Document MG6p9ba0aqNX5JEEgVoozLLwz

HUBB-0(131)1110 y ? (S5) Fwn WIN Date SuOjen Westinghouse Building 1554 272-3975 September 11, 1986 C=3 Id R&D Center 401 3X9 Industrial Hygiene C. W. Blckerstaff Asbestos in some forms is regulated when transported. Asbestos which is immersed or fixed in a natural or artificial binder material (such as cement, plastic, asphalt, resins or mineral ore), and manufactured products containing asbestos, or any material or products whose commercial value is not dependent on their asbestos content, are not subject to the requirements of 49 CFR. Commercial asbestos is any material or product containing asbestos that has a commercial value because of its asbestos content. Commercial asbestos must be offered for transportation and transported in: 1. Rigid, leaktlght packaging such as metal or fiberboard drums, portable tanks, hopper-type rail cars or hopper-type motor vehicles. 2. Bags or other non-rigid packaging in closed freight containers, motor vehicles, or railcars that are loaded by and for the exclusive use of the consignor and unloaded by the consignee. 3. Bags or other non-rigid packagings which are dust and sift proof when transported by other than private carrier by highway, such packagings containing asbestos must be palletized and unitized by methods such as shrink wrapping in plastic film or wrapping in fiberboard secured by scrapping. Pallets need not be used during transportation by vessel for loads with slings that are unitized by methods such as shrink wrapping, if the slings adequately and evenly support the loads and the unitizing method prevents shifting of the bags or other non-rigid packagings during conditions normally incident to transportation. 4. Bags or other non-rigid packagings which are dust and sift proof in strong outside fiberboard or wooden boxes. Oiscaro Date: 100 WfStINOMOUU CINTIMMIAl llUrtm s=3 fe) C0 u---- U Page 2 Asbestos, for example, is not a listed waste under the EPA RCRA regulations. Therefore, as a waste. It Is not required to be manifested according to federal EPA regulations. Since the disposal of asbestos Is regulated but does not require manifesting, except for the State of California which requires manifesting, the documentation should be made on a hazardous shipping paper (with the exception of California) and shown In this format: HM ,, _ ; 10 drums X Waste Asbestos ORM-C 2000 lbs The drum would be marked as follows: Waste Asbestos ORM-C Also a warning sticker The ORM-C marking on a package can be made with a marking pen. The rectangle must be a quarter of an inch larger than the ORM-C. I recommend the use of the attached sticker which can be purchased from Labelmaster or J. J. Keller. Then Waste Asbestos can be shown on the ORM-C sticker. All facilities that wish to dispose of asbestos should check with their state and local municipality, including county, as the transportation requirements may vary in various parts of the United States and other states besides California may require manifesting. Jo5ep\ EV^evineA Manager Materials Transportation Compliance Environmental Affairs Enclosures -- ORM-C Sticker ,, Hazardous Material Shipping Paper JEL/2039J/29 uoocoo-aanu