Document VjzLB50zbbMdZrqvQVDJDYQo

GHQ - September 22, 1971 AIA-42 J-M ENVIRONMENTAL HEALTH TASK FORCE AIA/NA BOARD OF DIRECTORS AND ADMINISTRATIVE SUB-CCMMXTTEE H. M. Ball T. H. Davison, M.D. J. E. Hesse E. M. Fenner H. M. Jackson J. B. Jobe K. V. Li_ndell A. B. Merchant F. L. Pundsack W. P. Raines Ivan Sabour-n C. L. Sheekler F. J. Solon, Jr. A. C. Smith R. R. Standel M. M. Swetonic Carl Thompson W. L. VanDerbeek G. w. Wright, M.D. \c7\ Z* ' /* George Barge A. H. Fay R. Power Fraser W. Gatewood J. A. Rishel F. j. Solon, Jr, E. W. Swain E. P. Stefl S. D. Weaver B. M. F< w. p. Raines M. M.ySwetonic L. Woodward C&'l Thompson ies Callaghan ILLINOIS POLLUTION CONTROL CARD PROPOSED REGULATIONS Attached is a report on fhe meeting held last Friday with Mr. Barker of the Illinois Pollution Control Board staff. Dr. Colin Harwood of XITRI, Dr, George W. Wight and representatives of the asbestos industry. ,* Plana are being worked out for testimony, on behalf of the AIA/NA, at one of the three scheduled public hearings, probably the one in Chicago. Because of its interest in connection with the Waukegan Plant and the recent adverse publicity in the Waukegan newspapers, Johns-Manville will also want to be represented, as an individual company, at the Waukegan meeting. Details of these arrangements will be forwarded as soon as possible. 01-0218291 Kllii. Ayo KNOWLTON, lire. AIA-42 June 15, 1971 MEMORANDUM TO: Mr. W. P. Raines Johns-Manvilie 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. Neil Regan discussed the Illinois situation this morning with Toaothy Harker of the Illinois Pollution Control Board. Barker 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 AlA/HA to talk to members of Lhe uuuu before Lhe hearings. For the record, the Illinois Pollution Control Board Chicago address and phone are as follows: 189 V. Madison Street, Chicago, Illinois 60603 C312-793-3620). . JDC:sdd Enclosure cc: Matt Swetonic ^Jaaes 0. Callaghan 1-0213 AIA-42 \ ? n 71-is ^ Asbestos and Spray Insulation \\ explanation or proposed regulations Scinnce is pointing its medical finger at asbestos and describing the "miracle fiber'* a mineral whose commercial b'le--ssi'n--g--s- c--an eixxaaccit a rather costly toll. -A--s---b--e--s--t--o--s- -i-n--s---u---i-r-.tion and factorryy workers exposed to heavy concentrations of asbestos fiber oov\er p.--rolonged p..e...r..i.o...d..s......h...a..v...e. .s.._u_f_f_e__r_e__d^,d_av.-:5jits consctruences. They arc visited with an alarmingly high in cidence. of nsb.osstosi."",, which produces a diffuse- fibrosis of the lower lung, of' l'u--n--g-----c--a--n---c--e--r""a*n* d of an e---x--t-r--e--m----e--ly rare cancer of the lininu of t_h__e l_u__ng, and a__b_d_o__m__e_n__,__m__e__s_o__t_h_e__li_o__m__a_. The rat_es o_ jft lu. ng_ca_n_c__e__r__a__r.e cxtraordA Jin&_r*lv_ - *h. i*gh% e. spec ially. among asbestos work err, who are smokers, indicating tha syner gistic potential of the mineral, fiber. ` The medical evidence is indefinite ns to why asbestos is r*rr*sr,r>enn>-. -..ith thrna theories in vo;j`ts: Cl) The fibers once ingested or inhaled act as a uontinouc physical irritant, inducing fl Ufi*r 20 to lit years; u) Tno filer* CwTlhMlDi c^r^i such as ben/.o (a) pyrene; (3.) fibers'accumulate in the lung and remain inmobiiiaed as "asbestos bodies" which cause cancer upon disintegration. * Similarly, while ths adverse effect of prolonged exposure to heavy concentrations of anbestos is clcamy documented,* the medical data is disturbingly vogue -as to the results of long term exposure to low' and moderate concentrations. i;or is there a clear dose-time relationship for exposure to heevy concentra tions. In short, an 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 arc agreed upon* T.nat millions of Americans are likely to contain "ashesuoa bodies" in their lungs and that asbestos fiber onco released is relatively indestruct ible. That is, the qualities of durability and of rnsistancs to normal chertjcal and physical stress, which make asbestos such 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, tho PCS has proponed Lhe notion's __ most comprehensive yet of ssbantos^ccntro! s. To ban'all uses of asbestos would be "a1..retina'* at its most clamorous. But ignoring 01-0218308 ' A1A-42 the need to explore and, perhaps, to adopt controls ior the significant contributors to a swelling volur.e of asbar.tos 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 asbestos- containing structures; the manufacturing and processing of asbestos-containing products; the transportalion of certain asbestos-containing products; tho disposal of asbestos-containing waste; and the use of asbestos in the brakes of millions of vehicles. . . Part II would impose several general requirements upon all commercial construction, repair, alteration, demolition, manufacturing or processing activity from which asbestos fiber is discharged into tho environment. The persons responsible for such activity must obtain a permit, from tho >:?A. Tho permit system will serve to produce the advanced -assurrance of corneliancc with the applicable control regulations and will thus raduce Uie cost and burden of in-the--field enforcement. In addition these commercial activities would have to provide facilities to prevent, the removal of asnenros rijoers from the site of such activity on the clothing of employees. Indeed, this poiios a rather-new concept of air pollution control, rnoue wno have died from lunu # iaOin.c.1 *v 1 , tio.sa association to an asbestos worker may be powerful proof of tho need for novelty* *. - Finally, Part II would provide for careful waste disposal procedures, as `wind-blown refuse hsaps and scrap piles contribute to the volume of asbestos fiber in. our air. The simple steps for control eliminate any excuse for such dangorously sloppy housework. . ... *" Part III 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 asbestos, 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 * asbestos-related activities at'construction sites be-done within an enclosure. It wtuld also require that asbestos construction products be so installed as to preclude the emission of fiber into the circulating air. -2- 01-0213309 AIA-42 Part v expresses, ironically, what may be n key reason for banning spray anbustos. 2t would require that procedural safe guards bs purnueti in order to demolish a structure whose destruction would other-rise expose members of the public to asbestos fiber. Clouds of dust are often raised by demolition work. The facts that great numbers of cor sens nay ha exposed to this duct in urban areas -int; that'the post-war generation of high-r^jes were the first buildings to use asbestos insulation extensively speak in favor of some such regulation. Part VI suggests an emission standard fer r.anufacturcrs of asbestos products, The standard is belinvod tube within th capture efficiency cf baghouso iiltraticn. The proposed boundary standard is thought to h<* a method for preventing dilution of exhaust gases. ' The standard would measure only fibers longer than five microns. The justification for this seems to be the administrative con venience of avoiding difficulties in measuring fibers iron- .5 to five microns in length. Medical evidence has indicated that the very srall fibers may be.the most dangerous. And the Bnard will seek extensive evidence on this point. Part VII prohibit-the use of brake lining in vehicles manufactured attor January 1*: 1975 and sold for use in Illinois. If brake lining decomposition emits nsb-vstos fiber, then th tremendous number vehicles using ashestcsi, and the Smnraet** icality'of controlling these numerous small emission sources would appear to speck to the need f.or a product ban. The prohibiticn is carefully wordsd to avoid the neeassitv of fitting vehicles produced prior to 1975 with non-asbestos brake.*:;. It is contemplated that the ban will necessitate design changes, probably to dine brakca, 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. "'*"f ' - 3^'pi'1 ' \IiHi* i*-M-.*>?'>' .-i'.;'* T*!!nw- 'r--r-T' V C/ . W >Jw mmM-. IV* . U 4 ` ^ W ^ *. I 1-021S3 I0 ATA-42 1 Proposed Regulation Only I June 9, 1971 CHAPTER V: TOXIC SUBSTANCES ASBESTOS: SPRAY 1MSULAIICH Talkie of Contents Part 1: rart XI i Part III - Part IV Part V Part VI Part vtl Introduction 101. 102. 103. Authority Policy Definitions General P.ecuirements \ 201. Permit 202. Removal of Asbestos from clothing 203. Waste disposal Snrav Pi reproof 3. nr? and Insulation 301. Spray asbestos prohibited JUi * n}*ia\f Mtdulullwii Construction* Alteration end Repair of Structure 401. Enclosure - , 402. Preclude exposure to circulating air Demolition 501. Xecessary and- practicable safeguards 502. Cessation of demolition work. Manufacturing 601. 602. 603. Emission standard; concentration at boundary Process water Waste sludge disposal Asbestos-Containino Products 701. * Transportation 702. Brake' lining oi- Q21Q31-1 AIA-42 PA'i;'_I: i::-rpODt)CTi o;.' 101. Authority --- Pursuant to the authority in Sections 9, in and 13 of tho Environmental Protection Act which empower tho Hoard to adopt regulations forbidding the ''sale, offer,- or use for reasons of air pollution control" or any tirtiele, and to set "utanriarth; specifying the maximum amounts or concentrations of various contaminants that may be discharged into the atmosphere" j 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 Aoard to constitute an air pollution hazard"; and to adopt effluent standards limiting the amounts of contaminants that nay be discharged into the water of Illinoiu, the Board adopts the following rules and regulations: 102. Policy It is the purpose of the General Assembly in adopting the Environmental Protection Act to maintain anti enhance the purity of the air and water ot Illinois in orcier to protect health, ' welfare and the quality of life. Accordingly, it is ncrooy *.*-u ijt mu* uinu 4*tn: . . i ,,** *> n w * nv.^n * iji* i i into the environment Unds 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 anwunt of asbestos liber released into the environment from tha major sources of emission. Such control is necessary not only to protect those members of the public who are in proximity to heevv concentrations e asbestos fiber but also to safeguard the health . of future generations endangered1by the continuous discharge of ashestos 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 omission standard or of procedural safeguards, such a course has been pursued. In those instances where restriction is unfeasible because of tho tremendouu number of snail, uncontrollable emission sources (automotive)or because of the unusual nature of tho emission source (3pray asbestos at' construction site**'1 a product ban has been resorted to. These prohibitions have been made with full consideration given to the available alternative materials. It is also the purpose of these regulation!; to reduce the emission of non-asbestos particulate from spray-fireprobing and i--0218312 AIA-42 insulation. Co protect against t'mrsa enincienn, tlut biological effects of which are unknown, procouaraJ safeguards have been enacted. 103. 3aftuitions Agency The Illinois Environmental Protection Agency Asbnstos Any fiber or any mixture containing fiber of hydrated silicate mineral, which, on the basis of its crystallino structure, fails into enc of two categories: (1) pyroxonfts - chrysotile fiber; (2) amohibclos - crocidolite* amosite, trend itc, aetinolyto or anthophy1i te fiber. Board Commercial Activity The Pollution Control Eoard of Illinois. - Any activity done for hire or having financial profit as a primary aim. Debris - Asbs tor,-cental ftinc waste produced by the t't .Hi,. I. j.: t>n i.'fr .( Spraying - The pneumatic application oi material used for fireproofing .or insulation. Waste - Any asbestos-containing matter*which has been or is intenaed to be discarded. PART TI: General Requirements Ro commercial activity, not'otherwise hereinafter prohibited, involving the discharge of aabeston fiber into the environment from the construction, alteration, repair os danoiition of a Ktruc ture or from the processing or manufacturing of asbestos-containin 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 the Agency lo engage in such activity. Before obtaining such permit, the applicant shall demonstrate compliance with the following safeguards: * (a) The designation of personnel * ..^creise full time supervisory authority over all ar.pccts oi the activity from which the release of asbestos fiber into the environ . raent could result# in such a manner as to insure compliance *2-- 01-0218313 "~AW42 with the pertinent asbestos control regulations. (b) That each employs** engaged in such activity has completed or will complete a natislacrory course of instruc tion on the potential hezarus of exposure to achnstos fiber including the orceautions that must be observed to prevent or restrict the dispersion of asbestos fiber into the environ ment. .202 (c) That such additional safeguards as are hereinafter specifically required and such precautions conn'stent with the purpose of these regulations as the Agency deems neces sary under the circumstances shall be complied with. Facilities shall be provided and procedures instituted and supervised, that prevent the removal o asbestos-containing material from the site on the clothing of employees. 203. Asbestos-containing wastes shall be immediately vacuumed or otherwise collected whore 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 narked as containing asbestos waste. Such containers shall be nlacnu directly upon a venicle tor disposal bv burial at an up- proved site. Section 2C3 shall not apply to the demolition of a structure, except an provided in Section 501{),.(d) and (e) or to the disposal of sludge waste except as provided in Section 603. PART III: SPRAY FIRSTROOriKG Ann T??SUhAT3C:: 301. The spraying of ashentos-containing material in prohibited. 302. Kon-asbestos particulate matter used for insulation or lira proofing shall not be sprayed uniuse the folio-wins procedures are takeni '. "` (a) Before the start of* spraying operations, all floor areas shall be swept clean and cleared of all objects, material 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-coated tarpaulins. . ' .* *` (b) The entire floor or area to be sprayed shall be enclosed with plastic or plastic- ~wod tarpaulins in a manner which shall preclude the escape of fiber-containing material from the enclosure. All interior open areas such as elevator shafts and stairwells shall be*enclosed in a man ner which shall prevent the escape of fiber-containing -3- 01--021831U AIA-42 natcrial from the working area, "Stack effect" af the sharts, stairwells end cor.perr.blo spaces shall be considered in Droviding proper enclosures. . (c) Regardless of adherence to^ tho stated :.*nntrol practices* any visible* emission o fiber-containing materials beyond th building perimeter will be considered a violation. (d) in case of visible emission of fibrous material from the construction site, immediate steps shall be ta>:en to cause the cessation of such emissions by cither effective control measures or work stoppage at the source of the omissions. There shall then be immediate nd com plete cleanup of all materiel that has escaped the construc tion site, and rcasursa shall be taken that will insure that no further uiapersal of any fibrous material into the atmosphoro can occur. (Q) The entire sprayed area, all ledges and surfaces including tarp_ aulins within the enclosure shall be thoroughly vacuumed upon completion of the spraying operation and immediately before the enclosure is dismantled. The vacuum cleaner shall contain a strong, single-service, disposable inner oag 01 durable iidLttsriai which shall be -removed from the vacuum cleaner and tightly scaled. The bag shall then bo S **. toWMtiAa ^ A *** in accordance with Section 203. (f) All areas used for opening bags containing fibrous material or the changing of hoppers shall be enclosed so as to prevent the escape of such material from . the immediate area in which such activity occurs. (g) Any plenum or othor structure coated with or containing fibrous insulation and used in the circulation of air in a building shall ba thoroughly cleaned of all debris and waste insulation. All applied fiber-containing innulation within a plenum or duct shall be coated with a sealant which precludes exposure of the fiber-containing material to the circulating air. - PART IV* CONSTRUCTION, ALTERATION AND REPAIR OF _STRUCTURE (a) The cutting, trimming, fitting or stripping of asbestoscontaining material in the construction, alteration or repair of a structure which is dono a- cm* site of such structure shall be conducted within a special enclosure designed to preclude the escape of asbestos fiber from the 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. -4- 1--02183 i.5 a AA42P 402 , ' Asbnstos-contninir.g material applied in the construction, alteration or repair of a structure shall be coatort with a sealant, provided with a cover or installed in none other manner no au to preclude exposure of the asbestos fiber to the circulating air. PART V: ns"M0LlT10:; 501. Whore 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 to: ` / , (a)* Boilers and pipes insulated with asbestos-containing material shall be wetted 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 disposed of in accordance with Section 203. ' (b) Demolition by toppling of walls is prohibited **. * * ***;#- Alit * " *' \ ` -- .* n * **Ofe the permit granted for demolition oi that structure. * 1 (c> Before the demolition of any section oi the structure, adequate wetting to suppress1the dust shall bo employed. .. ,. ' (d) Asbestos-ccntaining debris shall not be dropped or thrown front any floor but shall be transported by dust- tight chutes or buckets. Asbestos-containing debris in diutes or buekuts shall bo sufficiently wetted to preclude dust dispersion at the point.of discharge. * . 4 * . (e) All asbestos-containing debris shall be thoroughly wetted before loading into .trucks, other vehicles or con- . tainers. outing transport such waste shailbe enclosed or covered so as to prevent dust dispersion. Asbestos-containing debris shall be disposed by burial at an approved site. ' 502. In the evont asbestos-containing matter becomes air-borne beyond the property boundaries or in .the event freezing temper atures preclude the uso of water for dust suppression, tSenoliton work shall cease until ..itc alternate measures cun be taken. ` 601. PRR? * MANUFACTURING (a) Uo factory, plant or enterprise which engages in the processing or manufacturing of any asbestos-containing product shall emit asbestos fiber into the ambient air in excess of .5 fiber per cubic centimeter of air. The ambient . -5-.. ---------01-0218316