asbestos paper               45 to  90 MT (50 to 100 tons)
     Asbestos millboard            6 to  14 MT (7 to 15 tons)
     Asbestos roofing            (360 to 450 MT)* (400 to 500 tons)*
     Asbestos floor tile         300,000 to 650,000 pieces

*The limited data from roofing plants do not permit an accurate
estimate of the full range of production.

Plant Age

The ages of the plants in the asbestos manufacturing industry range
from a few to 50 or more years.  The manufacturing equipment is often
younger than the building housing the plant, although in some cases,
used machines have been installed in new plants.  Plant age could
not be correlated with operational efficiency, quality of house-
keeping, or wastewater characteristics.  The major effects of plant
age may be related to the cost of providing effluent control measures.
Plant age is not an appropriate basis for categorization of the
industry.

Geographic Location

Asbestos manufacturing plants are primarily in the east and south
and in California.  There are reportedly no differences in the pro-
cesses used throughout the country.  As noted above, differences
could exist in the locally supplied natural raw materials.  These
could influence the mode of operation and the effluent stream.  There
is no knowledge developed at present by which to describe the extent
or importance of these differences.

Plants in some southwestern locations are able to accomplish zero
discharge because of high evaporation losses from lagoons.  This
treatment option is not available throughout most  of the nation,
however.
                               19

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                                                             DRAFT
 General Manufacturing Process

 With the  exception of roofing  and  floor tile manufacture, there  is
 a basic similarity in the methods  of producing  the  various  asbestos
 products.   The  asbestos  fibers and other  raw materials  are  first
 slurried  with water and  then formed into  single or  multi-layered
 sheets as  most  of the water is removed.   The manufacturing  process
 always incorporates the  use of save-alls  (settling  tanks of various
 shapes) through which process  wastewaters are usually routed.  Water
 and solids are  recovered and reused from  the save-all,  and  excess
 overflow  and  underflow constitute  the process waste streams.   In all
 of these  product  categories, water serves both  as an ingredient  and
 a means of conveying the raw materials to and through the forming
 steps.

ASBESTOS-CEMENT PRODUCTS

 The largest single use category of asbestos fibers  in the United
 States is  the manufacture of asbestos-cement products.  The pipe
 segment is the  largest component of this  product category.

 Raw Materials

 Asbestos-cement products contain from 10  to 70  percent  asbestos  by
 weight, usually of the chrysotile  variety.  Crocidolite and other
 types are  used  to a limited extent depending upon the properties
 required  in the product.  Portland cement content varies from  25
 to 70 percent.  Consistent cement  quality is very important since
 variations in the chemical content or fineness  of the grind can
 affect production techniques and final product  strength.  The
 remaining  raw material,  from 5 to  35 percent, is finely ground silica.
 Some asbestos-cement pipe plants have facilities for grinding
 silica as  an  integral part of  their operations.  Finely ground
 solids from damaged pipe or sheet  trimmings are used by some plants
 as filler  material.   A maximum of  6 percent filler  can  be used in
 some products before strength  is affected.

 The interwoven  structure formed by the asbestos fibers  in asbestos-
 cement products functions as a reinforcing medium by imparting in-
 creased tensile strength to the cement.   As a result, there is a
 70 to 80 percent  decrease in the weight of the  product  required  to
 attain a  given  structural strength.  It is important that the
 asbestos be embedded in  the product in a  completely fiberized  or
 willowed  form,  and the necessary fiber conditioning is  frequently
 carried out prior to mixing the fiber with the  cement and silica.
 In some cases, however,  this fiber opening is accomplished  while
 the wet mixture is agitated by a pulp beater, or hollander.

 Manufacture

 Asbestos-cement sheet products are manufactured by  the  dry  process,
 the wet process,  or the  wet mechanical process.  Figures 1  through


                                20

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                                                            DRAFT
3 illustrate the sequence of steps in each of these manufacturing
processes with the sources of wastes indicated.  Products having
irregular shapes are formed by molding processes which account for
only a very limited production today.  Extrusion processes are not
widely used in the United States.

Dry Process—

In the dry process (Figure 1),  which is suited to the manufacture
of shingles and other sheet products, a uniform thickness of the
mixture of dry materials is distributed onto a conveyor belt,
sprayed with water, and then compressed against rolls to the de-
sired thickness and density.  Rotary cutters divide the moving sheet
into shingles or sheets which are subsequently removed from the con-
veyor for curing.  The major source of process wastewater in this
process is the water used to spray clean the empty belt as it returns.

Wet Process—

The wet process (Figure 2) produces dense sheets, flat or corrugated,
by introducing a slurry into a mold chamber and then compressing
the mixture to force out the excess water.  A setting and hardening
period of from 24 to 48 hours precedes the curing operation.  The
large, thick monolithic sheets used for laboratory bench tops are
manufactured by this process.  The grinding operations used to
finish the sheet surfaces produce a large quantity of 'dust which
may be discharged with the process wastewaters.  This affords a
means of reducing and controlling air emissions.

Wet Mechanical Process—

The wet mechanical process, which is also used for the manufacture
of asbestos-cement pipe (Figure 4), is similar in principle to some
papermaking processes.   The willowed asbestos fiber is conveyed
to a dry mixer where it is blended with the cement, silica, and
filler solids.  After thorough blending of the raw materials, the
mixture is transferred to a wet mixer or beater.  Underflow solids
and water from the save-all are added to form a slurry containing
about 97 percent water.  After thorough mixing, the slurry is pumped
to the cylinder vats for deposition onto one or more horizontal
screen cylinders.  The circumferential surface of each cylinder is
a fine wire mesh screen that allows water to be removed from the
underside of the slurry layer picked up by the cylinder.  The re-
sulting layer of asbestos-cement material is usually from 0.02 to
0.10 inch in thickness.  The layer from each cylinder is trans-
ferred to an endless felt conveyor to build up a single mat for
further processing.  A vacuum box removes additional water from the
mat prior to its transfer to mandrel or accumulator roll.  This
winds the mat into sheet or pipe stock of the desired thickness.
Pressure rollers bond the mat to the stock already deposited on the
mandrel or roll and remove excess water.  Pipe sections are removed
                                21

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                                               DRAFT
RAW MATERIALS
STORAGE
PROPORTIONING
DRY MIX
WATER
+

ROLLING



CUTTING r-
STEAM
+

CURING f"


FINISHING
STORAGE


	 >
                 CONSUMER
                                           WASTEWATER


                                           SOLIDS
                                           CONDENSATE
Figure 1 - Asbestos-Cement Sheet Manufacturing Operations,
            Dry Process
                     22

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                                                 DRAFT
         RAW MATERIALS
            STORAGE
         PROPORTIONING
            DRY MIX
WATER
            WET MIX
STEAM


HARDENING

+

CURING U-


FINISHING


             STORAGE
            CONSUMER
                                      WASTEWATER
                                      CONDENSATE
                                      SOLIDS
     Figure 2 - Asbestos-Cement Sheet Manufacturing Operations,
                Wet Process

-------
                                                    DRAFT
WATER
STEAM
         RAW MATERIALS
           STORAGE
         PROPORTIONING
           DRY MIX
      	RECYCLED SOLIDS

      RECYCLED WATER
          ~l
            WET MIX
                                                    WASTEWATER
              CLARIFICATION
               (SAVE-ALL)
                                                      I
            FORMING
                                     SLUDGE
                                     (DUMP)
            CURING
         AIR/AUTOCLAVE
            CUTTING
]	
                       CONDENSATE
SOLIDS
           FINISHING
            STORAGE
            CONSUMER
     Figure 3 - Asbestos-Cement Sheet Manufacturing Operations,
                Wet Mechanical Process

-------
WATER
STEAM
WATER
                                                   PFAF
        RAW MATERIALS
           STORAGE
        PROPORTIONING
           DRY MIX
	RECYCLED SOLIDS

 RECYCLED WATER
           WET MIX
                                                   WASTEWATER
         CLARIFICATION
          (SAVE-ALL)
_J
            FORMING
                               SLUDGE
                                (DUMP)
            CURING
          (AUTOCLAVE)
                 CONDENSATE
           PIPE END
           FINISHING
                 SOLIDS
                       RECYCLED
          HYDROSTATIC
            TESTING
                 WASTEWATER
           FINISHING
           STORAGE
           CONSUMER
   Figure 4 - Asbestos-Cement Pipe Manufacturing Operations,
               Wet Mechanical Process
                          25

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                                                            DRAFT
from the mandrel, air cured, steam cured in an autoclave, and then
machined on each end.

In \the manufacture of sheet products by the wet mechanical process,
the layer of asbestos-cement on the accumulator roll is periodically
cut across the roll and peeled away to form a sheet.  The sheet is
either passed through a pair of press rollers to shape the surface
and cut the sheet into shingles, formed into corrugated sheet, or
placed onto a flat surface for curing.

The asbestos-containing water removed from the slurry or mat is
recycled to the process.  Very little asbestos is lost from the
manufacturing process.

Cleaning

The cylinder screen and felt conveyor must be kept clean to in-
sure proper operation.  Cylinder showers spray water on the wire
surface after the mat has been removed by the felt.  Any cement or
fiber particles are washed out of the holes in the screen to pre-
vent "blinding".

The cylinders, mandrels, and accumulator rolls are occasionally
washed in acetic or hydrochloric acid to remove cement deposits.
This cleaning may be carried out while the machine is in operation
or the component, especially  cylinder screens, may be  removed  to a
separate acid washing facility.

The felt washing showers are a row of high pressure nozzles that,
with the aid of a "whipper", wash fiber out of the felt after the
mat of fiber has been picked up by the mandrel or accumulator
roll.  Fiber build-up in the felt can prevent vacuum boxes from re-
moving excess water from the mat.

In-Plant Recycling

Asbestos-cement product plants recycle the majority of their water
as a means of recovering all useable solids.  All water serving as
the carrying agent, 80 to 90 percent of the water in the process,
passes through a save-all after leaving the machine vat.  Solids
that settle out and concentrate near the bottom of the save-all
are pumped to the wet mixer to become part of a new slurry.  Much
of the clarified overflow from the save-all can be used for showers,
dilution, and various other uses depending upon the efficiency of
the save-all.

The save-all overflow may be discharged from the plant or may be
treated and returned to the plant for whatever uses its quality
justifies.  This may include water for wet saws, vacuum pump seals,
cooling, hydrotesting, or makeup water for plant startup.  If any
of these uses cannot be served by treated water, fresh water must be
                               26

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                                                            DRAFT
used since the quality and temperature of save-all overflow water
is rarely acceptable without additional clarification.

At most asbestos-cement product plants, part of the products that
are damaged or unacceptable for other reasons, are crushed, ground,
and used as filler in new products.  The remainder is crushed and
added to a refuse pile or landfill.

Asbestos-cement sheet plants trim the edges of the wet sheets as
they come off the accumulator roll.  The trimmings are immediately
returned to the wet mixer.  At this stage, the cement has not be-
gun to react and the trimmings can be an active part of the new
slurry.

Operating Schedule

Asbestos-cement pipe plants typically operate 24 hours a day and
five or six days a week.  Sheet plants may operate two shifts a
day rather than three depending upon market demand.

ASBESTOS PAPER

Asbestos paper has a great variety of uses and ingredient formulas
vary widely depending upon the intended use of the paper.  The
purchaser frequently specifies the exact formula to insure that the
paper has the desired qualities.

Raw Materials

Asbestos paper usually contains from 70 to 90 percent asbestos
fiber by weight, usually the short grades.  A mixture of the various
varieties of asbestos fiber is used with chrysotile as the principal
type.  The binder content of asbestos paper accounts for 3 to 15
percent of its weight.  The content and type varies with the desired
properties and intended applications of the paper.  Typical binders
are starch, glue, cement, gypsum, and several natural and synthetic
elastomers.

Asbestos paper used for roofing paper, pipe wrapping, and insula-
tion usually contains between 5 and 10 percent kraft fiber.  Mineral
wool, fiberglass, and a wide variety of other constituents are in-
cluded to provide special properties and may represent as much as
15 percent of the weight.

Manufacture

Asbestos paper is manufactured on machines of the Fourdrinier and
cylinder types that are similar to those which produce cellulose
(organic) paper.  The cylinder machine is more widely employed in
the industry today.  The overall manufacturing process is shown
in Figure 5 with waste sources indicated.
                                27

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                                                   DRAFT
        RAW MATERIALS
           STORAGE
        PROPORTIONING
WATER
STEAM
COOLING
WATER
                            RECYCLED SOLIDS
          STOCK CHEST
            METERING
             PAPER
            MACHINE
            DRYING
                                                   WASTEWATER
                                  CLARIFICATION
                                    (SAVE-ALL)
SLUDGE
(DUMP)
                                 COOLING WATER
                                 CONDENSATE
            STORAGE
           CONSUMER
              OR
         ROOFING PLANT
        Figure 5 - Asbestos Paper Manufacturing Operations

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                                                            DRAFT
The mixing operation combines the asbestos fibers with the binders
and any other minor ingredients.  A pulp beater or hollander mixes
the fibers and binder with water into a stock which typically con-
tains about three percent fiber.  Upon leaving the stock chest,
the stock is diluted to as little as one-half percent fiber in the
discharge chest.  The amount of dilution depends upon the quality
of the paper to be produced.

The discharge chest of a Fourdrinier paper machine deposits a thin
and uniform layer of stock onto an endless moving wire screen
through which a major portion of the water is drawn by suction
boxes or rolls adjacent to the sheet of paper.  The sheet is then
transferred onto an endless moving felt and pressed between pairs
of rolls to bring the paper to approximately 60 percent dryness.
Subsequently, the continuous sheet of paper passes over heated
rolls, while supported on a second felt, to effect further drying.
This is followed by calendering, to produce a smooth surface, and
winding of the paper onto a spindle.

The operation of a cylinder paper-making machine includes a mix-
ing operation for stock as indicated for the Fourdrinier machine.
Cylinder type paper machines usually have four to eight cylinders
instead of two as in most asbestos-cement pipe machines.

The stock is pumped to the cylinder vats of the machine.  Each vat
contains a large screen-surfaced cylinder extending the full length
of the vat.  The stock slurry flows through the screen depositing
a thin layer of fiber on the surface of the rotating cylinder before
flowing out through the ends of the cylinder.  The layer of fiber
is then transferred to a carrier felt moving across the top of the
rotating cylinders.  The layers picked up from the cylinders are
pressed together becoming a single homogeneous sheet as the felt
passes over each successive cylinder.

Vacuum boxes draw water out and pressure rolls squeeze water out
of the sheet and felt until the sheet is dry enough to be removed
from the felt.  After leaving the felt, the sheet is dried on
steam rolls and in ovens.  The paper is then calendered to pro-
duce a smooth surface and wound onto a spindle.

The width of the paper sheet is regulated by the deckles, a row
of nozzles located at each end of the cylinder screens.  The
deckles spray water on the screen at the edge of the sheet and
wash off excess fiber.

Gleaning

The cylinder showers are a row of nozzles that spray water on the
surface of the cylinder screens after the paper stock mat has been
removed by the felt.  They wash any remaining fiber and binder out
of the holes in the screens to prevent a build-up of fiber from
                                29

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                                                            DRAFT
"blinding" the screen and stopping the flow of water required to
deposit a layer of fiber on the surface of the cylinder.

The felt washing operations are carried out using high pressure
nozzles as in asbestos-cement pipe manufacture.

The asbestos-containing water, or "white water", which is removed
from the stock prior to passage across the heated drying rolls is
recycled to the process.

Water Usage

Water serves three basic purposes in the asbestos paper manufac-
turing process:  Ingredient carrier, binder wetting agent, and
heat transfer fluid.  Other uses include water for showers, decides,
pump seals, plant make-up, boiler make-up, and cooling.

Fresh water enters the system as boiler make-up, process make-up,
pump seal water, and shower water.  Boiler make-up water provides
steam for heating the paper stock and drying the finished paper.
The steam used to heat the stock slurry becomes a part of the slurry
and must be replaced.  Condensate from the drying rolls is recovered
and returned to the boiler.  Fresh water must be used to cool the
dried paper unless a cooling tower is available.  Save-all overflow
and other plant water is usually too hot for such purposes.  Large
quantities of fresh water are required during plant start-up to fill
the system.  This occurs infrequently, however.  Small quantities
of water are required continuously to replace that which evaporates
during drying and that which becomes a permanent part of the paper.
The characteristics of some paper products are such that fresh water
must be used for part, or all, of the beater make-up water.

Cylinder and felt washing showers usually require fresh water be-
cause save-all overflow water is rarely clean enough to be used in
the high pressure shower nozzles without causing plugging.  Fresh
water is used for the pump shaft seal water because the presence of
dirt in the seal water will cause plugging and can cause scoring of
the shaft.  Although the cooling water and part of the pump seal
water may be discharged from the plant after a single use, most of
the fresh water introduced into the plant enters the ingredient
carrying system and, therefore, the paper machine save-all loop.

In-Plant Recycling

The majority of the water in a paper plant serves as an ingredient
carrier and continually circulates in a loop through the paper
machine and the save-all.  All water flowing out of the cylinder
screen and that drawn by vacuum out of the wet paper sheet is
pumped to the save-all.  The solids settle to the bottom of the
save-all and are pumped to the stock chest of the beater.  Oc-
casionally, the solids from the save-all must be discharged from
the plant due to a product change, rapid setup of the binder, or
                                30

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                                                            DRAFT
a plant shutdown.  Save-all overflow water is used for "beater make-
up, dilution, deckle water, and occasionally shower water.

Excess overflow water mast be discharged from the plant or  sent to
a wastewater treatment facility for additional treatment before it
can be reused.

Trimmings from the edge of the paper, defective paper, and  other
waste paper can usually be returned to the beater and repulped for
recycling.

Operating Schedule

Asbestos paper manufacturing plants typically operate 24 hours a
day and 7 days a week.

MILLBOARD

Asbestos millboard is considered by some to be a very heavy paper
and is in fact very much like thick cardboard in texture and struc-
tural qualities.  It can easily be cut or drilled and can be
nailed or screwed to a supporting structure.

Raw Materials

Millboard formulas vary widely depending upon the intended  use of
the product.  Purchasers frequently specify the ingredients and
composition of the millboard to insure that the product meets
their particular requirements.  Asbestos content ranges between
60 and 95 percent with the higher content for products that will
be in close or direct contact with high temperature materials.
Portland cement and starch are the most common binders used and
represent 5 to 40 percent of the product.  Clay, lime, mineral
wool, and several other materials are frequently used as fill ma-
terial or to provide special qualities.  Water is also an impor-
tant ingredient in millboard.

Manufacture

The manufacturing steps in asbestos millboard production with waste
sources indicated are shown in Figure 6.  Millboard is produced on
small cylinder type machines similar to those used for making as-
bestos-cement pipe.  The machines are equipped with one or  two
cylinder screens, conveying felt, pressure rolls, and a cylinder
mold.  After the ingredients are mixed in a beater, the slurry is
transferred to a stirring vat or stock chest from which it  is di-
luted and pumped to the cylinder vats of the millboard machines.
Each cylinder vat contains a large screen surfaced cylinder extend-
ing the full length of the vat.  The slurry flows through the screen
depositing a mat of fiber on the surface of the rotating cylinder
before flowing out through the ends of the cylinder.  The mat of
                                31

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                                              DRAFT
  RAW MATERIALS
     STORAGE
  PROPORTIONING
                      RECYCLED SOLIDS
     FORMING
      DRYING
     TRIMMING


FINISHING
STORAGE
                             CLARIFICATION
                              (SAVE-ALL)
SOLIDS
                                              WASTEWATER
                 SLUDGE
                 (DUMP)
     CONSUMER
Figure 6 - Asbestos Millboard Manufacturing Operations

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                                                            DRAFT
fiber is then transferred to a carrier felt moving across the top
of the rotating cylinder.  On two-cylinder machines, the mats from
the first and second cylinders are pressed together becoming a
single homogeneous sheet as the felt picks up the mat of fiber from
the second cylinder.  Pressure rolls above the felt squeeze water
from the mat as it is picked up from the cylinders.  Some millboard
machines have vacuum boxes adjacent to the felt that draw water out
of the mat of fibers.  Additional pressure rolls remove more water
from the mat as it is wound onto the cylinder mold.

The cylinder mold is a drum about four feet wide and usually about
four feet in diameter.  As the carrier felt passes the cylinder
mold, the mat is transferred to the cylinder because the adhesion
to the wet cylinder surface is greater than the adhesion to the
felt.  The cylinder mold rotates, collecting successive layers of
fiber until the desired thickness is obtained.  The cylinder is
then momentarily stopped and the mat of fiber cut along a notch on
the surface of the cylinder parallel to the cylinder axis.  The
sheet of millboard is removed as the cylinder starts rotating to
build up another sheet.  The wet millboard, containing about 50
percent water, is air dried or moved into an autoclave or oven
for rapid curing.  Finished millboard usually contains 5 to 6 per-
cent water.

Cleaning

The operation of the deckles, cylinder showers, and felt washing
showers is basically the same as described previously for asbestos
paper.

Water Usage

The uses and flow patterns of water in millboard manufacturing
operations are very similar to those in asbestos paper making.

In-Plant Recycling

As with the asbestos products covered previously, most of the water
in the millboard manufacturing process serves as an ingredient carrier
and continually circulates in a loop through the millboard machine
and the save-all.  All water flowing out of the cylinder screen and
that drawn by vacuum out of the wet millboard is pumped to the save-
all.  Solids that settle in the save-all are pumped to the stock chest
or the beater.  Save-all overflow water is used for beater make-up,
dilution, deckle water, and occasionally shower water.  Excess over-
flow water must be discharged from the plant or sent to a treat-
ment facility for additional treatment before it can be reused.

When possible, trimmings from millboard sheets are returned to the
beater and repulped for use in new millboard.  Most millboards can
accept from 5 to 10 percent reclaimed material.
                                33

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                                                            DRAFT
Operating Schedule

A typical asbestos millboard plant operates two or three shifts per
day and five or six days a week.

ASBESTOS ROOFING

Asbestos roofing is made by saturating heavy grades of asbestos
paper with asphalt or coal tar with the subsequent application of
various surface treatments.  The stock paper may be single or mul-
tiple layered and usually contains mineral wool, kraft fibers, and
starch as well as asbestos.  Fiberglass filaments or strands of
wire may be embedded between layers for reinforcement.

Manufacture

Figure 7 shows the major steps in the manufacture of asbestos roof-
ing.  Asbestos paper is pulled through a bath of hot coal tar or
asphalt.  After it is thoroughly saturated, the paper passes over
a series of hot rollers to set the coal tar or asphalt in the paper.
The paper then passes over cooling rollers that reduce the tem-
perature of the paper and give it a smooth surface finish.  At some
plants, cooling water is sprayed directly on the surface of the
saturated paper.

Roll roofing is coated with various materials to prevent adhesion
between layers and then passed over a final series of cooling rol-
lers.  The roofing is then air dried and rolled up and packaged
for marketing.  The manufacture of asbestos roof shingles is simi-
lar from a wastewater point of view.

Water Usage

Water is used in two ways in the production of roofing.  It is con-
verted to steam to heat the saturating baths and hot rollers and
for cooling the hot paper after it has been saturated.  Condensate
from the saturating bath coils and the hot rollers is collected and
returned to the boilers.  Fresh make-up water in small quantities
is required to replace boiler blowdown water, steam, and conden-
sate that escapes through leaks.  Cooling water is used once and
discharged unless cooling towers or other means of cooling the
water are available.  The only process wastewater associated with
roofing manufacture is that originating in the spray cooling step.
In many cases, this contaminated contact cooling water is dis-
charged with the clean non-contact cooling water.

Operating Schedule

A typical roll roofing plant operates one or two shifts a day on
a five-day per week schedule.

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                                                 DRAFT
                ASBESTOS  PAPER
                    STORAGE
        HOT COAL TAR
        OR ASPHALT^
                  SATURATION
        STEAM
        COOLING
        WATER
                         FUMES
                HEAT TREATMENT
UNCOATED
ROOFING
        COOLING
        WATER
                        COOLING
                        WATER
COATING
                    COOLING
                        COOLING
                        WATER
                    CUTTING
                    ROLLING
                   PACKAGING
                    STORAGE
                   CONSUMER
     Figure 7 - Asbestos Roofing Manufacturing Operations
                        35

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                                                            DRAFT
FLOOR TILE

Most floor tile manufactured today uses a vinyl resin, although
some asphalt tile is still being produced.  The manufacturing pro-
cesses are very similar and the water pollution control aspects
are almost identical for the two forms of tile.

Raw Materials

Ingredient formulas vary with the manufacturer and the type of tile
being produced.  The asbestos content ranges from B to 30 percent
by weight and usually comprises very short fibers.  Asbestos is in-
cluded for its structural properties and it serves to maintain the
dimensional stability of the tile.  FVC resin serves as the binder
and makes up 15 to 25 percent of the  tile.  Chemical stabilizers
usually represent about 1 percent.  Limestone and other fillers
represent 55 to 70 percent of the weight.  Pigment content usually
averages about 5 percent, but may vary widely depending upon the
materials required to produce the desired color.

Manufacture

The tile manufacturing process, shown in Figure 8, involves several
steps; ingredient weighing, mixing, heating, decoration, calendering,
cooling, waxing, stamping, inspecting, and packaging.  The in-
gredients are weighed and mixed dry.  Liquid constituents, if re-
quired, are then added and thoroughly blended into the batch.  After
mixing, the batch is heated to about 150 degrees C and fed into a
mill where it is joined with the remainder of a previous batch for
continuous processing through the rest of the manufacturing operation.

The mill consists of a series of hot rollers that squeeze the mass
of raw tile material down to the desired thickness.  During the
milling operation, surface decoration in the form of small colored
chips of tile (mottle) are sprinkled onto the surface of the raw
tile sheet and pressed in to become a part of the sheet.  Some tile
has a surface decoration embossed and inked into the tile surface
during the rolling operation.  This may be done before or after cool-
ing.  After milling, the tile passes through calenders until it
reaches the required thickness and is ready for cooling.  Tile cool-
ing is accomplished in many ways and a given tile plant may use one
or several methods.  Water contact cooling in which the tile passes
through a water bath or is sprayed with water is used by some plants.
Others use non-contact cooling in which the rollers are filled with
water.  In some plants, the sheet of tile passes through a refrigera-
tion unit where cold air is blown onto the tile surface.  After cool-
ing, the tile is waxed, stamped onto squares, inspected, and packaged.
Trimmings and rejected tile squares are chopped up and reused.
                                36

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                                              DRAFT
        RAW MATERIALS
            STORAGE
        PROPORTIONING
STEAM
            MIXING
                      CONDENSATE
             FORMING
             ROLLING
COOLING
WATER
    a.
    oc
    a
    UJ
    o
    UJ
    oc
 COOLING
COOLING
WATER
FINISHING
 CUTTING
PACKAGING
 STORAGE
            CONSUMER
 Figure 8 - Asbestos Floor Tile Manufacturing Operations

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                                                            DRAFT
Water Usage

Water serves only as a heat transfer fluid.  It is used in the form
of steam to heat the batches and the hot rollers.  Fresh water is
required for boiler make-up, but only in quantities large enough to
replace leakage and boiler blowdown water.  Non-contact cooling
water remains clean and can be reused continually if cooling towers
or water chillers are available to remove the heat picked up from
the hot tile.

Make-up water is required only to replace water that leaks from the
system.  Direct contact cooling water from the cooling baths or
sprays does not become contaminated from direct contact with the
tile but may pick up dust or other materials.  This water may be
reused if facilities are available to clean the water and remove
the heat.  Fresh water is required to replace leakage and water
that evaporates.  Leakage from all sources collects dirt, oil, grease,
wax, ink, glue, and other contaminants.  This represents a serious
potential for pollution if discharged to a receiving water.

Operating Schedule

Floor tile plants typically operate 24 hours a day on a five or
six day per week schedule.
                                38

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                                                            DRAFT
                             SECTION V

               WATER USE AND WASTE CHARACTERIZATION
INTRODUCTION

Water is commonly used in asbestos manufacturing as an ingredient,
a carrying medium, for cooling, and for various auxiliary purposes
such as in pump seals, wet saws, pressure testing of pipe, and
others.  These uses are described in detail in following parts of
this section.  Water is used only for cooling in the manufacture
of asbestos roofing and floor tile products.  In the discussion
below, these two categories are not included unless specifically
mentioned.  In most asbestos manufacturing plants the wastewaters
from all sources are combined and discharged in a single sewer.

As described in detail in Section IV, asbestos manufacturing, in
almost all cases, involves forming the product from a dilute water
slurry of the mixed raw ingredients.  The product is brought to
the desired size, thiclmess, or shape by accumulating the solid
materials and removing most of the carriage water.  The water is
removed at several places in the machine and it, together with any
excess slurry, is piped to the save-all system.

The mixing operations are carried out on a batch, or semi-continuous,
basis.  Water and materials are returned from the save-alls as
needed during mixing.  Excess water and, in some cases, materials
are discharged from the save-all system.  Fresh water and additional
raw materials are added during mixing.  The fresh water is often
used first as vacuum pump seal water before going into the mixing
operations.

The major source of process wastewater in asbestos manufacturing
is the "machine" that converts the slurry into the formed wet pro-
duct.  It is not practical to isolate individual sources of waste-
water within the machine system.  The water is commonly transported
from the machine to the save-all system and back to the machine in
a closed system.  To measure the quantity of water flowing in the
machine-save-all recycle system involves a rather elaborate moni-
toring program that was beyond the scope of this study.  Only one
manufacturing plant provided data on in-plant water flows that were
more than rough estimates.  This information is presented below
under asbestos-cement pipe (Figure 9).  The relative amount of in-
ternal recycling in all asbestos manufacturing plants is signifi-
cant and of roughly the same relative proportion as detailed for
this pipe plant.

An important factor influencing both the volume and strength of the
                                39

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                                                            DRAFT
raw wastewaters is the save-all capacity in the plant.  Save-alls
are basically settling tanks in which solid-liquid separation is
accomplished by gravity.  Their purpose is first to recover raw ma-
terials (solids) and, second, water.  The efficiency of separation
is primarily dependent upon the hydraulic loading on the save-all.
Plants with greater save-all capacity have greater flexibility in
operation, more water storage volume, and a cleaner raw wastewater
leaving the manufacturing process.  In many asbestos manufacturing
plants, the solids in the save-alls are dumped when the product is
to be changed or when it is necessary to remove the accumulated
waste solids at the bottom.  It may also be necessary to dump the
save-alls when the manufacturing process is shut down.

The data used in developing the water usage and waste characteris-
tics information presented in the following parts of this Section
were derived from information supplied by the industry.  The results
from a sampling program at selected plants were used to verify, and
where necessary, supplement the industrial data.

ASBESTOS-CEMENT PIPE

Water Usage

The water balance at one asbestos-cement pipe plant was provided by
the plant personnel.  The values were verified in this study as far
as possible.  The balance is outlined diagrammatically in Figure 9.
The fresh water going into the pipe manufacturing machine is only
about one-quarter of the total used.  The rest is water recycled
from the save-all.  The percentage figures in Figure 9 are in terms
of the total water entering the manufacturing system, i.e., the
fresh water and that returned from the save-all.

Fresh water is used for wet saws, hydrotesting, cooling, sealing
vacuum pumps, and making steam for the autoclave as well as make-up
in the mixing unit.  Water is used with the saws to control dust and
fiber emissions to the air.  This is in contrast to the normally dry
lath operations that finish the pipe ends.

Hydrotesting is a routine procedure in which the strength of the
pipe is tested while full of water under pressure.  At some plants,
the hydrotest water is reused.

A pipe plant must remove solids from the bottom of the save-alls to
prevent their hardening into concretions.  At some plants, this
dumping and clean up is carried out when the manufacturing operations
are shut down for the weekend.  At other plants, dumping occurs more
frequently.

The reported wastewater discharge from 10 of the 14 asbestos-cement
pipe plants ranges from 76 to 2,080 cubic meters per day (0.02 to
.55 MGD).  The accuracy of these values is not known.  At a few loca-

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                                                         DRAFT
             FRESH OR
             TREATED
             WATER
         24 L/SEC
         (380 GPM)
           39 °/o
                    MAKE-UP, SAWS
                    HYDROTESTING
                    COOLING ,  ETC
TO TREATMENT
OR DISCHARGED
FROM PLANT
                                      14 L/SEC
                                      (225 GPM)
                                        23%
                                    PIPE
                                  MACHINE
                      10  L/SEC
                      (155 GPM)
                       16°/o
                                    REMAINS
                                    IN PIPE
               52  L/SEC
               (820 GPM)
                 83.5%
                                 SAVE-ALL
0.3 L/SEC
 (5GPM)
  .5%
                                                     38 L/SEC
                                                     (600 GPM)
                                                       61 %>
                                   14 L/SEC
                                   (220 GPM)
                                    22.5 %
24 L/SEC
(375 GPM)
 38.5%
                Figure 9 - Water Balance Diagram for a Typical
                            Asbestos-Cement Pipe Plant

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                                                            DRAFT
tions, there is little or no measurable discharge because of evap-
orative losses from lagoons.  Discharge records for a period of a
year or more were available at two pipe plants.  At one plant the
minimum flow was 65 percent of the average and the maximum was 145
percent.  The flow figures included cooling water from the manu-
facture of plastic pipe, however.  The maximum discharge at the
other plant, which produced only asbestos-cement pipe, was 670 per-
cent of the average.  The standard deviation in 403 values at this
plant was of the same magnitude as the average flow.

Waste Characteristics

The characteristics of raw wastewaters from asbestos-cement pipe
manufacturing were developed from sampling data from three plants
and reported values from one plant that provides minimal treat-
ment.  Two of the plants recirculated water from the external
treatment system back into the plant.  These plants tended to use
relatively much more water and the dissolved (filterable) solids
levels were much higher in the wastewaters from these plants.

Constituents—

The manufacture of asbestos-cement pipe in a typical plant increases
the levels of the major constituents in the water by the following
approximate amounts:

                              me/1         kg/MT      (Ib/Ton)

      Total solids            1,500        9           18
      Suspended solids          500        3.1          6.3
      BOD (5-day)                 2        0.01         0.02
      Alkalinity                700        4.4          8.8

The dissolved salts are reported to be primarily calcium and potas-
sium sulfates with lesser amounts of sodium chloride.  The magne-
sium levels are not known to be high.  The alkalinity is primarily
caused by hydroxide with a small carbonate contribution.  The pH
ranges as high as 12.9, but is generally close to 12.0,  or slightly
lower.

Temperature—The temperature fluctuations at a given plant are smal-
ler than the differences between plants.  The maximum raw waste temp-
erature measured in this study was 40 degrees C.  This plant recir-
culated some water from its treatment facility.  The average temperature
at two other pipe plants were 10 to 15 degrees C hotter than the intake
water.

Oil and grease—The oil and grease content of raw waste samples taken
at pipe plants was below detectable levels.  Reported data indicate
that at some plants there are measurable oil and grease levels in
                                42

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                                                            DRAFT
the final plant effluent.  This is believed to be from the equip-
ment rather than the process.

Organic matter—The organic content of pipe plant wastewaters is
normally low.  Some plants use organic acids (acetic) to clean the
mandrels and to remove scale in the plant.  This could contribute
BOD to the waste stream.  The waste acid is neutralized when mixed
with the highly alkaline process waste stream.  The high pH pre-
cludes the presence of any biological forms.

Plant nutrients—The measured and reported average levels of the
plant nutrients nitrogen and phosphorus in pipe plant effluents
were below 2.5 mg/1 and 0.05 mg/1, respectively.  There are uncon-
firmed peak values at individual plants of Kjeldahl nitrogen values
as high as 12 mg/1 and total phosphorus levels of 0.4 mg/1.

Toxic materials—The information on toxic constituents was derived
from reported data from a few individual plants.  Most plants did
not have data on every constituent.  Among the toxic constituents
reportedly measured in the effluents from some asbestos-cement
pipe plants are chromium, cyanide, mercury, phenols, and zinc.
Whether the origins of these materials are the primary raw materials
or additives used in small quantities, or both, is not known.

Color and turbidity—The raw wastewaters from pipe manufacture are
very turbid and of a gray-white color.  When the solids are re-
moved, the water has no color.

Fluctuations—The variations in raw waste loadings from a typical
plant are not known.  No plant measures or records the character-
istics of the raw wastewaters.  The wastewater treatment systems
are designed on hydraulic principles and their operational ef-
ficiency is largely independent of the strength of the influent
wastewater.

The changes in waste characteristics associated with start-up of
a pipe plant are minor and less than the normal fluctuations as-
sociated with operation.  When a pipe plant is shut down and the
save-alls dumped, there is released a heavy charge of suspended
solids in a short period of time.  Other parameters remain the same
or decrease slightly because of dilution by the flush water.  Grab
samples of raw pipe wastewaters collected during clean-up at one
plant gave results in the following ranges:

           Total solids             1,400 to 3,100 mg/1
           Suspended solids           300 to 2,900 mg/1
           Alkalinity                 540 to 2,000 mg/1

Fluctuations in raw wastewater quality should not cause serious
problems in the physical treatment facilities appropriate for pipe
plant wastes.
                                43

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                                                            DRAFT
ASBESTOS-CEMENT SHEET

Water Usage

No information is known to be available about the internal water
balance in an asbestos-cement sheet plant.  It is expected that
the percent recycle from the save-alls is roughly the same as for
asbestos-cement pipe (Figure 9).

The reported wastewater discharge from 4 of the 13 known sheet
plants ranges from 280 to 2,040 cubic meters per day (0.07 to .54
MGD).  The raw waste flows from the three sheet plants sampled
during this study were 570, 650, and 920 cu m/day (0.15, .17, and
.24 MGD).  The largest of the three values was from a plant that
discharges no effluent and, consequently, may use relatively more
water.

There are no known monitoring  records of discharge from asbestos-
cement sheet plants and no estimate of the minimum, maximum, and
variability of the flow from a plant can be made.

Waste Characteristics

The characteristics of raw wastewaters from asbestos-cement sheet
manufacturing were developed from sampling data from two plants.
No other data were available except that reported by one plant
using the wet press forming technique to make high-density sheet.
Since this product may include pigments and other additives and
since it is produced at only two known locations, neither of which
have adequate data, it is not properly included in this category.

Constituents—

The manufacture of asbestos-cement sheet products in a typical
plant increases the level of constituents in the water by the fol-
lowing approximate amounts:

                             me/1         kg/MT       (Ib/Ton)

     Total solids            2,000        15            30
     Suspended solids          850         6.5          13
     BOD (5-day)                 2         0.015         0.03
     Alkalinity              1,000         7.5          15

Little information is available on the dissolved salts in sheet
wastewaters, but they should be similar to those from asbestos-
 ement pipe manufacture.  The alkalinity is caused primarily by
hydroxide with a pH averaging 11.7 and ranging from 11.4 to 12.4
in all reporting plants.

Temperature—Meaningful temperature data was available from only
one sheet plant.  With a flow of 920 cu m/day (0.24 MGD), the tem-
                                44

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                                                            DRAFT
perature was increased 13 degrees C in the sheet manufacturing pro-
cess.  The reported peak summer temperatures of wastewaters dis-
charged from asbestos-cement sheet plants was 50 degrees C.

Oil and grease—The presence of oil and grease in wastewaters from
sheet plants has not been reported.  No measurable oil and grease
was found in the samples analyzed in this study.

Other constituents—The discussion regarding organic content, plant
nutrients, toxic constituents, turbidity and color, and fluctua-
tions of the characteristics of asbestos-cement pipe wastewaters
applies to those from asbestos-cement sheet.

ASBESTOS PAPER

Water Usage

The reported total wastewater discharges from 5 of the 12 asbestos
paper manufacturing plants range from 490 to 4,900 cubic meters per
day (0.13 to 1.3 MGD).  The accuracy of these values is not known.
The volumes of raw wastewater discharged to the treatment facility
at two plants visited in connection with this study were 1,700 and
2,700 cu m/day (0.45 and 0.72 MGD).  Many plants recirculate water
and solids from the wastewater treatment facility to the paper mak-
ing process and the effluent volume is considerably less than the
raw wastewater discharge.

Information about variability of flow is available from one plant
only.  This is the monitoring record of the treated effluent over a
recent eight-month period.  The average flow was 490 cu m/day (0.13
MGD) with minimum and maximum values of 430 and 755 cu m/day (0.14
and .20 MGD), respectively.  The standard deviation of the 113
readings taken during the period was 53 cu m/day (0.014 MGD).  The
exact quantities of water recycled from the save-all system and
from the waste treatment facility at this plant are not known.

Waste Characteristics

The raw wastewater characteristics from asbestos paper manufacturing
were developed from sampling data at two plants.  Both plants pro-
vide high levels of wastewater treatment with low volumes of effluent
discharge.  Consequently, the use of water within these two plants
may be higher than in plants that do not recycle treated wastewater.

Constituents—

The manufacture of asbestos paper in a typical plant increases the
levels of the constituents in the water by the following approximate
amounts:
                                45

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                                                            DRAFT
                                mg/1       keAff       (Ib/Ton)


      Total solids             1,900        26          52
      Suspended solids           680         9.5        19
      BOD (5 day)                110         1.5         3
      COD                        160         2.2         4.4

The pH of raw wastewaters from asbestos paper manufacturing is 8.0
or lower.

Temperature—The highest reported summer temperature value for
treated effluent is 32 degrees C.  It is believed that heated water
is used in mixing the raw materials at most plants, although at
least one uses cold water.  Recycled water tends to have a higher
temperature.

Oil and grease—Oil and grease was detected in only one of the
samples collected at the two paper manufacturing plants.   The level
was low, 1.2 mg/1, and was believed to be from plant equipment.
This type of material is not part of the product ingredients.

Organic matter—The oxygen demand is believed to be largely due to
the organic binders, i.e., starch or synthetic elastomers.  These
latter include several materials of different chemical compositions.

Nutrients—The total nitrogen levels reported in effluents from a
few paper plants averaged 16 mg/1, with the Kjeldabl fraction about
11 mg/1.  Phosphorus levels ranged from 0.25 to 1.0 mg/1.

Toxic materials—Trace amounts of copper, mercury, and zinc were
reported to be in the wastes from individual asbestos paper plants.

Color—The clarified wastewaters are taiown to have some color.  The
levels at two plants were 10 and 15 units.

Fluctuations—There was greater variability among the data from the
two paper plants than observed in most other asbestos manufacturing
operations.  There are no data on the variations in quality of raw
asbestos paper wastewaters other than the sampling results and these
were from too limited a period of time to be of value.  Results from
the monitoring program at one paper plant were cited above under
Water Usage.  Although they refer to treated effluent, they provide
some indication of the variability of the wastewater characteris-
tics, as follows:

                      Minimum     Average     Maximum    Std Dev'n

 Total solids        500 mg/1    685 mg/1    870 mg/1    260 mg/1
 Suspended solids     32          64          95          44
 BOD (5-day)          22          57          91          48
                                46

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                                                            DRAFT
Unlike asbestos-cement products plants, asbestos paper plants do
not use portland cement and the solids in the save-alls do not tend
to form concretions.  Shut-down is less regular and the plants tend
to operate around the clock.  Shut-downs are sometimes necessary
when changing products.  Since the elastomeric binders are not al-
ways compatible, the save-all solids may be dumped at these times.
There were no routine shut-down or start-up operations while the
paper plants were being sampled in this study and there is no infor-
mation on the characteristics of the raw wastewaters during these
periods.

ASBESTOS MILLBOARD

There are seven known locations where asbestos millboard is manu-
factured.  At all of these locations, the wastewaters are either
discharged to mnicipal sewers or are combined with other asbestos
manufacturing wastewaters.  Consequently, there is almost no in-
formation from the industry about the quantity and quality of mill-
board wastewaters.  The results presented below are based primarily
upon the sampling program carried out for this study at two plants.

Water Usage

The water leaving the save-all systems at the two plants amounted
to -41 and 136 cubic meters per metric ton (12,000 and 39,500 gal-
lons per ton).  One plant discharges its wastewaters to a large
lagoon system and recycles all of the lagoon effluent into the
plant.  This is a multi-product plant.  The other plant normally
recycles all of its save-all effluent.  Surges due to upsets or
shut-down are released to a municipal sewer.  Since neither plant
has any measurable effluent on a regular basis, the amounts of
water used in the manufacturing process may not be representative
of the amounts discharged by a plant that does not recycle its
wastewater.

Waste Characteristics

Constituents—

At the plant that discharges its wastewaters to the lagoon system,
the constituents added to the water were measured as follows:

                               me/I       kg ACT    (Ib/Ton)

        Suspended solids        35        1.8         3.5
        BOD (5-day)              5        0.25        0.5

The total solids and COD levels in the water leaving the millboard
save-alls were the same as those of the make-up water.  The pH of
the raw wastewater ranged from 8.3 to 9.2.  Some millboard is manu-
factured with portland cement and the pH would be higher in such cases.

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                                                            DRAFT
The effluent from the save-all system at the millboard plant that
operates with a completely closed water system had the character-
istics listed below.  In such a plant, the waste constituents ac-
cumulate until a steady-state level is reached.  The contribution
of each manufacturing cycle cannot be determined directly,and,
consequently, raw waste loadings expressed in terms of production
units are meaningless.

                             Average              Range

     Total solids          6,100 mg/1      3,950 to 7,800 mg/1
     Suspended solids      5,100           3,060 to 6,270
     BOD ( 5-day)               2
     COD                      60              10 to
The pH ranged from 11.8 to 12.1 and the alkalinity from 2,000 to
2,700 mg/1, mostly in the hydroxide form.

Temperature—The temperatures of the raw wastewaters at the two
sampled millboard plants were 12 and 26 degrees C, with the higher
temperature measured at the completely closed system.  The high-
est reported summer temperature of the effluents at two other mill-
board plants was 31 degrees C.

Other constituents—Small amounts of oil and grease, nitrogen, and
phosphorus were detected in some of the samples collected in this
study.

No information is available from the millboard industry on the
presence of plant nutrients, toxic constituent, or about the nature
of the additive materials that are used in the many varieties of
millboard.

Fluctuations—No information is available by which to accurately
estimate the degree of fluctuation in millboard wastewater charac-
teristics.  Judging from the differences in the two plants that
were sampled and from the relatively broad range of raw materials
used, the variability of wastewaters from millboard manufacture is
high.

ASBESTOS ROOFING

Unlike the asbestos products covered previously, water is not an
integral part of roofing products.  It is used, however, to cool
the roofing after saturation.  All plants use non-contact cooling
and some use spray contact cooling.  The roofing is largely, but
not completely, inert to water and the contact cooling water be-
comes a process wastewater.  This contaminated cooling water is
discharged with the non-contact cooling water in some plants, re-
sulting in a large volume of dilute process wastewater.

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                                                            DRAFT
Water Usage

The discharge volumes vary widely among the few roofing plants that
reported information on flows, ranging from 145 to 2,100 liters per
metric ton (35 to over 500 gallons per ton) of product.  The origi-
nal temperature of the cooling water, whether it is once-through or
recirculated, and whether non-contact water is included are factors
influencing the reported amount of water discharged.  The fluctua-
tions in flow rate should be minimal at a given location.

Waste Characteristics

The characteristics of spent cooling water from roofing manufacture
are developed from sampling data taken at one plant.  This plant em-
ploys surface sprays and discharges the contact and non-contact
cooling water into a common sewer.  The combined wastewater was
sampled.  At the time of sampling, the roofing was being made from
organic (non-asbestos) paper.  Since the water spray contacts only
the outer bituminous surface and not the base paper, it is believed
that the samples are representative of wastes from contact cooling
of asbestos-based roofing.

The added quantities of the major constituents were as follows:

                               me/1        kg ACT      (Ib/Ton')

        Suspended solids        150        0.06         0.13
        BOD (5-day)               6        0.003        0.005
        COD                      20        0.008        0.016

The pH of the wastewater averaged 8.2.

Temperature—The temperature of the spent cooling water was 13 de-
grees C, a 7-degree increase over the temperature of the intake
water at a flow rate of about 1,420 cubic meters per day (0.375 MGD).

Supplemental data—Information about the effluents from one other
asbestos roofing plant was reported by the manufacturer.  The waste-
water is treated by settling, oil skimming, and passage through an
adsorbant filter.  The added quantities of materials are reported
to be:

                               me/1       kg/kT     (Ib/TcaO

        Suspended solids        37        0.06        0.12
        BOD (5-day)             38        0.07        0.13
        COD                     91        0.15        0.30

The average pH of the effluent is reported to be 6.8.

Other constituents of interest were measured in this treated effluent
                                49

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                                                            DRAFT
with the following average results in terms of added quantities:

                               mg/1        kg/kT      (Ib/Ton)

     Total Solids              93         0.16         0.31
     Total Organic Carbon       1         0.0015       0.003
     Cyanide                    0.03      0.00005      0.0001
     Copper                    19         0.03         0.06
     Iron                      31         0.05         0.10
     Lead                       1         0.0015       0.003
     Nickel                     3         0.005        0.010
     Zinc                      71         0.12         0.24
     Oil and Grease             1.6       0.0025       0.005
     Phenols                    3         0.005        0.010

Total nitrogen and phosphorus levels in the cooling water were each
increased about 0.5 mg/1 by passage through the plant.  Arsenic,
cadmium, and chromium were analyzed for but not detected in the ef-
fluent.

The above information on treated roofing wastewaters is presented
as supplemental data.  It has not been verified, but it does pro-
vide an insight into the strength and character of the wastewaters
from asbestos roofing manufacture.

Fluctuations—There is insufficient information to describe varia-
tions in the characteristics within a plant or among plants in
this category.  Since the wastewater is spent cooling water, its
characteristics should be unaffected by start-up and shut-down opera-
tions.

ASBESTOS FLOOR TILE

From a water use and wastewater characterization point of view,
vinyl and asphalt tile manufacturing both produce the same result.
Like roofing, water is used only for cooling purposes.  Both con-
tact and non-contact cooling are usually employed.  Water does not
come into contact with the tile until it has been heated and rolled
into its final form.  In this stage it is completely inert to
water.

Water Usage

Cooling water usage information was available from six floor tile
plants with an average daily production of about 400,000 pieces.
The reported discharges ranged from about 80 to 1,700 liters (21 to
450 gallons) per 1,000 pieces with an average of 1,130 liters (300
gallons).

The wide range reflects differences in intake water temperatures,
whether or not the water is recirculated, and whether both contact
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                                                            DRAFT
and non-contact waters are Included in the figures.  Because the
water is used for cooling, fluctuations within a given plant should
not be large and should primarily be the result of changes in pro-
duction levels or seasonal temperature changes, or both.

Waste Characteristics

Despite that floor tile itself is inert in water, the contact cool-
ing water becomes contaminated with a diverse variety of materials
including wax, inks, oil, glue, and miscellaneous dirt and debris.
The material has a high organic content although the limited data
available indicate that it is not readily biodegradable.

Constituents—

The added waste constituents in a typical floor tile plant are as
follows:

                             mg/1       kg/1000 DC   (lb/1000 PC)

      Suspended solids        150          0.18          0.40
      BOD (5-day)              15          0.02          0.04
      COD                     300          0.36          O.SO

The reported pH of tile plant wastewaters ranges from 6.9 to 8.3,
averaging 7.3.

Temperature—The reported temperature data are inconsistent among
the few plants reporting.  Some plants with large per unit flow
volumes show a larger temperature increase than plants with much
smaller flows per 1,000 pieces.

Oil and grease—Oil and grease is reportedly present in tile plant
effluents, with maximum concentrations of 15 mg/1 after treatment.

Organic matter—The COD is believed to be largely associated with
the suspended solids with much of it being wax.

Plant nutrients—The limited data on plant nutrients indicate that
the increased total nitrogen and phosphorus levels should be less
than 5.0 and 1.5 mg/1, respectively.

Toxic materials—Phenol levels as high as 0.2 mg/1 were reported
by one plant.  One plant reported a maximum chromium level of 15
mg/1 and undetectable amounts of cadmium and zinc.

Color and turbidity—Data on the color and turbidity of wastewaters
from floor tile manufacture are not available.  The wastes do have
measurable levels of both parameters, however.
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                                                            DRAFT
Fluctuations—There are no taiown data by which to assess the varia-
tions in constituent concentrations in wastewaters from floor tile
plants.
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                                                            DRAFT
                              SECTION VI

                   SELECTION OF POLLUTANT PARAMETERS
SELECTED PARAMETERS

The chemical, physical, and biological parameters that define the
pollutant constituents in wastewaters from the asbestos manufactur-
ing industry are the following:

          Suspended solids
          BOD
          COD (or TOC)
          PH
          Temperature
          Dissolved solids
          Nitrogen
          Phosphorus
          Phenols
          Toxic materials

The last four listed parameters are not normally present in high
concentrations.  Individual plants have reported significant levels
of one or more in their effluents, however, and they are therefore
included.

Asbestos itself is not included in the list for several reasons.
There is no standard procedure for detecting or measuring the fiber
levels in water.  The effects of asbestos in water on human or aqua-
tic life are unknown.  It is likely that most of the fibers in
wastewaters are associated with other solids and it is expected
that control of other pollutants will significantly reduce the
fiber levels in treated effluents.

Pollutants in non-process wastewaters, such as discharges from non-
contact cooling systems, boiler blowdown, and wastes from water
treatment facilities are not included in this document.

The rationale for selection of the listed parameters is given below.
In the following paragraphs, the terms used to describe the levels
of the various parameters are relative within this industrial cate-
gory.  For example, a BOD level of 100/mg/l is high for asbestos
manufacturing wastewaters, but is low compared to many industrial
wastes.
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                                                            DRAFT
RATIONALE FOR SELECTION

The reasons for including the above listed parameters are briefly
presented below.  The reader is referred to other sources (Section
XIII) for descriptions of the parameters and procedures for
measuring them.

Suspended Solids

The suspended solids levels in raw asbestos manufacturing waste-
waters are often high with levels commonly in the 500 to 1,000/mg/l
range.  The solids are heavy and settle quickly.  They would produce
sludge deposits on the bottom of receiving water bodies if dis-
charged.  The solids could also contribute turbidity and possible
harm aquatic life if suspended in receiving waters.  The fiber con-
tent of the solids is reported to be relatively low, with the bulk
of the solids originating as cement, silica, clay, and other raw
materials.

Biochemical Oxygen Demand (BOD)

The BOD levels in wastes from asbestos-cement, roofing, and floor
tile product manufacture are usually very low.  Important BOD con-
tributions originate with the natural organic binders used in some
asbestos papers and millboards.  The typical maximum levels are
about 100 mg/1.

Chemical Oxygen Demand (COD)

Moderately high COD values are typically associated with raw waste-
waters from asbestos paper, roofing, and floor tile manufacturing.
The binders used in paper are believed to be the major source of
COD.  The elastomeric binders result in high COD results, but con-
tribute little BOD.  In other words, they are not readily biode-
gradable.  The COD in roofing wastewaters is caused by soluble
bitumens, phenols, oil and grease from bearings, and other materials
that contaminate the contact cooling water.  It is believed that
wax contributes the major portion of COD in raw wastewaters from
floor tile production.

EH

Raw wastewaters from products that contain portland cement normally
have an elevated pH value.  The pH of asbestos-cement wastes is
close to 12 or higher.  This indicates a caustic (hydroxide) alka-
linity that should be neutralized before discharge to receiving
waters or municipal sewers.  Highly caustic waters are harmful to
aquatic life.

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                                                            DRAFT
Temperature

Thermal increases are caused by chemical reactions, heating, and
contact cooling in various parts of the asbestos products industry.
Reported temperatures for effluents reach maximum levels of 38
degrees C (100 degrees F).  Recirculated water is relatively hotter
than that which is used once and discharged.

Dissolved Solids

In addition to the high suspended solids levels in most raw waste-
waters from asbestos manufacture, the dissolved (filterable) solids
are often of equal or greater magnitude.  These originate primarily
with the major raw materials, i.e., cement, clays, etc.  Sulfates
are reported to be one of the major dissolved components in the
case of asbestos-cement products.  The levels in some plant efflu-
ents are high enough to be of concern in public water supplies if
not adequately diluted by the receiving water.

Nitrogen

Nitrogen levels in raw wastewaters from asbestos manufacturing are
normally not high, with reported maxima for total nitrogen of about
15 mg/1.  It is included here because nitrogen at this level could
influence eutrophication rates in some water bodies.

In some cases, the sources of nitrogen are the minor ingredients
and additives in the product, rather than the principal raw mater-
ials.  These secondary ingredients are subject to change and the
nitrogen levels in the wastewater should be monitored to insure that
excessive levels are absent.

Phosphorus

Maximum phosphorus levels in asbestos wastewaters are typically in
the 1 to 2 mg/1 range.  Like nitrogen, this element can influence
eutrophication and should be monitored to insure that levels are
acceptably low.

Phenols

The presence of measurable phenol levels have been reported in
wastes from roofing manufacture.  These chemicals cause serious
taste and odors in water supplies and their entry to the waste
stream and the plant effluent should be controlled.

Toxic Materials

Individual plants have reported that one or more of the following
metals were present in their effluents; barium, cadmium, chromium,
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                                                            DRAFT
copper, mercury, nickel, and zinc.  Two pipe plants reported that
cyanides were present in their wastes.  In most cases, these
materials were at levels below those specified as safe for drinking
water.  There was no consistent pattern detected among the limited
data available.  These materials may originate in the major raw
materials or in the minor ingredients and additives.  Excessive
effluent levels could probably be most economically controlled by
changing or elimination of the source.
CRITICAL PARAMETERS

The critical parameters that should be measured regularly on waste-
waters discharged from asbestos manufacturing plants are the following:

          Suspended solids
          PH
          Temperature

The COD (or Total Organic Carbon content) of wastewaters from paper,
roofing, and floor tile plants should also be monitored regularly.
The other listed parameters should be measured regularly, but on a
less frequent schedule.
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                                                            DRAFT
                            SECTION VII

                 CONTROL AND TREATMENT TECHNOLOGY
INTRODUCTION

Those parts of the asbestos manufacturing industry covered in this
document fall into two groups; (l) asbestos-cement products and as-
bestos paper and millboard, and (2) roofing and floor tile.  The
wastewaters from the second group are contaminated contact cooling
waters and are relatively smaller in volume.  The level and type
of control and treatment measures for roofing and floor tile plants
are different than those for the product categories in the first
group.  Most of the general material below applies directly only
to the plants in the first group.

Waste Characteristics

The process wastewaters from the manufacture of asbestos-cement
products, paper, and millboard represent the major sources of
pollutant constituents in the asbestos manufacturing industry.  The
•wastes originate from several points in the manufacturing processes
and they are usually combined into a single discharge from the plant,
The wastes from all of these categories are similar in many charac-
teristics and they are amenable to treatment by the same operation,
namely, sedimentation.  Because of similarities in manufacturing
processes, many in-plant control measures apply at all locations.

Treatment

Sedimentation, with various auxiliary operations, yields an efflu-
ent of low pollution potential when properly applied to asbestos
manufacturing wastewaters.  The settled solids are inert, dense,
and appropriate for landfill disposal.  While present practices
within the industry are not achieving the best possible results
in all cases, they can be upgraded -without major technical problems.

Treatment beyond sedimentation and pH control is not appropriate
for wastes from the major product categories in the asbestos
manufacturing industry.  The only pollutant constituent remaining
at significant levels, other than temperature, is dissolved solids.
While these levels may be at undesirably high levels for certain
industrial water uses, they do not present serious hazards to human
health or to aquatic life.  To remove the dissolved solids burden
in these wastewaters would require advanced treatment operations
techniques, e.g., reverse osmosis, electrodialysis, or distillation.
The initial and annual costs associated with these advanced treat-
ment operations are so high that alternative solutions, namely,
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                                                           DRAFT
complete recycle of wastewaters, will be implemented by the
industry instead of further treatment.

During the course of the study carried out to prepare this docu-
ment, representatives of at least six of the companies listed in
Section III volunteered the information that complete recircula-
tion of process wastewaters was presently under consideration,
being developed, or actively being implemented.

Implementation

The in-plant control measures and end-of-pipe treatment technology
outlined below can be implemented as necessary throughout the
asbestos manufacturing industry.  Factors relating to plant and
equipment age, manufacturing process and capacity, and land
availability do not play a significant role in determining whether
or not a given plant can make the changes.  Implementation of a
particular control or treatment measure will involve approximately
the same degree of engineering and process design skill and will
have the same effects on plant operations, product quality, and
process flexibility at all locations.

IN-PLANT CONTROL MEASURES

Many asbestos manufacturing plants incorporate some in-plant
practices that reduce the release of pollutant constituents.  These
practices have resulted in economic benefits, e.g., reduced water
supply or waste disposal costs, or both.  Few plants include all
of the control measures that are possible, however.

Raw Material Storage

Raw materials are normally stored indoors and kept dry.  There are
no widespread water pollution problems related to improper raw
materials storage practices.

Wastewater Segregation

In all cases, sanitary sewage should be disposed of separately from
process wastewaters.  Public health considerations as well as econ-
omic factors dictate that sanitary wastes not be combined with as-
bestos process wastes.

Other non-process wastewaters are often combined with manufacturing
wastes in asbestos plants.  A careful evaluation should be made in
each plant to determine if some or all of these wastes could be
segregated and recirculated.  Such reduction in waste volumes might
result in smaller, more economical waste treatment facilities.

Housekeeping Practices

Except for roofing and floor tile plants, housekeeping practices

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                                                          DRAFT
do not greatly influence the wastewater characteristics.  The
use of wet clean-up techniques are common to control fiber and
dust air emissions.  In view of the alternative, continuation
of the proper use of such wet methods should not impair the
efficiency of end-of-pipe treatment facilities.

Water Usage

Fresh water should be used first for pump seals, steam generation,
showers, and similar uses that cannot tolerate high contaminant
levels.  The discharges from these uses should then go into the
manufacturing process as make-up water and elsewhere where water
quality is less critical.

Water conservation equipment and practices should be installed to
prevent overflows, spills, and leaks.  Plumbing arrangements that
discourage the unnecessary use of fresh water should be incorporated.

Plans should be made for complete recirculation of all wastewaters.
This will permit the installation of new equipment and the making
of the plant alterations as part of an integrated, long-range
program.  In some cases, it may be more economical for a given
plant to move directly toward complete recirculation rather than
install extensive treatment facilities.

In line with water use practices, evaluation of the benefits of
increased save-all capacity should be made at some plants.  This
•would provide more in-plant water storage, permit greater operating
flexibility, and reduce the level of pollutant constituents in the
raw wastewaters discharged from the plant.

Product Categories

In-plant control measures applicable to specific asbestos product
manufacturing operations are given below.

Asbestos-cement pipe—

Some pipe plants completely recirculate the water used in the hydro-
test operation.  Some plants reuse part of the autoclave condensate
directly.  Consideration should be given to piping wastewaters from
wet saws to the save-all system.

At least one pipe plant recycles a major fraction of the effluent
from its waste treatment facility back into the manufacturing process,

No plant making only asbestos-cement pipe has accomplished complete
recirculation.  A reported experimental attempt to do so by one
company was not successful.

The raw wastewater flow from asbestos-cement pipe manufacture is
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                                                            DRAFT
typically in the range of 4.1 to 5.2 cubic meters per metric ton
(1200 to 1500 gallons per ton) of product.

Asbestos-Cement Sheet Products—

Many of the in-plant control measures described above for pipe
plants could be incorporated in sheet plants.  The raw wastewater
flow from sheet manufacture is typically in the range of 5.2 to
6.2 cu m/MT (1500 to 1800 gal/ton).

One asbestos-cement sheet plant achieves complete recirculation
most of the time.  The manufacturing process is so balanced that
the fresh water intake equals the amount of water in the wet pro-
duct.  Fresh water enters the system only for boiler make-up and
as part of the vacuum pump seal water.  This plant is connected to
a municipal sewer and excess flows caused by upsets and process
shut-downs are discharged intermittently.  With sufficient holding
capacity to accommodate these surges, discharge to the sewer could
be eliminated.

The benefits of complete recycle at this plant include reduced
water cost and sewer service charges, minimal asbestos loss, and
possibly, a stronger product.

The major problem encountered in complete water recycle at this
plant is scaling.  Spray nozzles require occassional unplugging,
the water lines are scoured regularly with a pneumatically driven
cleaner, and fine sand is introduced into the pumps to eliminate
deposits.

While one sheet plant has accomplished almost complete recircula-
tion, this is not regarded as fully demonstrated technology.  This
plant makes only a few asbestos-cement sheet products.  The inter-
mittent discharge to the sewer does provide some blowdown relief
to the system.  Whether such complete recirculation could be applied
to plants making sheet products with more stringent quality speci-
fications is not known.  The progress at this plant does indicate
that complete recirculation is a realistic goal for the future.

Asbestos Paper—

The in-plant control measures outlined above for asbestos-cement
pipe can be applied in part in asbestos paper making plants.  One
paper plant has been able to close up its process water system when
making paper with a starch binder.  Such operation is not possible
when elastomeric binders are used and excess water is then dis-
charged to the municipal sewer.

An asbestos paper plant that practices partial recycle of water from
its waste treatment unit typically discharges within 30 percent of
11 cu m/MT ( 3,300 gal/ton).
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                                                            DRAFT
Partial recycle of water and underflow solids from the wastewater
treatment facility is not uncommon in the asbestos paper industry.
Complete recirculation and zero discharge has not been demonstrated
on a continuing basis at any plant making only paper.  It is likely
that paper could be manufactured using a closed system if only
starch binders were used.  Total and continuous recycle of water
and solids when using elastomeric binders cannot be accomplished
today.  Since some paper plants use both types of binders, a guide-
line based on the type of binder used would be impractical.

That significant recycle of wastewater has been accomplished indi-
cates that complete recirculation is a possible goal for the future.

Asbestos Millboard—

One plant that produces a wide variety of millboard products with
a relatively small save-all system presently achieves almost com-
plete recycle of the process water.  The stimulus at this location
was, at least in part, high costs for water and sewer services.
The plant releases save-all overflow to the municipal sewer when
upsets or product changes occur.  With greater save-all capacity
or a holding tank, this plant could accomplish zero discharge on
a continuous basis.

In connection with this study, four of the seven known millboard
plants in the country were visited.  Since almost complete recir-
culation has been demonstrated in a typical plant, it is believed
that zero discharge can be achieved soon by millboard manufacturing
plants.

Asbestos Roofing—

The plants that practice contact cooling should evaluate the pos-
sibility of eliminating this source of process wastewater.  If
this were done, and leaks and other losses of non-contact cooling
were closed and dry cleaning practices instituted, the asbestos
roofing industry would be able to operate without the discharge
of process wastewaters.

In any case, non-contact cooling water and condensate should not
be mixed with contact cooling water.  This practice greatly in-
creases the volume of process wastewater to be treated.

Asbestos Floor Tile—

There are several in-plant measures that should be used in floor
tile plants to control the release of pollutant constituents.  Raw
materials should be stored, measured, and mixed in an area completely
isolated from the cooling water systems.  Only after the ingredients
are made into tile are they insoluble in water.  Toxic materials
should be eliminated from the tile ingredients.
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                                                            DRAFT
If possible, contact water cooling operations should be eliminated.
If this is not feasible, the contact cooling water should be pro-
tected from contamination.  Bearing leaks should be controlled and
escaping water protected from contact with wax, oils, glue, and
other dirt.

If the contact cooling water and the non-contact cooling water that
escapes were prevented from becoming contaminated, it would be much
easier to treat.  This contamination is unnecessary and the result-
ing process wastewater is costly to treat.

TREATMENT TECHNOLOGY

Most asbestos manufacturing plants currently provide some form of
treatment of the raw wastewaters before discharge to receiving waters.
In virtually all cases, this treatment is sedimentation.  At several
plants, the treatment facilities are small and of simple design.
Fortunately the waste solids are dense and almost any period of de-
tention will accomplish major removal of the pollutant load.

Technical Considerations

Sedimentation is the oldest of all treatment unit operations in
sanitary engineering practice.  It is well understood and its costs,
ease of operation, efficiency, and reliability make it ideally
suited for industrial application.

Application—

Sedimentation is an appropriate form of treatment for asbestos manu-
facturing plant wastewaters regardless of the plant size and capacity,
manufacturing process, or plant and equipment age.  Design is based
on the hydraulic discharge and plants with smaller effluent volumes
can use smaller units.  The treatment system can be sized to accom-
modate surges and peak flows efficiently.  Because waste asbestos
solids are inert biologically, overdesign does not result in solids
management problems.

Land Requirements—

If necessary, complete settling facilities large enough to treat
the waste flows from any asbestos manufacturing plant can be placed
on an area of 0.1 hectare (0.25 acre) or less.  If more land is
available, larger units that provide solids storage may be con-
structed.  Such units would result in lower operating costs.  This
design is especially appropriate for wastewaters from asbestos-
cement manufacture because the solids are inert.  Solids with sig-
nificant BOD levels may require more prompt reuse or dewatering
and disposal.
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                                                            DRAFT
The land requirements for asbestos solids disposal are not exces-
sively high.  Some plants have disposed of solids within relatively
limited "boundaries for decades.  While this practice results in
problems it does serve to indicate that land disposal, if properly
carried out, is an appropriate means of disposing of waste solids
from asbestos manufacturing.

Compatibility of Control Measures—

The recommended end-of-pipe technology for the industry is sedimen-
tation, with ancillary operations as necessary.  The subsequent
control technology recommended is complete recirculation of all
process wastewaters from all categories of asbestos manufacturing
covered by this document.  In most cases, complete recycle will
require that the save-all system be expanded or supplemented to
provide higher quality water for some in-plant uses.  The waste-
water treatment facility could very readily serve this function.

Consequently, the recommended end-of-pipe control technology wou3d
represent part of an overall long-term control program to achieve
zero discharge of pollutant constituents at most locations.

Product Categories

Control and treatment technologies that are applicable to spe-
cific product categories of the asbestos manufacturing industry
are described below.

Asbestos-Cement Products—

The applicable end-of-pipe technology for wastewaters from the manu-
facture of asbestos-cement products, both pipe and sheet, is sedi-
mentation and neutralization.  Designs based on total detention
periods of 6 to 8 hours or loading levels of 24 cubic meters per
day per square meter (600 gallons per day per square foot) of sur-
face area yield effluent suspended solids levels of 30 mg/1 or
lower.

Neutralization to a pH level of 9.0 or below has been achieved at
two locations in the industry by adding sulfuric acid or on-site
generated carbon dioxide.  At both of these locations, sedimenta-
tion precedes and follows neutralization.

The solids removed by the settling units are best dewatered by
gravity thickening.  They are dense and biochemically inert and
are suitable for disposal by proper landfill disposal techniques.

To achieve complete recirculation of process wastewaters, surge
capacity will have to be added to the water system.  A sedimenta-
tion unit cannot function in this capacity.  A water storage tank
or reservoir would be required in the system.  With complete re-
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                                                            DRAFT
cycle, the neutralization operation will not be required.  Its func-
tion is to protect the receiving water.  High pH levels are not a
problem in the manufacture of asbestos-cement products.  As noted
in a previous section, additional scale control measures are neces-
sary when complete recycle is implemented.

As noted above, complete recirculation of asbestos-cement sheet
process water has been demonstrated partially.  Problems with pro-
duct strength have been reported in one effort to completely re-
cycle wastewater from asbestos-cement pipe manufacture.  Additional
research is needed to achieve this level of control.

Asbestos Paper—

The applicable end-of-pipe technology for wastewaters from the
manufacture of asbestos paper is sedimentation preceded, as neces-
sary, by grit removal and coagulation with polyelectrolytes.  This
treatment has been demonstrated at three or more locations.  Units
designed for a loading of 24 cubic meters per day per square meter
(600 gallons per day per square foot) have achieved suspended solids
and BOD reductions to 25 mg/1 or less.

Most of the settled solids as well as part of the clarified water
should be recycled from the settling unit to the manufacturing pro-
cess at paper plants.  The waste solids, which are normally kept
to a minimum, may be stored for later use or dewatered for land
disposal with the grit.  Waste solids result, in part, from the in-
compatibility of certain synthetic binders.

To achieve complete recycle of all process wastewaters at asbestos
paper plants, surge capacity will be required.  A water storage
tank will be required because the sedimentation unit cannot pro-
vide this function.

As noted above, complete recirculation of asbestos paper process
water has been demonstrated partially when starch is used as the
binder.  Additional research is needed to achieve this level of
control when using elastomeric binders.

Asbestos Millboard—

As discussed above under In-Plant Controls, the applicable control
measure for asbestos millboard plants is complete recycle of all
process wastewaters.  No end-of-pipe technology is specifically
required if the plant's save-all capacity is adequate.  Unlike
settling tanks, save-alls can provide surge capacity.

Waste solids will normally be generated only when the plant is
shut down.  These will require dewatering and transportation to a
land disposal site.  Since asbestos millboard manufacturing opera-

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                                                            DRAFT
tions are located in plants that make other asbestos products, the
best means of solids handling and disposal will be dependent on the
methods used for solids from the other product lines.

Asbestos Roofing—

The applicable end-of-pipe technology for asbestos roofing waste-
waters is sedimentation with skimming or filtration as necessary to
remove insoluble materials.  Properly designed and operated facili-
ties should reduce the suspended solids levels to 15 mg/1 and COD
to 20 mg/1 or less.  If the organic materials are not adequately
removed, further treatment, possibly by activated carbon adsorption,
will be required.  There is, at present, no information available
by which to assess the suitability or efficiency of such treatment
for these wastes.  Information is lacking on the nature of the dis-
solved organics in wastewaters from asbestos roofing manufacture.

To completely eliminate the discharge of pollutant constituents
will require that the contaminated cooling water that constitutes
the process wastewater be treated, cooled, and reused.  As noted
above, the precise type and extent of treatment required is not
known due to lack of information.

An alternative solution would be the elimination of contact cooling
and confinement of leaks so that the water remains uncontaminated.

Asbestos Floor Tile—

The applicable end-of-pipe technology for floor tile manufacturing
wastewaters is sedimentation with coagulation and skimming as neces-
sary to remove suspended solids.  It is believed that the high COD
levels associated with some tile plant wastes are caused by in-
soluble materials.  Properly designed and operated facilities should
reduce suspended solids levels to 30 mg/1 and COD to 75 mg/1 or less.

The wastes from different tile plants are somewhat different and
the precise technology required to achieve these levels cannot be
predicted.  At present, treatment beyond plain sedimentation and
skimming is not practiced by the industry.  Sorption on activated
carbon following filtration should remove soluble organic materials
to an acceptable level.
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                           SECTION VIII

            COST, ENERGY, AND NON-WATER QUALITY ASPECTS
COST AND REDUCTION BENEFITS OF ALTERNATIVE TREATMENT AND CONTROL
TECHNOLOGIES

A detailed analysis of the estimated costs and pollution reduction
benefits of alternative treatment and control technologies applicable
to the asbestos manufacturing industry is given in Appendix A of this
document.  The basic results for each product category are summarized
below.

Asbestos-Cement Pipe

Alternative A - No Waste Treatment or Control

Effluent waste load is estimated to be 3.1 kg/to (6.3 Ib/Ton) of sus-
pended solids, 4.4 kg/kr (8.8 Ib/Ton) of caustic (hydroxide) alkalinity,
and 6.3 kg/kr (12.6 Ib/Ton) of dissolved solids for the selected typi-
cal plant at this minimal control level.  The pH of the untreated waste
is 12.0.  In-plant use of save-alls is assumed, as this is universally
practiced in the industry.

          Costs.  None.
          Reduction Benefits.  None.

Alternative B - Sedimentation of Process Wastes

This alternative includes settling of all process wastewaters.  Some
form of sedimentation is applied at almost all plants in the industry.
Costs include land disposal of dewatered sludge.  Effluent suspended
solids load estimated to be 0.19 kg/MT (0.38 Ib/Ton).  Alkalinity,
pH, and dissolved solids remain high.

          Costs.  Investment costs are approximately $124,000.

          Reduction Benefits.  Effluent suspended solids reduction
                  of approximately 94 percent.

Alternative C - Sedimentation and Neutralization of Process Wastes

This alternative includes settling of all process wastewaters before
and after neutralization to pH 9.0 or below.  This alternative is
practiced presently by about 15 percent of the pipe plants.  Effluent
suspended solids load of less than 0.19 kg/MT (0.38 Ib/Ton), caustic
alkalinity removed, and dissolved solids reduced somewhat.
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                                                            DRAFT
          Costs.  Incremental costs are approximately $77,000 over
                  Alternative Bj total costs are $201,000.

          Reduction Benefits.  Reduction of effluent suspended solids
                  of at least 95 percent, caustic alkalinity of almost
                  100 percent, and an indeterminate reduction in dis-
                  solved solids.

Alternative D - Complete Recycle of Process Water

This alternative includes complete recycle of all process power wastewaters
back into the manufacturing processes and other in-plant uses.  Fresh
water taken into plant equals quantity leaving in wet product and
other evaporative losses.  Complete control of pollutant constituents
without discharge is effected.  No pipe plant presently recycles all
of the process wastes.

          Costs.  Incremental costs are approximately $104,000 over
                  Alternative C; total costs are $305,000.

          Reduction Benefits.  Reduction of all pollutant constituents,
                  including suspended and dissolved solids and alka-
                  linity, of 100 percent.

Asbestos-Cement Sheet Products

Alternative A - No Waste Treatment or Control

Effluent waste load is estimated to be 6.5 kg/MT (13 Ib/Ton) of sus-
pended solids, 7.5 kg/kT (15 It/Ton) of caustic (hydroxide) alkalinity,
and 8.5 kg/iff (17 Xb/Ton) of dissolved solids for the selected typical
plant at this minimal control level.  The pH of the untreated waste is
11.7 or higher.  In-plant use of save-alls is assumed, as this is
universally practiced in the industry.

          Costs.  None.
          Reduction Benefits.  None.

Alternative B - Sedimentation of Process Wastes

This alternative includes settling of all process wastewaters.  Some
form of sedimentation is applied at most plants in the industry.  Costs
include land disposal of the dewatered sludge.  Effluent suspended
solids load estimated to be 0.23 kg/MT (0.45 Ib/Ton).  Alkalinity,
pH, and dissolved solids remain high.

          Costs.  Investment costs are approximately $56,000.

          Reduction Benefits.  Effluent suspended solids reduction
                  of approximately 96 percent.
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                                                            DRAFT
Alternative C - Sedimentation and Neutralization of Process Water

This alternative includes settling of all process wastewaters before
and after neutralization to pH 9.0 or below.  This alternative is
used by 10 percent or less of the sheet plants.  Effluent suspended
solids load of less than 0.23 kg/far (0.45 Ib/Ton), caustic alkalinity
removed, and dissolved solids reduced somewhat.

          Costs.  Incremental costs are approximately $36,000 over
                  Alternative B; total costs are $92,000.

          Reduction Benefits.  Reduction of effluent suspended
                  solids of at least 96 percent, caustic alkalinity
                  of almost 100 percent, and an indeterminate
                  reduction in dissolved solids.

Alternative D - Complete Recycle of Process Water

This alternative includes complete recycle of all process wastewaters
back into the manufacturing processes or other in-plant uses.  Fresh
water taken into plant equals quantity leaving in wet product and
other evaporative losses.  Complete control of pollutant constituents
without discharge is effected.  One sheet plant is known to accomplish
complete recycle during routine operation.

          Costs.  Incremental costs are approximately $59,000 over
                  Alternative C; total costs are $151,000.

          Reduction Benefits.  Reduction of all pollutant constitu-
                  ents, including suspended and dissolved solids
                  and alkalinity, of 100 percent.

Asbestos Paper

Alternative A - No Waste Treatment or Control

Effluent waste load is estimated to be 9.5 kg/kT (19 Ib/Ton) of sus-
pended solids, 1.5 kg/kT (3 Ib/Ton) of BOD, and 16.5 kg/to (33 lb/
Ton) of dissolved solids for the selected typical plant at this
minimal control level.  In-plant use of save-alls is assumed, as
this is universally practiced in the industry.

          Costs.  None.
          Reduction Benefits.  None.

Alternative B - Sedimentation of Process Wastes

This alternative includes settling of all process wastewaters.  Some
form of sedimentation is applied at approximately 70 percent of
plants in the industry.  Costs include land disposal of dewatered
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                                                            DRAFT
sludge.  Effluent load estimated to be 0.35 kg/kr (0.7 Ib/Ton)  of
suspended solids and of BOD and 16.5 kg/kC (33 Ib/Ton) of dissolved
solids.

          Costs.  Investment costs are approximately $237,000.

          Reduction Benefits.   Estimated reduction of effluent
                  solids of 96 percent and BOD of 75 percent.
                  Dissolved solids remain unchanged.

Alternative C - Complete Recycle of Process Water

This alternative includes complete recycle of all process wastewaters
back into the manufacturing processes and other in-plant uses.   Fresh
water taken into plant equals  quantity leaving in wet product and
other evaporative losses.  Complete control of pollutant constituents
without discharge is effected.  One paper plant is known to achieve
complete recycle when using starch binder under routine conditions.

          Costs.  Incremental  costs are approximately $57,000 over
                  Alternative  B; total costs are $294,000.

          Reduction Benefits.   Reduction of all pollutant constitu-
                  ents, including suspended and dissolved solids and
                  BOD, of 100  percent.

Asbestos Millboard

Alternative A - No Waste Treatment or Control

Effluent waste load is estimated to be 1.8 kg/kT (3.6 Ib/Ton) of
suspended solids and 0.25 kg/to (0.5 Ib/Ton) of BOD for the selected
typical plant at this minimal  control level.  In-plant use of save-
alls is assumed, as this is universally practiced in the industry.

          Costs.  None.
          Reduction Benefits.   None.

Alternative B - Sedimentation  of Process Wastes

This alternative includes settling of all process wastewaters.   Some
form of sedimentation is applied at at least 40 percent of the  plants.
Costs include disposal of sludge.  Effluent load estimated to be 0.8
kg/to (1.6 Ib/Ton) of suspended solids and 0.2 kg/kC (0.4 Ib/Ton)  of
BOD.

          Costs.  Investment costs are approximately $40,000.

          Reduction Benefits.   Estimated reduction of effluent  sus-
                  pended solids of 55 percent and BOD of 20 percent.
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                                                            DRAFT
Alternative C - Complete Recycle of Process Water

This alternative includes complete recycle of all process wastewaters
back into the manufacturing process and other in-plant uses.  Fresh
water taken into plant equals the quantity in wet product.  Complete
control of pollutant constituents without discharge is effected.
One millboard plant is known to achieve complete recycle most of
the time.

          Costs.  Incremental costs are approximately $12,000 over
                  Alternative B; total costs are $52,000.

          Reduction Benefits.  Reduction of suspended solids, BOD,
                  and all other pollutant constituents of 100 percent.

Asbestos Roofing

Alternative A - No Waste Treatment or Control

Effluent waste load is estimated to be 0.06 kg/to (0.12 Ib/Ton)  of
suspended solids, 0.003 kg/kE (0.006 Ib/Ton) of BOD, and 0.008 kg/to
(0.016 Ib/Ton) of COD for the selected typical plant at this minimal
control level.

          Costs.  None.
          Reduction Benefits.  None.

Alternative B - Sedimentation of Process Wastes (Contaminated Cooling
                Water)

This alternative includes settling of all process wastewaters (con-
taminated cooling water) with skimming or filtration as necessary to
remove suspended matter.  Effluent load estimated to be 0.006 kg/^T
(0.012 Ib/Ton) of suspended solids.  BOD and COD waste loads remain
the same as Alternative A.

          Costs.  Investment costs are approximately $24,000.

          Reduction Benefits.  Estimated reduction of effluent
                  suspended solids of 90 percent.

Alternative C - Complete Recycle of Process Water (Contaminated Cool-
                ing Water)

This alternative includes treatment, cooling, and reuse of process
waste (contaminated cooling water).  No process wastewaters are dis-
charged and complete control of pollutant constituents is effected.

          Costs.  Incremental costs are approximately $24,000 over
                  Alternative B; total costs are $48,000.
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                                                            DRAFT
          Reduction Benefits.  Reduction of suspended solids,  BOD,
                  and COD and all other pollutant constituents of
                  100 percent.

Asbestos Floor Tile

Alternative A - No Waste Treatment or Control

Effluent waste load is estimated to be 0.18 kg (0.38 Ib)  of suspended
solids, 0.017 kg (0.04 Ib) of BOD, and 0.34 kg (0.75 Ib)  of COD per
1,000 pieces of tile manufactured at the selected typical plant at
this minimal control level.

          Costs.  None.
          Reduction Benefits.  None.

Alternative B - Coagulation and Sedimentation of Process  Wastes
                (Contaminated Cooling Water)

This alternative includes polyelectrolyte coagulation and sedimenta-
tion with skimming as necessary to remove suspended matter. The per-
centage of tile plants applying this alternative is not known, but
is expected to be less than 25 percent.  The effluent load is  esti-
mated to be 0.04 kg (0.08 Ib) of suspended solids and 0.09 kg  (0.19)
of COD per 1,000 pieces of tile manufactured.  The BOD load may be
reduced somewhat.

          Costs.  Investment costs are approximately $52,000.

          Reduction Benefits.  Estimated reduction of effluent sus-
                  pended solids of 80 percent and COD of  75 percent.

Alternative C - Complete Recycle of Process Water (Contaminated
                Cooling Water)

This alternative includes additional treatment by filtration,  cool-
ing, and reuse of process wastewaters (contaminated cooling water).
No process wastes are discharged and complete control of  pollutant
constituents is effected.

          Costs.  Incremental costs are approximately $58,000  over
                  Alternative B; total costs are $110,000.

          Reduction Benefits.  Reduction of suspended solids,  BOD,
                  and COD and all other pollutant constituents of
                  100 percent.
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ENERGY REQUIREMENTS OF TREATMENT AND CONTROL TECHNOLOGIES

The energy required to implement in-plant control measures at a typi-
cal asbestos manufacturing plant is 20 kw (25 Hp) or less.  The
energy requirement is primarily for pumping to recycle and reuse
water.

The energy requirements of the end-of-pipe treatment technology are
not high for a typical plant.  No aeration or heating operations are
involved.  The single largest energy use would be a centrifuge for
dewatering waste solids from a paper or millboard plant.  This would
be used only intermittently and would require no more than 30 to 40
kw when running.  The motors for the sludge mechanisms in clarifiers
are normally small, 5 kw or less; and the pumping energy requirements
would be similar in magnitude to those for in-plant controls.

It is estimated that the total energy requirements for in-plant con-
trol and end-of-pipe treatment technology at a typical asbestos
manufacturing plant would not exceed 50 kw on a sustained basis.

No information was provided by the industry relative to the energy
requirements of individual manufacturing plants.  Most involve steam
generation for heating, for autoclaves, and for product drying.  The
additional energy required to implement the control and treatment
technologies is estimated to be less than 10 percent of the require-
ments of the manufacturing and associated operations.

NON-WATER QUALITY ASPECTS OF TREATMENT AND CONTROL TECHNOLOGIES

Air Pollution

The only significant potential air pollution problem associated with
application of the treatment and control technologies at a typical
asbestos manufacturing plant is the release of asbestos fibers and
other particulates from improperly managed solid wastes.  Exposed
accumulations of dried solids may serve as sources of air emissions
upon weathering.  The extent or seriousness of this phenomenon is
not known.  With proper solid wastes management the problem can be
avoided.

The biodegradable organic matter content of asbestos solids is low
or non-existent.  The solids do not undergo appreciable microbial
breakdown and there are no odor problems associated with asbestos
wastes.

There are no unusual or uncontrollable sources of noise associated
with application of the treatment and control technologies.
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                                                            DRAFT
Solid Waste Disposal

Landfilling of waste solids and dewatered sludges from asbestos manu-
facturing is an appropriate means of disposal.  The wastes are largely
inorganic and incineration, composting, or pyrolysis would not be
effective in reducing their volume.  The dewatered solids are rela-
tively dense and they are stable when used as fill material.  If
disposed of using proper sanitary landfill techniques, solids from
asbestos manufacturing should cause no environmental problems and
should be beneficial for reclaiming marginal or low-lying land.

The quantities of solids associated with treatment and control of
wastewaters from paper, millboard, roofing, and floor tile manufac-
turing are extremely small.  For example, the reported volume of
dewatered waste solids from a paper plant is 1.5 cu m (2 cu yd) per
month.  The costs for scavenger disposal are about $600 per year.
Solids are wasted only when elastomeric binders are being used,
which is 25 to 35 percent of the time.  Another example is that
provided by one of the larger floor tile plants in the country.  The
sludge and skimmings from the sedimentation unit amount to about 625
liters (165 gallons) per week.  Unlike other asbestos manufacturing
wastes, this material is highly organic and is disposed of by a com-
mercial firm that incinerates it.  The treatment facility at this
plant is not highly efficient, but is believed to capture at least
50 percent of the waste solids.

Contrary to the above categories, the waste solids associated with
asbestos-cement product manufacture are significant in volume.  The
reported losses at one pipe plant are in the order of 5 to 10 per-
cent of the weight of the raw materials.  The losses of asbestos
fibers are kept to a minimum in this industry, to 1 percent or less,
and the fiber content of the waste solids is low.  The solids have
no salvage or recovery value.

At many asbestos-cement product plants, the waste solids are dis-
posed of within the plant boundaries.  In some cases, the solids
have accumulated for decades.  The resulting piles may be sources
of air and water pollution.  To what extent material is released to
the atmosphere or to surface and groundwaters is not known.  The
piles are relatively stable and resistant to weathering.  They are,
however, clear examples of land pollution.  They are aesthetically
unattractive and, once accumulated, they are costly to remove.  The
practice of above-ground disposal of industrial residues has little
merit other than low costs.

The costs of waste solids removal at two asbestos-cement pipe plants
are in the order of $25,000 per year, or $0.30 to $0.40 per metric
ton ($0.33 to $0.45 per ton) of pipe production.  The costs at one
asbestos-cement sheet plant for solids disposal by a commercial firm
are about $0.18 to $0.23/MT ($0.20 to $0.25/T) of production.
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                                                            DRAFT
In summary, the solid wastes disposal associated with the application
of treatment and control technologies in the asbestos manufacturing
industry does not present any serious technical problems.  The wastes
are amenable to proper landfill disposal.  Much of the waste solid
material generated by the industry is presently being disposed of
and full application of control measures and treatment technology
will not result in major increases at most plants.  In many cases,
complete recycle will result in lower losses of solids.

DISCHARGE TO PUBLIC SEWERS

In order to develop estimated costs for the whole asbestos manufactur-
ing industry and to gain a better appreciation of the total impact of
the application of alternative treatment and control technologies, an
estimate was developed of the number of manufacturing operations that
presently do not involve discharge of process wastewaters, directly or
indirectly, into navigable waters.  Except for one multi-product plant
that achieves zero discharge, these plants discharge their wastewaters,
with or without pretreatment, to public sewers.  The percentages for
each product category or subcategory are as follows:

               Asbestos-cement pipe        21%
               Asbestos-cement sheet       46$
               Asbestos paper              42$
               Asbestos millboard          57$
               Asbestos roofing            44$
               Asbestos floor tile         54$
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                                                            DRAFT
                            SECTION IX

      EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
    THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
                  EFFLUENT LIMITATIONS GUIDELINES
INTRODUCTION

The effluent limitations which must be achieved July 1, 1977 are
to specify the degree of effluent reduction attainable through the
application of the Best Practicable Control Technology Currently
Available.  Best Practicable Control Technology Currently Available
is generally based upon the average of the best existing performance
by plants of various sizes, ages, and unit processes within the
industrial category or subcategory.  This average is not based
upon a broad range of plants -within the asbestos manufacturing
industry, but based upon performance levels achieved by exemplary
plants.

Consideration must also be given to:

     a.   The total cost of application of technology in relation
          to the effluent reduction benefits to be achieved from
          such application;

     b.   the size and age of equipment and facilities involved;

     c.   the processes employed;

     d.   the engineering aspects of the application of various
          types of control techniques;

     e.   process changes;

     f.   non-water quality environmental impact (including
          energy requirements).

Also, Best Practicable Control Technology Currently Available
emphasizes treatment facilities at the end of a manufacturing pro-
cess, but also includes the control technologies within the process
itself when the latter are considered to be normal practice within
an industry.

NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.
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A further consideration is the degree of economic and engineering
reliability which must be established for the technology to be
"currently available."  As a result of demonstration projects,
pilot plants and general use, there must exist a high degree of
confidence in the engineering and economic practicability of the
technology at the time of commencement of construction or instal-
lation of the control facilities.

EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF BEST
POLLUTION CONTROL TECHNOLOGY CURRENTLY AVAILABLE

Based on the information contained in Sections III through VIII of
this document, a determination has been made of the degree of
effluent reduction attainable through the application of the Best
Pollution Control Technology Currently Available for the asbestos
manufacturing industry.  The effluent reductions are summarized
here.

Suspended Solids

The principal pollutant constituent in wastewaters from the manufac-
ture of asbestos-cement products and asbestos paper and millboard
is suspended solids.  Application of this control technology will
reduce suspended solids levels by at least 95 percent.

The relatively lesser suspended solids from asbestos roofing and
floor tile manufacture will be reduced by 90 and 80 percent,
respectively, by the application of this control technology.

Caustic Alkalinity

Wastewaters from asbestos-cement product manufacture are highly
caustic.  Application of this control technology will reduce the
caustic alkalinity by 100 percent.  The pH will be 9.0 or below.

Oxygen Demanding Materials

Wastewaters from asbestos paper and floor tile manufacture may
contain organic constituents that exert an oxygen demand; BOD or
COD in the case of paper wastes and COD in floor tile wastes.
Application of this control technology will reduce the oxygen demand
by 75 percent.

Dissolved Solids

Asbestos manufacturing may raise the dissolved solids level in water

NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.
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                                                            DRAFT
significantly, especially in the case of asbestos-cement products.
Application of this control technology will reduce the dissolved
solids by an indeterminate amount.  The dissolved solids in the
treated effluent will still be relatively high.

Temperature

Asbestos manufacturing operations increase the water temperature
to maximum levels of 40 degrees C.  Application of this control
technology will not result in significant temperature reduction.

IDENTIFICATION OF BEST POLLUTION CONTROL TECHNOLOGY CURRENTLY
AVAILABLE

In-plant control measures available to the asbestos manufacturing
industry will not significantly reduce the level of pollutant
constituents in the effluent.  Application of such measures may
result in economic benefits and reduced end-of-pipe treatment costs.

The Best Pollution Control Technology Currently Available for the
categories of the asbestos manufacturing industry is summarized
below.

Asbestos-Cement Pipe

The control technology is sedimentation and neutralization of all
process wastewaters with land disposal of dewatered waste solids.
Effluent limitations for suspended solids of 0.19 kg/to (0.38 Ib/Ton)
and for BOD of 0.09 kg/MT (0.18 Ib/Ton) and pH of 9.0 or below.

Asbestos-Cement Sheet Products

The control technology is sedimentation and neutralization of all
process wastewaters with land disposal of dewatered waste solids.
Effluent limitations for suspended solids of 0.23 kg/MT (0.45 Ib/Ton)
and for BOD of 0.11 kg/MT (0.22 Ib/Ton) and pH of 9.0 or below.

Asbestos Paper

The control technology is sedimentation, with coagulation as necessary,
of all process wastewaters with land disposal of dewatered waste
solids.  Effluent limitations for suspended solids and for BOD of 0.35
kg/MT (0.70 Ib/Ton) and for COD of 0.70 kg/to (1.40 Ib/Ton).
NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.
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                                                            DRAFT
Asbestos Millboard

The control technology is no discharge of wastewater to navigable
waters.  In a plant that manufactures millboard and other asbestos
products, no increase in the limitations should be allowed for the
millboard if the waste streams are combined.

Asbestos Roofing

The control technology is sedimentation, with skimming and ancillary
physical treatment operations as necessary, of all process waste-
waters (contaminated cooling water).  Effluent limitations for
suspended solids Of 0.006 kg/to (0.0.12 Ib/Ton) and for COD of
0.008 kg/MT (0.016 Ib/Ton).

Asbestos Floor Tile

The control technology is sedimentation, with skimming as necessary,
or other physical treatment of all process wastewaters (contaminated
cooling water).  Effluent limitations for suspended solids of 0.04
kg/MT (0.08 Ib/Ton) and for COD of 0.09 kg/to (0.18 Ib/Ton).

RATIONALE FOR THE SELECTION OF BEST POLLUTION CONTROL TECHNOLOGY
CURRENTLY AVAILABLE

Total Costs of Application

Based upon the information presented in Section VIII and detailed
in Appendix A of this document, the industry as a whole would
have to invest less than $3,000,000 to achieve the effluent
limitations prescribed herein.  The increased annual costs of
applying this control technology are approximately $1,500,000 for
the industry.

Size and Age of Equipment and Facilities

As developed in this document, the narrow size range amoung
manufacturing plants in the same product category is insufficient
to substantiate differences in control technology based on size.
Age of equipment and facilities also does not procide a basis for
differentiation in application of this control technology.

Processes Employed

All plants in a given product category use very similar manufac-
turing processes and produce similar wastewater discharges.  There

NOTICE:   THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.
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                                                            DRAFT
is no evidence that operation of any current process or subprocess
•will substantially affect capabilities to implement this control
technology.

Engineering Aspects of Application

This control technology has been applied at approximately 40 percent
of the asbestos manufacturing locations in the industry.  The
concepts are proven and available for implementation.

Process Changes

The implementation of this control technology does not require in-
plant changes or process modifications.  Major developments in
manufacturing processes in the future are not expected.  This control
technology can be applied so that upsets and other fluctuations in
process operations can be accommodated without exceeding the effluent
limitations.

Non-Water Quality Environmental Impact

There is no evidence that application of this control technology
will result in any unusual air pollution or solid \vaste disposal
problems, either in kind or magnitude.  The costs of avoiding
problems in these areas are not excessive.  The energy required to
apply this control technology represents only a small increment of
the present total energy requirements of the industry.
NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RECEIVED
AND FURTHER INTERNAL REVIEW BY EPA.
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                                                            DRAFT
                             SECTION X

     EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
      THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
                  EFFLUENT LIMITATIONS GUIDELINES
INTRODUCTION

The effluent limitations that must be achieved July 1, 1983, are
to specify the degree of effluent reduction attainable through
the application of the Best Available Technology Economically
Achievable.  This control technology is not based upon an average
of the best performance within an industrial category, but is de-
termined by identifying the very best control and treatment tech-
nology employed by a specific plant within the industrial category
or subcategory, or where it is readily transferable from one in-
dustry process to another.

Consideration must also be given to:

a.  the total cost of application of this control technology in
    relation to the effluent reduction benefits to be achieved
    from such application;

b.  the size and age of equipment and facilities involved;

c.  the processes employed;

d.  the engineering aspects of the application of this control
    technology;

e.  process changes;

f.  non-water quality environmental impact (including energy re-
    quirements) .

Best Available Technology Economically Achievable also considers
the availability of in-process controls as well as control or ad-
ditional end-of-pipe treatment techniques.  This control technology
is the highest degree that has been achieved or has been demon-
strated to be capable of being designed for plant scale operation
up to and including "no discharge" of pollutants.

Although economic factors are considered in this development, the
costs for this level of control are intended to be the top-of-the-

NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RE-
CEIVED AND FURTHER INTERNAL REVIEW BY EPA.
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                                                            DRAFT
line of current technology subject to limitations imposed by eco-
nomic and engineering feasibility.  However, this control technology
may be characterized by some technical risk with respect to per-
formance and with respect to certainty of costs.  Therefore, this
control technology may necessitate some industrially sponsored de-
velopment work prior to its application.

EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF BEST
AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE

Based upon the information contained in Sections III through VIII
of this document, a determination has been made that the degree
of effluent reduction attainable through the application of the
Best Available Pollution Control Technology Economically Achievable
is no discharge to navigable waters.

IDENTIFICATION OF BEST AVAILABLE POLLUTION CONTROL TECHNOLOGY
ECONOMICALLY ACHIEVABLE

This control technology for all categories and subcategories of
the asbestos manufacturing industry is recycle and reuse of all
process waters and all cooling water that contacts the product or
otherwise is exposed to contamination by pollutant constituents.

To implement this control technology requires that the quantity of
fresh water supplied to the plant for manufacturing purposes equal
the quantity leaving the plant with the product or lost through
evaporation.  A combination of in-plant control measures to con-
serve water usage and end-of-pipe treatment technology will be re-
quired at most plants to apply this control technology.

RATIONALE FOR THE SELECTION OF BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE

Total Cost of Application

Based upon the information contained in Section VII and Appendix A
of this document, the industry as a whole would have to invest up
to an estimated maximum of $6,000,000 to achieve the effluent limi-
tations prescribed herein.  The increased annual costs to the in-
dustry would be approximately $2,700,000.

Size and Age of Equipment and Facilities

As discussed in Section IX, differences in size and age of equip-
ment and facilities in the industry do not play a significant role
in the application of this control technology.

NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RE-
CEIVED AND FURTHER INTERNAL REVIEW BY EPA.

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                                                            DRAFT
Processes Employed

The manufacturing processes employed within each category or sub-
category of the industry are basically similar and the differences
will not influence the applicability of this control technology.

Engineering Aspects of Application

With the exception of the asbestos-cement pipe and elastomeric
asbestos paper subcategories, this control technology has been
demonstrated for sustained operating periods by at least one manu-
facturing plant in the industry, or by well proven applications
in other industrial classifications.  To fully implement the con-
trol measures and achieve no discharge of pollutants will require
that the capacity of the water recycle systems be expanded to ac-
commodate upsets and surge flows.  This expansion of capacity pre-
sents no unusual engineering problems.

Some additional study by the industry is necessary to apply this
technology to the asbestos-cement pipe and elastomeric asbestos
paper subcategories.  Some progress has been made in these areas,
but complete recycle of all water has not yet been accomplished.

Process Changes

The application of this control technology will require some opera-
tional changes in the manufacturing processes, but no fundamental
changes are indicated.  Many of the in-plant control measures and
end-of-pipe treatment techniques with partial recycle of process
wastewaters have already been implemented by many plants in the in-
dustry.

Non-Water Quality Environmental Aspects

The application of this control technology will not create any new
air or land pollution problems or require significantly more energy
than associated with the application of the Best Practicable Control
Technology Currently Available.  These aspects are discussed in
Section IX of this document.
NOTICE:  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RE-
CEIVED AND FURTHER INTERNAL REVIEW BY EPA.

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                                                            DRAFT
                            SECTION XI

               NEW SOURCE PERFORMANCE STANDARDS AND
                      PRETREATMENT STANDARDS
INTRODUCTION

Defined standards of performance are to be achieved by new sources
and by sources discharging into publicly owned sewerage systems en-
compassing activated sludge or trickling filter wastewater treat-
ment plants.  The term "new source" is defined to mean "any source,
the construction of which is commenced after the publication of the
proposed regulations prescribing a standard of performance."

NEW SOURCE PERFORMANCE STANDARDS

New sources, except as noted below, should achieve the effluent li-
mitations prescribed as attainable through the application of the
Best Available Technology Economically Achievable.

New sources manufacturing asbestos-cement pipe or asbestos paper
with elastomeric binders should achieve the effluent limitations
prescribed as attainable through the application of the Best Prac-
ticable Control Technology Currently Available.

PRETREATMENT STANDARDS

The pollutant constituents in wastewaters from asbestos manufacturing
that are potentially harmful to, (or untreatable in,) sewerage sys-
tems employing biological treatment units are the following:

Suspended solids
Caustic alkalinity
Refractory organic materials
Toxic materials

Achievement of the effluent limitations prescribed as attainable
through the application of the Best Practicable Control Technology
Currently Available should render the wastewaters suitable for
treatment in a biological treatment system in terms of suspended
solids, caustic alkalinity, and refractory organic materials.  Dis-
charge of toxic concentrations of heavy metals, cyanides, and other
elements and compounds recognized as harmful to biological treat-
ment systems should be prohibited.

NOTICE;  THESE ARE TENTATIVE RECOMMENDATIONS BASED UPON INFORMATION
IN THIS REPORT AND ARE SUBJECT TO CHANGE BASED UPON COMMENTS RE-
CEIVED AND FURTHER INTERNAL REVIEW BY EPA.
                                87

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                                                            DRAFT
                            SECTION XII

                          ACKNOWLEDGMENTS
Appreciation is extended to the many people in the asbestos manu-
facturing industry who cooperated in providing information and
data.  The assistance of the Asbestos Information Association -
North America in distributing questionnaires to its membership is
appreciated.

Special mention is made of the following company representatives
who gave of their time in developing the information for this docu-
ment.

Mr. Edmund M. Fenner and Mr. Lucine D.  Mutaw of the Johns-Manville
Corporation.

Mr. S. E. Monoky, Mr. Fred L. Bickel, and Mr. John P. McGinley of
the Certain-Teed Products Corporation.

Mr. W. C. Harper, Mr. Aubrey A. Serratt, Mr. A. W. Smith,  and
Mr. R. S. Miller of The Celotex Corporation.

Mr. E. A. Opila, Mr. Herbert A. Dalik,  Mr. William Carl, Mr. Paul
Masek, and Mr. Ed Potkay of The Flintkote Company.

Mr. R. K. Wilson, Mr. W. H. Wolfinger,  and Mr. M. A. Arvieta of the
Armstrong Cork Company.

Mr. Jack Holloway and Mr. Stan Stempien of the GAF Corporation.

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                                                             DRAFT
                           SECTION XIII

                            REFERENCES


1.   Asbestos. Stover Publishing Company, Willow Grove, Pa.

2.   Bowles, 0., The Asbestos Industry. U.S. Bureau of Mines,  Bulletin
          552

3.   Clifton, Robert A., "Asbestos", Bureau of Mines Minerals Year-
          book. U.S. Department of the Interior, 1971

4.   DuBois, Arthur B., Airborne Asbestos. U.S. Department of
          Commerce, 1971

5.   Impact of Proposed OSHA Standard for Asbestos, report to U.S.
          Department of Labor by Arthur D. Little, Inc.,  1972

6.   Industrial Waste Study Report: Flat Glass. Cement. Lime. Gypsum.
          and Asbestos Industries, report to Environmental Protection
          Agency by Sverdrup & Parcel and Associates, Inc., 1971

7.   Knapp, Carol E., "Asbestos, Friend or Foe?", Environmental
          Science and Technology Vol. 4, No. 9, 1970

8.   May, Timothy C., and Lewis, Richard W., "Asbestos",  Bureau of
          Mines Bulletin 650. Mineral Facts and Problems. U.S. Depart-
          ment of the Interior, 1970

9.   McDermott, James H., "Asbestos in Water", Memorandum to
          Regional Water Supply Representatives. U.S. Environmental
          Protection Agency, April 24, 1973

10.  McDonald, J. Corbett, McDonald, Alison D., Giffs, Graham W.,
          Siemiatycki, Jack and Rossiter, M. A.,  "Mortality  in the
          Crysotile Asbestos Mines and Mills of Quebec",  Archive of
          Environmental Health. Vol. 22, 1971

11.  Methods for Chemical Analysis of Water and Wastes. Environmental
          Protection Agency, National Environmental Research Center,
          Analytical Quality Control Laboratory, Cincinnati, Ohio,
          1971

12.  National Inventory of Sources and Emissions; Cadmium. Nickel
          and Asbestos, report to National Air Pollution  Control
          Administration, Department of Health, Education and Wel-
          fare, by W. E. Davis & Associates, 1970
                                 91

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                                                            DRAFT
13.  Patterson, W. L. and Banker, R. F., Estimating Costs and Man-
          power Requirements for Conventional Wastewater Treatment
          Facilities. Black and Veatch, Consulting Engineers for
          the Office of Research and Monitoring, Environmental Pro-
          tection Agency, 1971

14.  Rosato, D. V., Asbestos:  Its Industrial Applications. Reinhold
          Publishing Corporation, New York, N. Y.  1959

15.  Selikoff, Irving J., Hammond, E. Cuyler and Seidman, Herbert,
          Cancer Risk of Insulation Workers in the United States.
          International Agency for Research on Cancer, 1972

16.  Selikoff, Irving J., Nicholson, William J. and Langer, Arthur M.,
         "Asbestos Air Pollution", Archives of Environmental Health
          Volume 25, American Medical Association, 1972

17.  Sewage Treatment Plant and Sewer Construction Cost Indexes.
          Environmental Protection Agency, Office of Water Programs
          Operations, Municipal Wastewater Systems Division,
          Evaluation and Resource Control Branch

18.  Sinclair, W. E., Asbestos. Its Origin. Production and Utilization.
          London, Mining Publications Ltd., 1955

19.  Smith, Robert, Cost of Conventional and Advanced Treatment of
          Wastewaters. Federal Water Pollution Control Admini-
          stration, U.S. Department of the Interior, 1968

20.  Smith, Robert and McMichael, Walter F., Cost and Performance
          Estimates for Tertiary Wastewater Treating Processes.
          Federal Water Pollution Control Administration, U.S. De-
          partment of the Interior, 1969

21.  Standard Methods for the Examination of Water and Wastewater.
          13th edition, American Public Health Association, Washing-
          ton D.C., 1971

22.  Sullivan, Ralph J., Air Pollution Aspects of Asbestos. U.S.
          Department of Commerce, 1969

23.  Tabershaw, I. R.,  "Asbestos as an Enviromental Hazard", Journal
          of Occupational Medicine. 1968

24.  The Asbestos Factbook.  Asbestos, Willow Grove, Pa.,  1970

25.  Villecro, M., "Technology, Danger of Asbestos",  Architectural
          Forum.  1970
                               92

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                                                            DRAFT
26.  Welcome to the Johns-Manville Transite Pipe Plant  at Manville.
          N.J.. Johns-Manville Co., New York,  N. Y.  1969.

27.  Wright, G. W., "Asbestos and Health in 1969", American Review
          of Respiratory Diseases, 1969.
                                93

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                                                            DRAFT
                            SECTION XIV

                             GLOSSARY
1.  Beater
    A wet mixer used to separate the fibers, mix the ingredients,
    and provide a homogeneous slurry.
    A chemical substance mixed with asbestos and other ingredients
    to bond them together.

3.  Blinding

    The plugging by fibers and binder of the pores in carrier felts
    and holes in cylinder screens thereby reducing or preventing
    the flow of water through the felt or screen.

4.  Calender

    A machine designed to give paper a smooth surface by passing
    it between a series of pressure rollers.

5.  Elastomeric Paper

    Paper made with a synthetic or natural rubber binder.

6.  Felt

    An endless belt of heavy porous cloth.

7.  Mottle

    Solid color granulated tile chips that are made and fed into
    tile production lines to provide color and pattern.

8.  Vacuum Box

    A box with a long, narrow opening positioned just below or above
    the felt in a paper machine.  The vacuum maintained in the box
    draws water out of the sheet of fiber through the felt and into
    the box.

9.  Whipper

    A rotating paddle designed to release fiber or other particulate
    matter from a paper, pipe, or millboard machine carrier felt by
    beating the felt as it moves through the machine.

                                95

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                            DRAFT
                         CONVERSION TABLE




Multiply (English Units)       bv.


    ENGLISH UNIT           CONVERSION


acre                         0.405


cubic feet                   0.028


cubic feet                  28.32

                                     &
degree Fahrenheit         0.555(F-32)


feet                         0.3048


gallon                       3.785


gallon/minute                0.0631


horsepower                   0.7457


pounds                       0.454


million gallons/day          3,785


square feet                  0.0929


tons (short)                 0.907


 Actual conversion, not a multiplier
               To Obtain (Metric Units)


                      METRIC UNIT


             hectares


             cubic meters


             liters


             degree Centigrade


             meters


             liters


             liters/second


             kilowatts


             kilograms


             cubic meters/day


             square meters


             metric tons (1000 kilograms)
96

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