Document 65baBD7VKa0YLMYmObJXjJ0Nd

FILE NAME: EPA National Emission Standards DATE: 1974 Mar 6 DOC#: EPA006 DOCUMENT DESCRIPTION: Letter to Environmental Defense Fund from EPA RE Recommendations for Extending the Coverage of the National Emission Standards for Hazardous Air Pollutants UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 1974 Ms. Jackie Warren Environmental Defense Fund . 1525 18th Street, N.W. Washington, D. C. 20031 Dear Ms. Warren: The purpose of this letter is to summarize our recommendations for extending the coverage of the national emission standards for hazardous air pollutants and provide an opportunity for your review prior to our March 11 meeting. Our studies have identified central fabricating shops for the following products as major potential sources of asbestos emissions: 1. Asbestos cement boards for the molten metal industry, marine industry, ventilation hoods, baking ovens, electrical panels, and laboratory furniture. 2. Asbestos cement building products. 3. Asbestos friction products. For these sources we intend to recommend a standard similar to that . now applicable to asbestos manufacturing operations, which would prevent visible emissions to the outside air or require the use of specified gas cleaning equipment. 'We have traced the flow of asbestoscontaining materials from manufacturer to fabricator to end users, and have concluded that almost all fabrication is performed in central shops rather than at field sites. In the absence of any identifiable major field fabrication operations for asbestos products, we do not see a need for recommending coverage of field fabrication. The field installation of molded asbestos insulating products, which are friable, isjxnown to be a'source of occupational asbestos exposure, and we have considered such installation to be a major potentialsource^df'pubTic"'expdsureTsd.~^Tpdicatiphs~'are~that difficulties in control11ng occupational^exposures and the avai1abi1ity of substitutes for asbestos in these products will force a discontinuance of'the use of molded asbestos insulating products. Accordingly,.we. ~ 2~ will recommend a prohibition on the use of molded asbestos insulating products. It may be necessary, however, to exempt a minority of products used in special applications, such as very high temperature insulation, because substitutes for asbestos are not available. Two additional asbestos manufacturing operations have been identified as major potential sources of asbestos emissions, and we will recommend their inclusion under the existing manufacturing regulation. The sources are^shotgun shell manufacturers, and asphalt concrete plants which occasionally use asbestos in specialty paving materials.f ' ' . investigations have indicated a need for controlling the disposal of friable and dusty asbestos waste materials, starting at the location of generation and extending through the various handling operations to the ultimate disposal site. We will recommend standards for: 1. Sources covered by the manufacturing regulation. 2. Operations covered by the demolition regulation. 3. Central fabricating shops. . The revised regulations we recommend will have to account for the wide diversity in types of sources, types of wastes, and available alternatives for ultimate disposal. We have not yet decided on the form for the waste disposal regulation. We are considering no visible emissions to the outside air, specified work practices, or a combination of these two requirements. The results from the ambient asbestos study we performed at the GAF Corporation asbestos mine-mill complex in Vermont indicate that windblown emissions from the inactive portion.of the pile are not a major problem; however, the dumping of tailings from a conveyor onto the active portion of the pile and the redistribution of the deposited tailings away from the end of the conveyor are major potential sources of asbestos emissions which are not covered by our current regulations. As I mentioned in my letter of July 24, 1973, to Scott Lang, we know of no effective, broadly applicable control techniques for this type of emission source which would, for example, prevent the generation of visible emissions. The obvious control alternative of v/etting the wastes prior to deposition would be applicable at some mills, but freezing conditions or lack of sufficient water supplies limit the use of this technique. Our Control Systems Laboratory is continuing to investigate control techniques for this type of emission source, but a more complete assessment of the possibilities for control will not be available for another year. Consequently, we have not been able to arrive at a recommendation for controlling tailings piles, and we would like to discuss this situation with you further on March 11. - 3- ccoommpDllePttePdd,05!in!c!l?u!d^i^ng paonratliyosnesofofj;hoeurVerarmnboinetntstauidry wshamipclhesh.as Tbheeen final report of this study is now being prepared. > site fip asbesbos study which we performed at a waste disposal been ng operations in Ambler, Pennsylvania, has been completed. I am enclosing a copy of our report of this study and describing the details of the ambient sampling network. ll??1Cdtes tnat windblown emissions from the inactive p o m ons of the piles are not a major problem. In particular, the .lnactive pile at Ambler which is adjacent to a children's playground, and--w--hic--h was -discussed with wSt-c'^o^tvt Lang uaunud Lucile Adamson in one of pur early meetings, v/as not found to "produce"ambient asbestos,levels significantly above,.,background.1evels. Public access to inactive piles such as -his one should be controlled, however, and y/e intend to recommend fencing and posting as a method of accomplishing this. The relatively high asbestos'concentrations "measured at one site removed trom the active disposal operations at Ambler indicate that control of the operations should be improved. The regulations which we will recommend for disposal of wastes from asbestos manufacturing operations will apply to these operations. There are relatively few existing asbestos waste piles as large as the ones located at Ambler, and it appears that re stringent waste disposal regulations will force greater recycling of potential wastes for reprocessing and preclude the formation of new piles of this size. . 9ur "investigation of sewage sludge incinerators shows that mercury emissions should be limited, and we will recommend an emission standard tor this source category. If you have any questions, please call me. Sincerely, . Enclosures Don R. Goodwin Director Emission Standards and Engineering Division