Document 71Nx1K5ZoBvjQV3gpoN669v0j

HII/l and KNOWLTON. Irc. June 15, 1971 MEMORANDUM TO: Mr. W. F. Raines Johns-Manville Corporation SUBJECT: Illinois Pollution Control Board -- Asbestos Regulations Here are the asbestos regulations proposed by the Illinois Pollution Control Board. Attached also you will find a brief sheet explaining the need for the proposed regulations. Nell Regan discussed the Illinois situation this morning with Tamothy Harker of the Illinois Pollution Control Board. Harker said that no hearings are scheduled as yet but probably would be within the next two months. He told Regan he thought it would be unethical for A1A/KA to talk to miasuairit of uualu ueluiia L'm hearings. For the record, the Illinois Pollution Control Board Chicago address and phone are as follows: 189 W. Madison Street, Chicago, Illinois 60603 (312-793-3620). t JDC:sdd Enclosure James D. Callaghan cc: Matt Swetonic 01-0210307 * n 7i-i6 Asbestos and Spray Xnsulntion \\ 7'xplm:.vti0-s or proposed Rr.GULATious Science i3 pointing its medical finder at asbestos and describing the "miracle fiber" a mineral whose commercial blessings can exact a rather costly toll. Asbestos insula tion and factory workers exposed to heavy concontrations of ( asbestos fiber over prolonged periods have* suffered no. . consequences. They arc visited with cn alarmingly high in cidence of asbastosin, which produces a diffuse-fibrosis of the lower lung, of lung cancer and of an extremely rare cancer of the iinina of the lung and abdomen, mesothelioma. The rates of lung cancer are extraordinary high especially among asbestos workers who are smokers, indicating tha syne?- . gistic potential of the mineral, fiber. The medical evidence i3 indefinite as to why asbestos ? osi*ririncnn*-. with throa theories in vou.e: (1) The fibers once ingested-or inhaled act as a continous physical irritant, inducing (i i.w>iijr after u to J*' years, tJ) t'no fiber* contaan carcinogens such as ben ac (a) pyrents; (3) fibers'Accumulate in the lung and remain immobilized *ts "asbestos bodies'* which cause cancer upon disinteoration. Similarly, while the adverse effect of prolonged exposure to heavy concentrations of abestos is clcacy documented, the* medical data is disturbingly vaguer .as to the results of long term exposure to low* and moderate concentrations. hor is there a clear dose-tine relationship for exposure to heavy concerrtrar tions. In short, as with many other environmental contaminants, the public has discovered too late that asbestos is potentially dangerous and too little of the extent of that threat. But two depressing facts are agreed upon: Tnat millions of Americans are likely to contain "asbestou bodies" in their lungs and that asbestos fiber once released is relatively indestruct ible. That is, the qualities of durability and of resistance to normal chemical and physical stress, which make asbestos nuch a commercial success, render it potentially dangerous to present and future generations because of the tendency of the fibers to accumulate in the atmosphere and in the lungs. In light of. these facts, the PCS has proponed the nation's met comprehensive t of abefttos"'*ccntro`i s. To ban* all uses of asbestos would be "ali.t.'niflia" at its most clanorouc. But ignoring 01-0218308 'i ui.ur. .Si i : the need to explore and, perhaps, to adopt controls lor the significant contributors to a swelling volume of asbestos fiber . in our air would constitute a foolish complacency. To this end> the suggested regulations would identify these "significant contributors" as the commercial use of asbestos in construction work; the demolition of ashestoscontaining structures; the manufacturing and processing of asbestos-containing products; the transportation of certain asbestos-containing products; tho disposal of asbestos-containing waste; and the use of asbestos in the brakes of millions of vehicles. Part IT would impose sQvpral general requirements upon all commercial construction, repair, alteration, demolition, manufacturing or processing activity from which asbestos fiber is discharged into the environment. The persons responsible for such activity must obtain a permit, from tho KPA. Tho permit system will serve to produce the advanced .-assurrance of comoliancc with the applicable control regulations and will thus raduce V1' cost and burden of in-the--field enforcement. In addition these commercial activities would have to provide facilities to prevent the removal of asncctos rimers from the site of such activity on the clothing of employees. Indeed, this pesos a rather-new concept of air pollution control, rnoca wao have dies from lung VwiU 'uu^, alwsa association to an asbestos worker may be powerful proof of the need for novelty. Finally, Part IX would provide for careful vzasto disposal procedures, as wind-blown refuse heaps and scrap piles contribute to the volume of asbestos fiber in our air. The simple steps for control eliminate any excuse for such dangerously sloppy housework. . . Part IZX would prohibit tho spraying of asbestos-containing insulation and fireproofing. Experience has indicated that procedural safeguards are inadequate and their enforcement is * an overtaxing burden. Chicago has banned spray asbahtos, and New York city and Philadelphia are considering doing so. Procedural safeguards designed to reduce fiber emissions would be required to spray non-asbestos insulation. The biological effects of these fibers is unknown. Prudence would seem to % dictate reasonable efforts to soften the potential future blow from spray fiber aspiring to asbestos*' status. Part IV suggests that various * asbcstoc-relatecl activities at`construction sites be-done within an enclosure. It would also require that asbestos construction products be so installed as to preclude the emission of fiber into the circulating air. 01-0218309 4 Part V expresses;, ironically, what rpy bo a key reason for Clouds dust <sr often raised by demolition work. Tho facts that great numb*r3 of persons nay ho exposed to this dust in urban areas and thtt'the post-war generation of high-rises were the first building;; to use asbestos insulation extensively speak in favor of some such regulation. Part VT suggests an emission standard for manufacturers of asbestos products. The standard is believed to be within the capture efficiency cf bachousc filtration. The proposed boundary standard is thought to b/ a method for preventing dilution of exhaust gases. The standard would measure only fiber:; longer than five microns. The justification for this seems to be the administrative con venience of avoiding difficulties in measuring fibers fron. .5 to five microns in length. Medical evidence has indicated ,, that the very srall fibers nay be.the most dangerous. And the onavd will seek extensive evidence on this point. Part VII vovJb prohibit-the use of brake lining in vehicles manufactured at tor January 1*: 1975 and sold for use in Illinois. If brake lining decomposition emits asbestos fiber, then the tremendous number of vehicles using asbesten, and the impracticality'of controlling these numerous small emission sources would appear to speak* to the need for a product ban. The pro hibition" is carefully wordsd to avoid the necessity of fitting vehicles produced prior to 1375 with non-asbestos brakes. It is contemplated that the ban will necessitate design chances, probably to dine brakes, and it is thought that requiring the invidual vehicle, owner to undergo this expense is Unreasonable. The tine lag of over three years is thought to be sufficient for vehicle manufacturers to accomplish any necessary design changes. T'rrrry. iv.' I jEfWiJL-H Jtm iMMWfiMfiiiia** ft* w * v. ; V- : *T**? 'rAfM. 01-0218310 I Proposed Peculation Or.lv i June 9/1971 CHAPTER V: '-ON 1C SUBSTANCES ASBESTOS: SPRAY UCSULATIOU Table of Contents Part 1: Tart XI s Part III Introduction. 101. 102. 103. Authority Policy Definitions General Resuiremsnts 201. Permit 202. Removal o Asbestos front clothing 203. Waste disposal Snrav Pireproofing and Insulation 301. Spray asbestos prohibited Part IV Part V Part VI Part VII Construction, Alteration and Repair of Structure 401. Enclosure 402. Preclude exposure to circulating air Demolition 501. Necessary and. practicable safeguards 502. Cessation of demolition verb. .. ,v Manufacturing 601. 602. 603. Emission standard; concentration at boundary Process water Waste sludge disposal Asbestos-Containinc products 701. * Transportation 702. Brahe lining 01-0219*1 1 PAST T; introduction 101. Autfiori fry - Pursuant to the authority in Sections 9, 10 and 13 of the Euvironr.cnt.al Protection /Act which empower the Untird to adept regulations forbidding the "sale, offer/ or use for reasons of air pollution control" oi any article, and to set "standards specifying the maximum amounts or concentrations of various contaminants that way be disenarged into the atmosphere" > and to set standards for'the issuance of permits for the operation of any equipment or facility capable oi causing or contributing to air pollution) and to promulgate "conditions regarding the... use of any.... article determined by the hoard to constitute an air pollution hazard"; and to adopt effluent standards limiting the amounts of contaminants that nay be discharged into the water of Illinois, the Board adopts the following rules and regulations: 102. Policy It is the purpose of- the General Assembly in adopting thtf Environmental Protection Act to maintain ami enhance the purity of the air and water oi Illinois in order to protect health, welfare and the quality of lilts. Accordingly, it is ncreoy ur <Hi i*i t tittw I.uau i.ih: into the environment h-nds to severely endanger the public health and welfare and that the uncontrolled spraying of fiber-containing materials unreasonably interferes with the enjoyment of life and property. - It is the purpose of these regulations to control the amount of asbestos liber released into the environment from the major sourcos of emission* Such control is necessary not only to protect those members of the public who are in proximity to heavy concentrations of asbestos fiber but also to'safeguard the health of future generations cneangered'by the continuous discharge of asbestos fiber which can be toxic and which tends to be cumulative both in the atmosphere and in .the human body. Where health can be protected by the adoption of an emission standard or of procedural safeguards, such a course has been pursued. In those instances where restriction is unfeasible because of the tremendous number of small, uncontrollable emission sourcos (automotive)or because of the ununual nature of tho emission source (spray asbestos at construction site*'' a product ban has been rsnorted to. These prohibitions have been made with full consideration given to the available alternative materials. It is also the purpose of those regulations to rccluco the emission of non-asbestos particulate from spray-fireproding and 01-0218312 insulation* To protect agnins L Lhe-se emissions, thi biological effects of which are unknown. procedural safeguards avo been enacted. 103. Definitions Agency The Illinois Environmental Protection Agency Asbestos Any fiber or any mixture containing fiber of hydrated silicate mineral, which, on the basis of its crystalline structure/ falls into one of two categories: Cl) pyroxene* - chrysotilc fiber; (2) annhiboles - erocidoliie, amosite, tremolite, actinolyto or anthophylite fiber. Board The Pollution Control Board of Illinois. Commercial - Activity - Any activity done for hire or having financial * profit as a primary aim. Debris - Asbeston-centalhtnc waste produced by the i'.Mi 1 .! * Li. uu Luj u Spraying - The pneumatic application of material used for fireproofing or insulation. Waste - Any asbestos-containing natter*v:hich has been or is intenaed to be discarded. PART II: Conorr). Requirements No commercial activity, not* otherwise hereinafter prohibited, involving the discharge of asbestos fiber into the environment from the construction, alteration, repair or demolition of a struc ture or from the processing or manufacturing of asbestos-containing products, shall be conducted unless the person or entity in charge of such activity complies with the following regulations: 201. A permit shall be obtained from tho Agency to engage in such activity. Boforo obtaining such permit, tho applicant shall demonstrate compliance with the following safeguards: * (a) The designation of personnel ,,*.oreise full-, time supervisory authority over all aspects ci tho activity from which the release of asbestos iibor into the environ ment could result, in such s manner as to insure compliance 01-0218313 with the pertinent asbestos control regulations. (b) That each employee engaged in such activity has completed or will complete a natisiactory course of instruc tion on the potential bazarus of exposure to sshnutos fiber including the precautions that must bo observed to prevent or restrict the dispersion of asbestos fiber into the environ-. Riant. . .202 (c) That such additional safeguards as are hereinafter specifically required and such precautions cons*stent with the purpose of these regulations as the Agency ciasma neces sary under the cireamsLances shall be complied with. Facilities shall be provided and procedures instituted and supervised that prevent the removal of asbestos-containing material from the site on the clothing of employees. 203. Asbestos-containing wastes shall bo immediately vacuumed or otherwise collected where vseuming is impossible, and shall be placed in a container resistant to tearing or breaking under normal handling conditions, which shall be tightly sealed and clearly* marked as containing asbostos waste. Such containers shall be placed directly uson a vehicle for disposal bv burial at an up- proved site. Section 2C3 shall not apply to the demolition of a structure, except as provided in Section 501(a),.(d) and (a) or to the disposal of sludge waste except as provided in Section 603. PART III: SPRAY FlRSTlioOriXG AND TSSUhATlOK 301. 302. The spraying of asbestos-containing material is prohibited. *s Non-asbestos particulate matter used for insulation or fire proofing shall not be sprayod unless the following procedures are taken: (a) Before the start of* spraying operations, all floor areas shall be swept clean and cleared of all objects, notarial and equipment other than that employed in the appli cation, of the fiber-containing material, or, in the alterna tive, all such objects, material and equipment shall be covered with plastic or plastic-coatcd tarpaulins. (b) The entire floor or area to be sprayed shall be enclosed with plastic or plastic- ~M.cd tarpaulins in a manner which shall preclude the escape of fiber-containing material from the enclosure. All interior opu.n areas such as elevator shafts and stairwells shall be*enclosed in a man ner which shall prevent the escape ot fibor-containing -3 01--0218314 material Iron the working erea. "Steel; effect" of the shafts, stairwells and comparable spacers shall be considered in providing proper enclosures. (c) Ibagardlcsn of adherence -to the stated control practices, any visible emission o fibur-contair.ing materials beyond the building uarimstcr will be considered a violation. (d) In ease of visible omission of fibrous material from the construction site, immediate stops shall be taken to cause the cessation of such emissions by either effective control measures or work stoppage at the source of the emissions. There shall then be immediate and com plete cleanup of all material that has escaped the construc tion situ# and measures shall be token that will insure that no further dispersal of any fibrous material into the atmosphere can occur. (a) The entire sprayed area, all ledges and surfaces including tarpaulins within the enclosure shall be thoroughly vacuumed upon completion of the spraying operation and immediately before tho enclosure is dismantled. Thu vacubm cleaner shall contain a strong, single-service, disposable xnr.cr oau ox durable utoxeriai which shall be -removuu from the vacuum cleaner and-tightly sealed. The bag shall then be ^ * mm ^ 4 ^ f JL f I U WW*I M||k W* % tv **** w in accordance with Section 203. () All areas used for opening bags containing fibrous material or the changing of hoppers shall be enclosed so as to prevent the escape cf such material the immediate area in which such activity occurs. from - (g) Any plenum or other structure coated with or containing fibrous insulation und used in the circulation of air in a building shall be thoroughly cleaned of all debris and waste insulation. All applied fibcr-containirv insulation within a plenum or duct shall be coated with a sealant which precludes exposure of the fiber-containing material to the circulating air. PART IVi CONSTRUCTION, ALTERATION AND REPAIR OF _STRUCTURE 401. (a) The cutting, trimming, fitting or stripping of asbestoscontaining material in the construction, alteration or repair of a structure which is dono a. the site of such structure shall be conducted within a special enclosure designed to preclude the escape of asbestos fiber from tho immediate area of .such enclosure. (b) The mechanical exhaustion of dust from such enclosure to the ambient air is prohibited unless such exhaust system is equipped with a fabric filter for dust collection. 01-0218315 402. " Asbestos-containing material applied in the construction# alteration or repair of a structure shall be coated with a sealant# provided with a cover or installed in some other manner ?> as to preclude exposure of the asbestos fiber to the circulating air. PART V: nmOLlTlOtt 501. where the risk of public exposure to asbestos fiber from the. dislodging of asbestos-containing materials is present, no demolition of a structure shall be initiated unless all safe guards necessary and practicable to reduce the emission of dust are taken. / Such procedures shall Include# but are not necessarily limited tot #(a)- Boilers and pipes insulated with asbestos-containing material shall be wotted and stripped before toppling of walls is begun. This procedure shall be followed# where practicable# as to all.other asbestos-lined surfaces. Such asbestos 'waste shall be immediately bagged and disponnu of: in accordance with Section 203. (b) Demolition by toppling of walls is prohibited except within -- n #vw ' V >..U. ituwi'twV US the permit granted for demolition of that structure. (c) Before the demolition of any section oi the structure, adequate wotting to suppress the dust shall be employed. 0 (d) Asbestos-ccntaining debris shall not be dropped or thrown from any floor but shall be transported by dusttight chutes or buckets. Asbestos-containing debris in diutes or buckets shall bo sufficiently wetted to preclude dust dispersion at i the point.of discharge. '* (e) All asbestos-containing debris shall bo thoroughly wetted before loading into .trucks# other vehicles or con.tainers. oaring transport such waste shnllba enclosed or covered so as to prevent dust dispersion. Asbestos-containing debris shall be disoosed by burial at an approved site. 502.. Zn the event asbestos-containing matter bocomos air-borne beyond the property boundaries or in .the event freezing temper atures preclude the uso of water for dust suppression# denoliton work shall cease until ><*-- ..itc alternate measures cun be taken. PART VI: MANUFACTURING 601. (a) bo factory# plant or enterprise which engager. in the processing or manufacturing of any ossber.tos-ccntnining product shall emit asbestos fiber into the ambient air in excess of .5 fiber per cubic centimeter of air. The ambient -5-.. ------------01-0218316