Document X8wy6omJd0XV4mL1bYMN2L4Jg

FILE NAME Flooring Defense Exhibits FLDX DATE 1974 Oct DOC FLDX005 DOCUMENT DESCRIPTION EPA Background Material on National Emission Standards for Hazardous Air Pollutants PB237169 UVM 0 A 2-74-009a a a BACKGROUND INFORMATION | ON NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS PROPOSED AMENDMENTS TO STANDARDS FOR ASBESTOS AND MERCURY IH.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Waste Management Office of Air Quality Planning and Standards Research Triangle Park North Carolina 27711 October 1974 U.S. Department of Comme Comme Comme Nationa Techn cal Information Service Springfeld Virginia 22161 This report is published by the Environmental Protection Agency to report information of general interest in the field of air pollution Copies are available free of charge to Federal employees current contractors and grantees and nonprofit organizatio-nass supplies permit - from the Air Pollution Technical Information Center Environmental Protection Agency Research Triangle Park North Carolina 27711. This document is also available to the public for sale through the Superintendent of Documents U.S. Government Printing Office Washington D.C. 20402 Publication No. 2-74-009a ii TABLE OF CONTENTS LIST OF FIGURES . . . . . . . . . . . . . . .vi LIST OF CHAPTER TABLES ..----- oe 1 INTRODUCTION 2... kes De ee eee ee ee te ee . .vii ee 1 ee CHAPTER 2 ASBESTOS MANUFACTURING 2... 2... 2 a eee 4 SUMMARY OF PROPOSED AMENDMENT . ...-....2.. 4 RATIONALE FOR PROPOSED AMENDMENT 4 Shotgun Shell Manufacture 1... ee 4 eee Asphalt Concrete Plants . 6 CHAPTER 3 ASBESTOS DEMOLITION AND RENOVATION .10 SUMMARY OF PROPOSED AMENDMENTS " .10 RATIONALE FOR PROPOSED AMENDMENTS .11 .11 Addition of Renovation Operations .12 Revisions in Demolition Procedures .13 .13 Definition of Friable Asbestos Materials . . .15 Suspension of Certain Wetting Requirements in Freezing Temperatures .17 .17 Emergency Reporting Requirements . .19 CHAPTER 4 ASBESTOS FABRICATION te e e te ee .21 SUMMARY OF PROPOSED AMENDMENTS ' . 4. e+ ee es .21 CHAPTER 5. RATIONALE FOR PROPOSED AMENDMENTS .2 2-1 1 .21 .21 Field Fabrication . 2... 2. ee ee .24 .24 Central Shop Fabrication ..... .2 ee6 .26 DISPOSAL OF ASBESTOS WASTES . . . . .31 SUMMARY OF PROPOSED AMENDMENTS 2 ... 1. 2. .31 .31 Disposal of Wastes from Manufacturing Fabricating Demolition Renovation and Spraying Operations 2... 2 eee ee .31 Disposal of Wastes from Asbestos Mills . 2... . 31 Waste Disposal Sites 32 RATIONALE FOR PROPOSED AMENDMENTS .. . . 2... 2 33 Process Wastes 6 0... ee ek ee .. 34 Waste Disposal Practices i... ...-.--- 39 Waste Disposal Sites oo + 50 CHAPTER 6 CHAPTER 7 MERCURY EMISSIONS FROM SLUDGE INCINERATION AND DRYING FACILITIES . . Dobe ee ee 73 SUMMARY OF PROPOSED AMENDMENT 2 ee ee 73 RATIONAFLOER PROPOSED AMENDMENT ..... 73 Description of Industry. poe ee ee - 77 ' Mercury Emissions betes eee woe 2 90 ENVIRONMENTAL IMPACT te ek ee he ee ee . 103 ASBESTOS . 2. 1. ee - 103 | MERCURY ee Le 105 CHAPTER 8. ECONOMIC IMPACT 107 ASBESTOS 2...1... - 107 Asbestos Manufacturing ....... Le Asbestos Fabrication ..... 107 110 Asbestos Demolition and Renovation . 111 Disposal of Asbestos Wastes.714 .714 Waste Disposal Sites .....-. eee 116 MERCURY 2 - 121 APPENDIX A. OPTIONAL CLEANING METHODS FOR COMPLIANCE WITH ASBESTOS STANDARD we ee ee ee ee .124 .124 APPENDIX B. CHEMICAL STABILIZAOFTIWAOSTNE DISPOSAL SITES . . 126 iv APPENDIX C. ESTIMATION OF ALLOWABLE MERCURY EMISSIONS FROM SEWAGE SLUDGE INCINERATION FACILITIES .. .132 APPENDIX D. SOURCES CONSULTED DURING STANDARDS DEVELOPMENT .137 LIST OF FIGURES 5-1 Sources of asbestos emissions in Ambler Pennsylvania . 2... 2 ee ee ee ee ee ee eee ee 54 5-2 6-1 6-2 Sources of asbestos emissions in Hyde Park Vermont . . 63 ' Total mercury content of sewage sludge for incineration ; assuming 0 percent control of emissions ....... . 96 Total mercury content of sewage sludge for incineration assuming 50 percent control of emissions . 97 C Calculated maximum allowable mercury emissions from a sewage sludge incinerator under applicable Pasquill stability classes C and D and wind speed of 2 mps .134 vi LIST OF TABLES 4-1 ASBESTOS CONSUMPTION MAJOR PRODUCT CATEGORIES ...... 5-1 SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED OCTOBER 15-18 1973 IN AMBLER . PENNSYLVAN 2. I. A . 5-2 SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED SEPTEMBER OCTOBER 1 1973 IN HYDE PARK VERMONT . . 5-3 AMBIENT ASBESTOS CONCENTRATIONS FROM TAILINGS PILE AND ON PUBLIC ROADWAY 1 . ww ee ee eee . 5-4 ASBESTOS VERMONT CONCENTRATION .. 2. ee ee OF MATERIAL SAMPLES TAKEN IN ee he ee . 6-1 LOCATION OF SAMPLING SITES . 2. 1. ew ee ee ee tee 4 AVERAGE CHARACTERISTICS OF SEWAGE SLUDGE ...... 6-2 MERCURY CONCENTRATION IN SEWAGE SLUDGES DRY SOLIDS BASIS . 6-3 DISTRIBUTION OF EXISTING BURNING CAPACITIES PLANTS 2... ACCORDING TO SLUDGE eee eee 6-4 SLUDGE BURNING CAPACITIES OF LARGEST PLANTS . 6-5 NUMBER OF SEWAGE SLUDGE INCINERATORS 1970 THROUGH 1980 . . 6-6 MERCURY EMISSIONS FROM SEWAGE SLUDGE INCINERATORS . 8-1 C SUMMARY OF ECONOMIC IMPACT OF PROPOSED AMENDMENTS TO ASBESTOS STANDARD ' 1. 1 1 2 ww eee eee ee SOURCE CHARACTERISTICS INCINERATION FACILITY OF A HYPOTHETICAL SEWAGE SLUDGE . 2 1 2 ww ee ee ee ee ee vii 1 INTRODUCTION Section 112 of the Clean Air Act requires the Administrator to list hazardous air pollutants for which he intends to set emission standards and to then establish National Emission Standards for Hazardous Air Pollutants NESHAP for such substances A hazardous air pollutant is defined as . . .an air pollutant to which no ambient air quality standard is applicable and which in the judgment of the Administrator may cause or contribute to an increase in mortality or an increase | in serious irreversible or incapacitating reversible illness National emission standards for three hazardous air pollutants asbestos beryllium and mercury were promulgated on April 6 1973 38 FR 8820 Clarifying revisions to these standards were promulgated on May 3 1974 39 FR 15396 In April 1973 the Environmental Defense Fund filed a petition for review of the standards with the United States Court of Appeals for the District of Columbia This petition led to Agency investigation of additional sources of asbestos and mercury emissions Appendix D presents a summary of the information sources consulted during the Agency's investigation This investigation together with information gained through enforcing the standards has led to the Administrator's determination that the standards should be amended Such amendments are being proposed in the Federal Register The preamble to the proposed amendments includes a brief explanation and rationale for the proposed actions This document provides a more detailed discussion of the statements made in the preamble concerning the basis for the proposed amendments which deal mainly with expanding the standards to cover additional major sources Changes have also been made to improve the uniformity of enforcement and workability of the standards 1 = The basic approach used to develop the standards was to first identify ambient concentrations of the pollutants which were judged to provide an ample margin of safety to protect the public health Allowable emissions were then derived from the safe ambient concenc- oncen- trations by using meteorological procedures For asbestos however it is impossible to prescribe and enforce allowable numerical concentrations or mass emission limitations known to provide an ample margin of safety to protect public health since no safe level has been identified Although improvements have been made in asbestos measurement techniques since promulgation of the standard and although the Agency has used these methods to estimate emissions from two large asbestos waste disposal sites in developing the proposed regulations the techniques have yet to be sufficiently refined to provide a reliable basis for standard setting Therefore the promulgated standard for asbestos includes limitations on visible emissions or as an option in some cases the use of designated control equipment requirements that certain procedures be followed and prohibitions on the use of certain materials or of certain operations The promulgated standard for mercury specifies an allowable mass emission rate which was derived from dispersion estimates as the rate which would protect against the violation of an average daily ambient concentration of 1 microgram per cubic meter averaged over a day period A complete explanation of the basis and rationale for the asbestos and mercury standards that were promulgated on April 6 1973 38 FR 8820 may be found in the preamble to the regulation and in Background Information on Development of National Emission . Standards for Hazardous Air Pollutants Asbestos Beryllium and Mercury EPA Publication No. APTD March 1973 2. ASBESTOS MANUFACTURING SUMMARY OF PROPOSED AMENDMENT' There shall be no visible emissions of containing particulate matter to the outside air from two additional manufacturing operations 1 The manufacture of shotgun shells 2 The manufacture of asphalt concrete As an alternative to the emission standard specified air cleaning methods may be used see Appendix A RATIONALE FOR PROPOSED AMENDMENT Asbestos is a significant raw material in the manufacture of numerous products The standard promulgated April 6 1973 38 FR 8820 limits the emissions of asbestos from nine manu- facturing operations In the course of enforcing the standard for asbestos the Agency discovered that the manufacture of shotgun shells utilizes a substantial amount of asbestos and observed that asbestos emissions were poorly controlled at some asphalt concrete plants On the basis of a subsequent investigation of these two source categories see Appendix D the Administrator has determined that they are major sources of asbestos emissions and is therefore proposing that the asbestos standard be extended to include these two manufacturing operations Shotgun Shell Manufacture The investigation into the manufacture of shotgun shells included a visit to the only shotgun shell manufacturing plant in the United States that is known to use commercial asbestos and discussions with the plant operator and the Asbestos Information Association AIA Asbestos is used to manufacture base wads for shotgun shells The asbestos is mixed with wood flour and wax and then pressed into base wads The weight composition of the final mixture at the plant visited was 54 percent wood flour 36 percent asbestos and 10 percent wax Asbestos emissions can occur during asbestos addition to the mixture during mixing operations and at the wad presses The emission points are vented to the outside air through particulate collection devices The quantity of asbestos used in the manufacture of shotgun shells asa category is about 0.06 percent of the total asbestos consumption in the United States a low usage level for a major source category However the annual asbestos consumption for the shotgun shell plant visited is approximately aproximately 454 metric tons ca. 500 tons The usage of this amount of asbestos at one location is large compared to that of many individual plants that are regulated by the asbestos standard The raw material handling and wad pressing operations potentially generate asbestos emissions comparable to those from manufacturing operations presently covered by the asbestos standard Because asbestos emissions at shotgun shell plants are directly proportional to the asbestos usage rate and because the plant uses relatively large quantities of asbestos the Administrator has determined that the manufacture of shotgun shells is a major source of asbestos emissions and is therefore proposing to cover it under the asbestos standard The gas streams that ventilate the handling systems and presses present no unique problems in employing commercially available particulate control devices The promulgated standard for asbestos manufacturing operations allows no visible emissions of containing particulate matter to the outside air from the facility or as an alternative the use of specified fabric filtration devices or other control devices of equivalent effectiveness The proposed amendment would make this provision applicable to shotgun shell plants Asphalt Concrete Plants In developing the proposed standard for asphalt concrete plants Agency personnel visited several asphalt concrete plants and had discussions with the National Asphalt Paving Association NAPA the AIA asphalt plant operators and distributors of commercial asbestos Asbestos is added to asphalt to give it greater strength and longer wear life The asbestos mixture is usually applied as a thin topping layer and is most commonly commonly used on airport roadways bridges or street curbing Only about 50 of the estimated 5000 asphalt concrete plants in the United States use asbestos each year and the total amount of asbestos consumed by an individual plant will vary greatly from year to year For example in 1971 1972 and 1973 one asphalt plant that was visited by Agency personnel produced 2300 metric tons ca. 2500 tons none and 410 metric tons ca. 450 tons respectiveloyf 3 percent to 4 percent asbestos concrete mix Some 4100 metric tons ca. 4500 tons of asbestos per year are used in the manufacture of asphalt concrete On an annual average this amounts to 80 to 90 metric tons ca. 90 to 100 tons of asbestos per asphalt concrete plant that manufactures asbestos asphalt concrete mix The plants generally use the asbestos within a short period of time usually less than one week Although the annual amount of asbestos used by the individual plants is not unusually high the rate at which individual plants use the asbestos is very high Ninety tons asbestos when used in one week yield an equivalent usage rate of 4500 metric tons ca. 5000 tons of asbestos per year In such situation it is possible to have high concentrations of asbestos in the vicinity of the plant during the period of usage The asbestos emissions of most concern are associated with the asbestos handling and mixing operations that occur during the manufacture of asphalt concrete The asbestos fibers are bound into the asphalt concrete product and the asbestos emissions that occur during the handling and use of the concrete product are not considered to be major sources of asbestos emissions In the manufacturing process asbestos is mixed with dried aggregate After a short dry mixing time hot liquid asphalt is added to the containing aggregate and thoroughly mixed Asbestos emissions to the outside air can occur during the addition 7 of asbestos to the mixing device and from ventilation gases during the mixing operation Asbestos is added to the mixing device during the dry aggregate mixing stage by use of an enclosed conveyor or more commonly by dumping asbestos directly into the mixer in unopened plastic bags When asbestos is added to the mixer by an enclosed conveyor asbestos emissions can occur during the emptying of asbestos into the conveyor hopper and from the ventilation of the mixer The asbestos emissions during the emptying operation can be controlled by hooding and ventilation of the asbestos hopper In the other more commonly used asbestos addition method the plastic bag is ruptured by the mixer and its contents thoroughly mixed with the aggregate The empty plastic bags melt and become part of the product when the hot asphalt is subsequently added to the aggregate mix If the mixer is properly ventilated and under negative pressure no asbestos emissions should result at the point of addition of the asbestos bags however the mixer ventilation gas stream is an asbestos emission point | The raw material handling and the mixing operations potentially generate asbestos emissions comparable to those from manufacturing operations presently covered by the promulgated asbestos standard Since the asbestos emissions at asphalt batch plants are directly proportional to the asbestos usage rate and because some plants use relatively large quantities of asbestos for certain periods of time the Administrator has determined that the manufacture of asphalt concrete is a major source of asbestos emissions and is therefore proposintgo cover it under the asbestos standard The gas streams that ventilatthee mixing operation and handling operation present no unique problem in employing commercially available particulate control devices The asbestos emissions from the ventilation gas stream of the asbestos hoppers and the mixer ventilation gas streams can be effectively controlled with commercially available technology The standard for asbestos manufacturing operations allows no visible emissions of containing particu- late matter to the outside air from the facility or as an alternative the use of specified fabric filtration devices or other control devices of equivalent effectiveness The proposed amendment would make this provision applicable to asphalt concrete plants 3. ASBESTOS DEMOLITION AND RENOVATION SUMMARY OF PROPOSED AMENDMENTS The proposed standard applies to two types of operations 1 The demolition of any institutional commercial or industrial building including apartment buildings having more than four dwelling units structure facility installation or portion thereof which contains any pipe boiler tank reactor turbine furnace or structural member that is insulated or fireproofed with friable asbestos material The renovatioonf any institutional commercial or industrial building structure facility installation or portion thereof involving the removing or stripping of friable asbestos materials used to insulate more than 80 meters ca. 260 feet of pipe or the removing or stripping of more than 15 square meters ca. 160 square feet of friable asbestos material used to insulate or fireproof any boiler tank reactor turbine furnace or structural member The owners or operators of these operations must comply with the following requirements 1 Intention to demolish or renovate and specified details of the operation must be declared to the Administrator in a written notice postmarked at least 10 days prior to commencement of demolition or as early as possible prior to commencement of either emergency demolition or renovation 10 2 Prior to wrecking all friable asbestos materials except those encased in concretoer similar material must be removed either by dismantling in units or sections any apparatus that is insulated or fireproofed with friable asbestos materials or by stripping the asbestos materials from the apparatus Handling procedures for removal are specified 3 Throughout the removal and handling operations all asbestos materials must be wetted except that a Specified air cleaning methods see Appendix A may be used as an alternative to wetting for stripping apparatus that has been removed in units or sections b Wetting requirements are suspended in certain instances when the temperature at the point of stripping is below C 32 4 The demolition of buildings that have been determined to be structurally unsound and in danger of imminent collapse . is exempt from certain requirements including the removal of friable asbestos materials prior to wrecking RATIONALFOER THE PROPOSED AMENDMENTS After promulgation of the asbestos demolition standard on April 6 1973 several questions and comments from demolition contractors were brought to the attention of the Agency concerning identification of friable asbestos materials reporting procedures and work practices acceptable under the standard In response 11 certain clarifying changes which did not alter the intent or stringency of the standard were promulgated on May 3 1974 39 FR 15396 In addition the Agency investigated those questions which involved possible changes in the intent of the regulation Demolition operations involving a variety of sizes and types of buildings were visited samples of friable and friable asbestos materials were taken and demolition practices were observed Additional information was obtained through discussions with demolition trade association personnel demolition contractors and local and State air pollution control personnel see Appendix D The investigation indicated that amendments to the asbestos standard were necessary to more clearly define the intent of applicability of the standard to extend the coverage of the standard and for some operations to make the standard less burdensome to demolition contractors without decreasing the protection afforded Therefore amendments to the standard are being proposed to extend coverage to renovation operations and the stripping and removal of certain items in addition to pipes boilers and supporting structural members to suspend certain wetting requirements under freezing weather conditions and to clarify the types of materials and operations intended to be covered by the standard Addition of Renovation Operations The asbestos standard applies to demolition operations that involve the wrecking of supporting structural members Certain major renovation operations where supporting structural members are not wrecked but where significant quantities of friable 12 asbestos materials are removed , will potentially result in asbestos emissions of a magnitude similar to that from demolition The Administrator has determined that a four apartment building the maximum size apartment building that is excluded from the asbestos demolition standard could contain up to 80 meters of insulated pipe and 75 square meters of insulation on a boiler Renovation operations involving the removal or stripping of quantities of friable asbestos in excess of this amount would create asbestos emissions of the same magnitude as the demolition operations presently covered by the standard Therefore the Administrator is proposing to extend the asbestos standard to cover renovation operations of the scale previously described Rather than requiring 10 days notice of intention to renovate asin demolition operations the Agency has specified that notice of any renovation operation must be provided as early as possible prior to the commencement of the operation In some renovations such as the replacement of a boiler in an apartment building it may be infeasible to delay taking corrective action in order to provide 10 days notice Since the amounotf notice which is feasible will vary from case to case the Agency has made this requirement flexible Revisions in Demolition Procedures The definition of demolition which was promulgated May 3 1974 39 FR 15396 potentially allows circumvention of the intended applicability of the asbestos standard Under 13 the original wording removal of friable asbestos materials is not strictly considered demolition if it is accomplished prior to the wrecking or removal of any supporting structural member The intent of the standard is to control emissions from the stripping and removal of the friable asbestos materials as well as from the actual wrecking operations Consequently a revision to the definition of demolition is being proposed to clarify that demolition involves the removal of friable asbestos materials : or specified items insulated or fireproofweitdh friable asbestos materials as well as the wrecking and removal of supporting structural members Under the asbestos standard only demolition involving boilers pipes and supporting structural members insulated or fireproofed with friable asbestos materials is required to be controlled However enforcement of the standard has revealed that the stripping or removailn units or sections of tanks reactors turbines furnaces and supporting structural members covered with friable asbestos materials can generate asbestos emissions of a similar magnitude The Administrator has therefore determined that the asbestos demolition standard should be expanded to regulate the stripping or removal in sections of these specified items as well since these operations also constitute significant sources of asbestos emissions In addition the asbestos demolition standard is being extended to regulate the stripping of friable asbestos materials from units or sections of pipes boilers tanks reactors turbines furnaces 14 and structural members after their removal from a facility that will be demolished Significant asbestos emissions can occur from such operations and the Administrator is proposing that these operations should also be regulated by the asbestos demolition standard Demolition contractors have commented that the requirement for all friable asbestos materials to be removed from a building or structure prior to beginning demolition is not necessary in certain types of sectionalized structures which are independently supported and that this requirement is unnecessarily burdensome The Agency were being , visited demolition sites where buildings demolished in sections and observed that and structures friable asbestos insulation in one independently supported section was not disturbed by demolition procedures in the adjoining sections The stringency of the standard will not be altered by allowing this practice under appropriate conditions The Administrator is therefore proposing that the demolition standard be amended to allow a supporting structural member to be wrecked before all friable asbestos material is removed from a building or structure provided that a the friable asbestos material in the area that is being actively wrecked is first removed according to the procedures required by the standard and the friable asbestos material in areas not being wrecked is not broken up and can still be stripped or removed prior to active wrecking in those areas Definition of Friable Asbestos Materials The asbestos standard specifies work practices for the handling of asbestos materials during demolition operations only if those 15 materials are friable The use of the word friable is intended to distinguish between such materials as asbestos floor tile in which the asbestos fibers are well bound and such materials as the common types of molded asbestos pipe insulation from which the asbestos fibers can be readily released The intent of the asbestos standard is not to control handling of asbestos floor tile asbestos felt roofing or other similar materials since it is the Administrator's judgment that such activities will not release asbestos in a manner which is dangerous to human health However the standard does not specify a method for determining if a particular containing material is friable Therefore in order to make the intent of the standard more explicit the Agency is proposing to define friable asbestos materials as any materials that contain more than 1 percent asbestos by weight and that can be crumbled pulverized or reduced to powder when dry by hand pressure " Friable asbestos materials is defined to exclude those materials that contain less than 1 percent asbestos by weight The exclusion is intended to be consistent with section 61.22 of the asbestos standard which permits the use of spray asbestos insulation or fireproofing that contains less than1 percent asbestos by weight In the past asbestos insulation or fireproofing materials have generally contained between 10 and 90 percent asbestos by weight No known materials now contain less than 1 percent asbestos by weight except spray insulatioonr fireproofing products and materials that contain asbestos as a natural contaminant 16 It is the Agency's proposed intent that such on.materials not be subject to the stripping and removal provisions of the demolition demolition standard The Agency has received several comments from demolition trade | associations and air pollution control personnel concerning the friability of corrugated asbestos paper insulation The determination of whether this type of insulation is friable is complicated because in some cases it is not friable and in other cases it seems to be Friability of such paper seems to depend on the degree of deterioration of the paper binders New paper insuladtoeisonont seem to be friable however if the insulation has been installed for a long period of time and subjected to a series of wetting and drying cycles it is more likely that the binders will deteriorate and that the material will become friable Therefore the determination friable of whether corrugated asbestos paper insulation is or _ not will be made on a case basis If demolition contractors have questions concerning whether a particular asbestos paper insulation product is friable they should request assistance from the Enforcement Division of the appropriate EPA Regional Office Suspension of Certain Wetting Requirements in Freezing Temperatures The asbestos standard contains no exemption from the wetting requirements during cold weather conditions Demolition contractors commented that wetting at temperatures below C produces freezing of oversprayed water and hazardous footing for workers 17 On the basis of observations of demolition sites during freezing weather the Administrator has determined that the spraying of water in those areas where workers will be walking presents a serious hazard The Agency is proposing a narrow exemption from the wetting requirements during freezing weather in an attempt to balance the hazards of workmen slipping on ice and of increased asbestos emissions due to stripping inside of a building without wetting It should be noted that only the wetting requirements are suspended in freezing weather friable asbestos materials must still be removed from buildinprgiosr to wrecking Procedures are specified in the proposed amendments which will minimize asbestos emissions when the wetting requirements are suspended because of freezing weather Friable asbestos materials must be removed in sections whenever possible prior to the commence- ment of actual wrecking Once these sections are removed from buildings subsequent stripping of friable asbestos materials is not exempt from the wetting requirements regardless of outside temperature Additionally friable asbestos material wastes must be wetted under all circumstances The Administrator has judged that when the above measures are taken the suspension of wetting requirements during freezing weather will continue to protect human health with an ample margin of safety Methods other than wetting with water such as the use of anti- freeze compounds portable evacuation hoods and associated air filtering equipment and the suspension of demolition operations in freezing weather were determined to be infeasible 18 The increment of additional emission control to be gained by each of the above alternatives is outweighed by practical difficulties Emergency Reporting Requirements An amendment to the asbestos standard is being proposed which makes the reporting requirements for emergency demolition operations more explicit Only buildings structures facilities ard installations which have been ordered to be demolished by an authorized representative of the State or local governmental agency responsible for building demolition would be exempted from the requirement of removing asbestos materials before demolition However the proposed amendment requires that the portions of the structure containing friable asbestos material must be wetted during the wrecking operation This requirement applies even in freezing weather since the spraying operation will not erdanger workmen within the building As specified in the asbestos standard it is also necessary that the building structurc facility or installation be structurally unsound and in danger of imminent collapse Agency personnel contacted State and local governmental agencies responsible for building demolition to determine the approximate annual number of emergency demolition demolition operations No specific number was obtained but estimates from State and local governmental agencies indicated that emergency demolition _ operations do not occur frequently _ Under the proposed amendment the report of intention to demolish submitted by the owner or operator of the demolition demolition operation must 19 include the name title and authority of the person who orders the demolition to be carried out The proposed amendment requires such reports to be postmarked as early as possible prior to the commencement of demolition 23 * ASBESTOS FABRICATION SUMMARY OF PROPOSED AMENDMENTS There shall be no visible emissions to the outside air from the fol owing following operations 1 The fabrication of friction products excluding those operations that primarily install asbestos friction materials on motor vehicles 2 The fabrication fabrication of asbestos building products 3 The fabrication of asbestos or silicate board for ventilation ventilation hoods ovens electrical panels laboratory furniture bulkheads partitions and ceilings for marine construction and flow control devices for the molten metal industry As an alternative to the emission standard specified cleaning methods may be used see Appendix A Molded insulating materials that are friable and applied insulating materials that are friable after drying installed after the effective date of the standard shall contain no commercial asbestos applied insulating materialsmaterials are excluded RATIONALE FOR THE PROPOSED AMENDMENTS Asbestos is used in numerous products because of its multi- beneficial properties For example , one company advertises that there are over 3200 end uses for asbestos Although the number of specific uses is large the major uses of asbestos can be categorized 21 into the following groupings Table 4-1 ASBESTOS CONSUMPTION BY MAJOR PRODUCT CATEGORIES Asbestos End Use Floor Tile 1972 Consumption Metric Tons 80,800 80,800 Ca. Short Tons 89,000 89,000 Percent Friction Products Felt and Paper Packing and Gaskets 73,600 109,900 29,000 81,000 121,000 32,000 32,000 10 15 4 Textiles 7,300 8,000 1 Sprayed Insulation 14,500 Construction Industry Miscellaneous 308,700 109,900 16,000 | 340,000 121,000 121,000 2 42 15 This listing is based on the most recent Bureau of Mines reporting format It differs significantly from the method previously used to present such data because it is based on an expanded list of consumers A further breakdown of the 42 percent used in the construction industry is Asbestos Pipe Asbestos Building Products 19 % Floor Tile used in Construction Miscellaneous % % Many of these products are fabricated either at the manufacturing location or at a separate location prior to application in an end use Some fabrication involves cutting or operations which do not generate large quantities of asbestos emissions for example the cutting to size of asbestos floor tile during installation In other instances processing which could be performed at fabrication 22 sites is incorporated into manufacturing operations emissions from this type of processing are already covered by the asbestos standard However some fabrication operations such as the grinding of motor vehicle brake linings can be carried out either at the site of manufacture or at a different central fabricating site Fabrication at a different site is not covered by the asbestos standard The petition of the Environmental Defense Fund questioned the exclusion of fabrication operations from the asbestos standard As a result of these questions the Agency visited 15 plants that perform fabricating operations on manufactured asbestos products and consulted with several plant operators and trade associations see Appendix D From this investigation it was concluded that asbestos products other than friable insulating products are fabricated to only a limited extent but that the fabrication of certain categories of asbestos products in central shops is a major source of asbestos emissions The investigation was thus divided into the two main areas of field fabrication and central shop fabrication The proposed asbestos standard for fabrication includes all known major fabrication categories The major fabrication categories were determined determined by the Agency to be the fabrication of friction products the fabrication of asbestos products and the fabrication of asbestos or -silicate boards for several end uses These categories account for approximately 40 percent see Table 4-1 of the asbestos consumed in the U. S. The asbestos product categories| of floor tile felt and paper packing and gaskets textiles and sprayed insulation account for approximately 35 percent of the U. S asbestos consumption but do not generate significant amounts of asbestos emissions 23 Field Fabrication The investigation revealed that installation of friable asbestos insulation materials for pine boilers reactors turbines and furnaces is the only known major source of asbestos emissions from field fabrication The task of installing and removing asbestos asbestos insulating materials is a known source of occupational asbestos exposure 3,4,5 Asbestos products have been used extensively for thermal insulation of pipes boilers tanks reactors and furnaces The products are used in residential commerciaanld industrial buildings as well as on ships The asbestos functions as a reinforcing agent in molded semicircular sections sheets and blocks of such materials | as magnesium carbonate and calcium silicate Molded asbestos insulation is fabricated by cutting and sawing the insulating material at the site of installation to fit contours of specific equipment This type of field fabrication was common practice in the past frequently at new construction sites for buildings and industrial plants Powdered material of similar composition is mixed with water into a slurry and applied by hand trowel to fill the crevices between molded sections and to insulate irregular shapes Most of the molded asbestos insulating products are friable and can create along with applied insulation significant amounts of dust during fabrication operations Some control methods exist for installation but these methods still permit asbestos | | | emissions The use of molded asbestos insulation is currently being phased out Asbestos insulating products have been developed for a number of applications largely because of the known occupational 24 hazards of installing products such as the common types of molded asbestos pipe insulation These substitutes are available for the complete range of temperature requirements Fiberglasiss used at lower temperatures and refractory fiber insulations can be used for extremely high temperature requirements 8 Because an economical and effective control method i.e. the adoption of asbestos insulating products is available the Administrator has determined that in order to protect public health with an ample margin of safety it would be prudent to prohibit the use of friable asbestos insulating products and is proposing to do so Even though the use of these asbestos ' products in the U. S. has been largely discontinued a regulation is necessary to stop the use where it is being practiced and to prevent the possible future use of friable asbestos insulating | products Asbestos products other than insulating products are fieldfabricated to only a limited extent Asbestos pipes asbestos building products and asbestos board products were found to be fabricated almost completely in central shops The only required field fabrication of such products is drilling holes and cutting pieces to fit in limited number of cases The Agency found that the asbestos products that were fabricated were usually cut with knives or saws equipped with collection devices and holes were drilled with drills equipped with dustcollection devices Accordingly the Agency has determined that the field fabrication of asbestos products other than insulating products is not a major source of asbestos emissions to the air 25 Central Shop Fabrication Friction Products -- Enforcement of the asbestos standard revealed the existence of facilities that fabricate large quantities of automotive brake shoe linings but do not manufacture the linings These fabrication sources are not covered by the standard because the Agency was not aware of them at the time of promulgation The fabricating operations performed at these facilities are similar to those performed at asbestos friction product manufacturing plants which are covered as major sources of asbestos emissions by the asbestos standard The amount of dust generated from grinding drilling sanding and cutting operations is about 450 grams ca. 1 bound for every 30 brake shoes fabricated For a large facility that fabricates over 2 million brake shoes per year this amounts to over 27 metric tons ca. 30 tons of asbestos dust per vear Because the operations are also similar in quantity of asbestos emissions generated the Agency is proposing that the asbestos standard be amended to include these fabrication operations | Agency representatives also visited several individual brake shoe installers to inspect the facilities and operations The ~ installers radius wheel drums as well as brake shoes to ensure good braking immediately after installation Pelatively small quantities of containing dust are generated by the individual installers and even these small quantities were well controlled by fabric filters at the facilities inspected Tho combination brake drum grinding and brake shoe grinding 26 26 machines are equipped with a local dust pickup and a small integral fabric filter for of collection the brake dust On the basis of these inspections the Administrator has concluded that these operations do not cause an atmospheric emission problem and therefore therefore these operations are not included in the proposed fabrication standard Building Products -- Asbestos is used in numerous cement building products The most common asbestos building products include flat sheets corrugated sheets shingles and panels which are used for walls and roofs of industrial buildings canal bulkheads cooling tower construction and other applications Agency personnel visited three distributors of asbestos building products that performed fabricating operations in a central shop The major fabrication operationast these facilities involved sawing trimming drilling and grinding of asbestos building products to meet customer specifications Cooling tower manufacturers that were contacted have all sheets cut and drilled for each cooling tower by the asbestos sheet manufacturer or distributor at a central fabricating ; shop Fabrication in the field is done only occasionally when a cut and drilled sheet will not 9,10 The flat asbestos sheets as used in homes barns or other inexpensive construction are usually installed with fasteners or nails and require little drilling Similarly asbestos shingles are delivered to the job site with punched holes and are nailed to the house ' Additional holes are punched out in the field with an anvil puncher and the siding shingles are using a guillotine cutter and knife Little if any field fabrication occurs which could cause asbestos emissions Fabrication of asbestos pipe by the manufacturers involves 27 machining ends and cutting pipe to exact dimensions which provides for easy assembly and a water fit Therefore fabrication of asbestos pipe rarely occurs after the pipe leaves the manufacturing location The only field fabrication is an occasional cutting or tappinogf a pipe The amount of containing dust generated by central shops that fabricate asbestos building products was estimated to be approximately 90 week ca. 200 week The Administrator has judged that uncontrolled asbestos emissions from such fabrication shops are comparable to uncontrolled asbestos emissions from asbestos manufacturing sources presently covered by the standard and therefore is proposing standards to limit asbestos emissions from these sources Specialty Asbestos and silicate boards are used in construction of ovens electrical panels laboratory furniture ship bulkheads and flow control devices for the molten metal industry For example the molten metal industry requires 1,200,000 1,200,000 board feet of treated asbestos boards per year The number of plants using these boards is large and includes most of the primary aluminum plants as well as many other molten metal handling operations The largest of these facilities do their own fabricating work though many have it fabricated by distributors or small machine shops Data from an aluminum plant that was visited showed that the dust generated during machining of flow control devices for the molten metal industry industry could amount to 1/3 of the board weight prior to machining Asbestos board products are also used for bulkheads and ceilings in commercial vessels and as partition walls in the living quarters 28 of offshore oil derricks Approximately 64 metric tons ca. 70 tons were installed on one transport ship which was inspected by Agency personnel According to discussions with asbestos product manufacturers, there are probably fewer than 10 distributors of asbestos board to the marine industranyd fabrication performed by the distributors generally involves cutting 4- by ft sheets to specified lengths on table saws The Administrator has judged that uncontrolled asbestos emissions from the fabrication of asbestos and silicate boards for ventilation hoods ovens electrical panels laboratory furniture marine construction and flow control devices for the molten metal industry are comparable to uncontrolled asbestos emissions from asbestos manufacturing sources presently covered by the asbestos standard and therefore is proposing an amendment limit asbestos emissions from these sources 29 REFERENCES 1. Clifton R. A. Asbestos Preprint from the Bureau of Mines Washington 1972 Bureau Minerals Yearbook U. S. Department of the Interior of Mines D. C. U. S. AsbestosContairing Product Shipment Values and Asbestos Tonnages Used for the Year 1971 Asbestos Information Association of North America Asbestos Magazine p 33 December 1973 Mangold C. and Control yard March A. R. R. Beckett and D. J. Bessmer at Puget Sound Naval Shipyard Puget 1970 Asbestos Exposure Sound Naval Ship- Selikoff I. J. Jacob Churg and E. C. Hammond and Neoplasia JAMA 188 April 6 1964 Asbestos Exposure Marr N. T. Asbestos Exposure During Naval Vessel Overhaul American American Industrial Hygiene Association Journal 264 May June 1964 National Insulation Contractors Association Notice of Application Order for Variance and Interim Order Denial of Interim Register August 23 1973 pp 22687-22691 Federal Phone 5 and conversations 9 1974 with John Wisnaerd Naval Supply Depot April Phone conversation with Jack Barnhart The Thermal Contractors Association March 14 1974 Insulation Meeting with Al Fay of National Gypsum Ike Weaver of Raybestos- Manhattan and Robert Mereness of the Asbestos Information Association of North America on March 1 1974 Phone conversations with cooling tower fabricators the Marley Company and Research Cottrell February 22 1974 30 5. DISPOSAOLF ASBESTOS WASTES --.. - SUMMARY OF PROPOSED AMENDMENTS . Fabricating Demolition Disposal of Wastes from Manufacturing Renovation and Spraying Operations 4 . There shall visible emissions to theoutsidaier from - any stage of waste handling extending from collection through deposition of 1 containing waste generated by manufacturing and fabricating operations and by the sprayed application of asbestos insulating or fireproofing materials and 2 Friable asbestos waste and control device asbestos waste . generated by oper and a renot vatii on o opern atis ons Alternatives to the emission standard include 1 Spec weti tinf g pi acke agid ng andlabeling procedures - 2 Pelletizing of wastes into friable pellets prior to disposal- Either the collectanid nthge pelletizing of the wastes shall generate no visible emissions to the outside air or spec airi clef anii ng me ethd ods -, see Appendix A shall be used for these operations 3 Other disposal methods approvebdy the Administrator Incineratioonf containers that previously contained commercial asbestos is prohibited _ Disposal of Wastes from Asbestos Mills There shall visible emission to the outside air from any stage of waste handling extending from collection through depositioonf asbestos tailings or control device asbestos 31 waste generated by an asbestos mill As an alternativteo the emission standard the wastes may be transferred to the tailings conveyor in a manner that generates no visible emissions to the outside air and may then be wetted with a suppression agent in a manner that generates no visible emissions Control device asbestos waste may also be handled according to the alternative procedures specified for wastes generated by manufacturing fabricating demolition renovation and spraying operations see previous section Waste Disposal Sites There shall be no visible emissions to the outside air from either active or inactive waste disposal sites where asbestos- containing waste has been deposited Warning signs shall be posted at all entrances to active or inactive waste disposal sites and at least every 100 meters ca. 330 feet along property lines Legend and format of the signs are specified in the regulation~ containing sections of waste disposal sites shall be fenced to deter public access unless specified requirements for coverinthge area with containing materials are met Alternatives to the emission standard are divided according to the type of site 1 Active sections -- Application of a suppression agent or a centimeter ca. inch layer of containing material the end of each operating day or once every 24 hour when the site is in continuous operation 32 2 Inactive sections of disposal sites other than asbestos mill tailings disposal sites -- Application of a 15- centimeter ca. inch layer of compacted non asbestos- material containing on which a vegetation cover adequate | maintained to control wind and water erosion is or 2 application of a centimeter ca. foot layer of compacted containing material maintained to prevent exposure of the asbestos waste from erosion 3 Inactive sections of asbestos mill tailings disposal sites ~~ Application of suppression agents sufficient to control wind erosion or either of the two methods specified for inactive sections of disposal sites other than asbestos mill tailings disposal sites see previous item FO RATIONALE FOR PROPOSED AMENDMENTS The petition of the Environmental Defense Fund the exclusion of asbestos waste disposal operations et al questioned including some portions of asbestos mill tailings disposal operations from the standard In response to the questions raised the Agency initiated a further study of emissions from the disposal of - asbestoscontaining waste materials During the course of this investigation which covered the waste disposal process from the point of waste generation to the ultimate disposal site waste disposal practices were observed at six asbestos mill tailings disposal operations twenty fabrication and manufacturing plants one demolition waste disposal operation and six ultimate waste disposal operations 23 From observations at various facilities of the quantity of waste handled dustiness of the waste and types of handling operations necessary to dispose of the waste it was concluded that major asbestos emissions could occur at any point during the disposal operations from the collection of containing waste to the depositing of the waste at a disposal area The improper operation ofa disposal site where containing waste is deposited can also result in emissions from both active and inactive portions of the site The Agency's investigation included ambient air studies in the vicinity of a large asbestos mill tailings disposal site and a large manufacturing and fabrication asbestos waste disposal site The investigation concluded that 1 the disposal of asbestos waste generated by asbestos manufacturing fabrication spraying renovation and demolition operations is a major source of asbestos emissions and that emissions from all stages of waste disposal from collection to deposition at a disposal site from these operations should be regulated 2 the disposal of tailings and other wastes from asbestos mills is a major asbestos emission source and that emissions from all stages of waste disposal from collection to deposition at a disposal site should be regulated and 3 the asbestos emissions from asbestos waste disposal sites are a major asbestos emission source and should be controlled Process Wastes Asbestos Manufacturing Waste -- The manufacture of numerous asbestoscement board products involves mixing asbestos with cement water and other additives the mixture is subsequently allowed to dry or cure 34 Some of the products must be finished by grinding sawing and polishing while others are ready for shipment without any fabrication Examples of products include density monolithic stonelike board asbestos board for marine applications treated asbestos boards for marine applications treated asbestos boards for the molten metal industry corrugated asbestos siding and blackboards Four basic types of asbestos wastes were observed which can exist at almost all asbestos board plants process slurry wastes asbestos dust collected in baghouses scrap product and empty bags which previously contained asbestos Amounts of each type of waste depend on the product being made and the finishing required For example a large plant that produces 3 million board feed of product per year generates each day approximatelyaproximately 8 cubic meters ca. 10 cubic yards of dust 9 cubic meters ca. 12 cubic yards of scrap board and 9 cubic meters ca. 12 cubic yards : of empty paper bags that previously contained asbestos.. Fourteen pipe plants in the U.S. manufacture for various uses asbestos pipe that ranges from 7.6 to 122 cm ca. 3 to 48 inches in diameter Differences were observed in the waste disposal practices at the plants that were visited during the investigation but the techniques that were observed are representative of those used at other asbestos pipe plants amounts | Substantial of dust and other waste are created in the manufacturing of asbestos pipe The types of waste generated at pipe plants include dust from various cutting and machining operations scrap and broken pipe slurries and solid 35 waste that The slurry includes asbestos shipping bags both plastic and paper is a waste product from the process and contains residual constituents that do not bind into the pipe As an example of the quantity of waste generated a pipe plant in California generates 6 cubic meters of dust 14 cubic meters of paper bags and pipe and 450 kg ca. 1000 pounds of slurry process waste each day In the production of friction products asbestos emissions are controlled from the handling of asbestos in bags and operations such as weighing of raw materials charging of mixers blending of component ingredients and discharging of mixers that involve asbestos in mixed molding compounds However fabricating operations on the products can generate much greater quantities of asbestos- containing dust from the use of band saws abrasive wheels drills cylindrical grinders and circular saws The grinding and drilling of brake linings during manufacture release as much as 30 percent of the lining material as waste In most cases these emissions are significant and are collected in baghouses Discussions with plant operators indicated that 12,200 to 45,400 kg ca. 27,000 to 100,000 pounds per month can be generated by large brake shoe manufacturing facilities The only other asbestos wastes are rejected products and paper or plastic bags which contained asbestos Wastes from the manufacture of asbestos paper consist of asbestos sludge from the waste water and scrap pieces of asbestos paper from edge trimmings and defective rolls The asbestos fibers are held together with such binders as starch glue water glass resins latex cement and gypsum Most of the scrap waste and sludge can be recycled except when binders like rubber are used 36 The paper bags containing the asbestos are pulpable and become part of the final product The cohesive nature of the sludges waiting to be recycled and the entrapped asbestos fibers in scrap paper reduce any potential airborne emission problems Asbestos textile mills consume to 3 percent of the asbestos used in the U.S. in the production of roving carded lap yarn cord rope plaited goods braided tubing tape webbing and cloth Based on an inspection of a small spinning operation wastes consist of dry dusty asbestos wet slurry waste and rejected pieces of yarn Amounts of waste vary depending on the size of the operation and the types of products The small yarn spinning operation which was inspected disposed of 9 kg ca. 20 pounds of waste per day All manufacturing operations producing containing products have the potential to create waste disposal problems The emission potential associated with the wastes differs depending on binding agents and dustiness of the waste For example cement building products in which the asbestos fibers are tightly bound will Most plants pose lesser air pollution problems during disposal mix asbestos waste sucahs shipping bags with non- asbestos waste and the local waste collector either public or private picks up the mixture and usually dumps it in a landfill area These containing waste materials are usually disposed of without regard to their potential as emission sources 37 Asbestos Fabrication Waste -- The basic fabrication operations of sawing shearing grinding milling and drilling of manufactured asbestos products generate asbestos dust which is vented to and is collected by control devices The containing waste generated from such operations includes control device waste as well as scrap products from the fabrication operations Asbestos Demolition andRenovation Waste -- The waste generated by demolition and renovation operations is friable asbestos material waste vacuum cleaner dust and units insulated or fire- proofed with friable asbestos material The asbestos waste can be removed from units or sections in pieces or left intact on pipes boilers and other items and the whole unit disposed of in a section The waste generated from renovation operations is similar in nature to demolition waste Asbestos Spraying Waste -- containing waste from the spray application of asbestos fireproofing and insulating products consists mainly of oversprayed products Approximately 10 percent of the material that is sprayed ends as waste material and has to be disposed of This material is usually collected by sweeping and scraping after a spray application and usually is disposed of in a slightly wet form Asbestos Mill Waste -- Mill waste consists of the ore tailings which vary in size from dust to 1/2 inch diameter and control device asbestos waste baghouse dust All mills except one produce dry tailings The exception uses a wet extraction technique and produces wet tailings 38 Waste Disposal Practices Disposal of Manufacturing Wastes -- Asbestos waste materials generated at manufacturing plants consist of process waste control equipment waste scrap product waste and emptied asbestos shipping bags Amounts and types of wastes that must be disposed of vary with the product production rate and amount of waste that can be recycled Disposal practices vary somewhat among plants but the basic | procedures are similar Collected baghouse dust and other dusty waste are disposed of by 1 transferring the dust from the baghouse hoppetro a truck or trash dumpster 2 transporting the dust to a disposal site and 3 depositing the dust in a landfill Screw conveyor systems are usually used to remove dust from baghouses but an producing method of dumping the dust directly into a truck is also used At another plant 6 cubic meters of dust per day is placed in a truck and wetted down prior to being driven { to a county landfill operation Although visible emissions generally should not occur while the dust is in the dump truck visible emissions occur while the dust is being dumped and buried Baghouse dust that cannot be recycled at one plant is put into a dumpster and transported to a company waste pile The handling of this dust is a potential source of emissions At one large plant 11 cubic meters ca. 15 cubic yards per day is transported in a dumpster to a slurry pond where the dust is emptied and later mixed with water and slurry waste from the rest of the plant An emission problem does exisitn this operation before the dust has been wetted 39 39 One method used to dispose of baghouse dust from machining operations is to transport the collected dust about 1 cubic meter per day in a dumpster with the top sprayed with water and covered with a tarp to a pond where water is mixed with the dust to form a slurry which is subsequently mixed with waste slurry from the manufacturing process Emission potential is reduced during transportation but dust near the pond shows some emissions still occur during dumping | operations To prevent asbestos emissions during transport to a landfill dust can be mixed with water sprayed with water and covered transported in a closed container or pelletized The only disposal techniques for baghouse dust that were observed to be emission- free during landfill operations were those using sufficiently wetted pelletized or slurried wastes Where only small quantities of dust must be handled sealed plastic bags can be used to contain asbestos fibers during disposal Two asbestos brake shoe lining manufacturers use pelletizing units to ensure dust- free conditions during waste disposal operations Baghouse dust from one machining transported about operation on asbestos boards 8 cubic meters per day to a is pelletized and landfill this method greatly reduces air pollution potential from the waste during disposal Only one disposal technique used for friable asbestos waste was observed to produce visible emissions At an asbestos- cement pipe manufacturing plant scrap or reject pipe about 900 kg per day that is not crushed and recycled to the process is hauled by trucks to the plant disposal dump The company An hires a contractor to crush the pipe with a bulldozer about every 8 weeks Some emissions were visible during the crushing operation The visible dust usually settled to the ground in less than 15 seconds and only crossed the plant boundary twice during an hour period | One tyne of containing waste common to almost all manufacturers is shipping bags The handling of these bags which contain residual amounts of asbestos fibers presents| a potential emission problem Several plants observed by the Agency combine the bags with asbestos materials for disposal by trash collectors Several plants seal the emptied bags in plastic bags before combining them in dumpsters or compactors with asbestos waste for disposal One asbestos plant seals the bags in plastic bags about 9 cubic meters per day and then buries them in the plant landfill One manufacturing plant incinerates emptied bags contaminated with asbestos fibers which can result in asbestos emissions There is no known control device available that allows most solid waste incinerators to control particulate emissions to the level achievable for such sources as asbestos mills and manufacturing operations covered by the asbestos .standard There are environmentally acceptable alternative disposal methods for disposing of such waste such as landfilling Accordingly the Administrator has proposed to prohibit the incineration of containers such as paper or plastic bags that previously contained commercial asbestos 41 Process slurry wastes from manufacturing plants are disposed of while wet and do not appear to pose atmospheric emission problems during the disposal process Each asbestos manufacturing plant has somewhat different disposal problems problems that depend on location and recycle capabilities Volumes of process waste slurry can be large for example at one plant about 23 cubic meters per day of the wastes are pumped into a lagoon Smaller amounts of slurry wastes are dumped into the city sewer system at one plant this practice potentially causes a water pollution hazard Process slurry from an asbestos pipe manufacturing plant about 45,000 liters ca. 12,000 gallons per week is transported to a section of a dump where it is allowed to dry in a settling pond When it reaches the consistency of damp clay the material is taken from the pond and stored in piles This material is finally mixed in layers with crushed pipe to form a solid waste pile One plant shovels slurry from a lagoon into piles where it is allowed to partially dry before it is transported to a county landfill about 450 kg per day The county dump requested that the slurry be partially dried before it is brought to the landfill to facilitate handling Slurry from the settling pond at one plant is scooped out placed in closed containers on trucks and taken to the plant landfill There appears to be no air pollution problem in transporting the slurry to the plant landfill At the landfill all plant waste is mixed with waste from the city and covered within 24 hours Slurry wastes are also disposed of from textile manufacturing operations Dried wastes from asbestos 42 products were observed to be cohesive and did not indicate significant emission potential One of the best methods to reduce or eliminate waste materialiss to recycle them into asbestos manufacturing processes Asbestos pipe plants recycle much of their dust waste and scrap pipe However not all pipe can be recycled because of either economics or type of pipe produced Attempts have been made to recycle dust from asbestos boards but the result was a weak product All wastes at an asbestos paper plant can be recycled except scraps of paper containing rubber binders Friction product scraps are generally not recyclable because they degrade the quality of the product Disposal of Fabricating Wastes -- Asbestos fabrication waste materials that must be handied can be classified into three basic types dusty wastes slurry wastes and material scraps Most of the dusty slurry wastes are those collected by emission control systems The amount of this type of waste generated governs the waste disposal techniques which can be used For small amounts of dust up to about 0.3 cubic meters ca. 10 cubic feet per day plastic bags can be used as airtight containers during disposal Several methods are used to handle relatively small amounts of dusty and slurry wastes at various plants Waste collected in the baghouses from table saw operations is placed inside cardboard barrels and labeled with the OSHA asbestos warning notice prior to disposal Waste collected in cloth bags from portable power tools is dumped into plastic bags mixed with cement and water and then added to other trash for disposal 43 One central shop that sizes asbestos boards prior to shipment to a job site generates about 190 liters ca. 50 gallons of dry dust per day from table saws Eight liters ca. 2 gallons per day of dust are collected from portable drills and saws used while the boards are being installed Waste generated from machining asbestos boards for the molten metal industry varies in consistency from fine dust sawing and sanding operations to chips lathes and drills Waste generated from machining can amount to as much as 30 percent of the board weight About 380 liters ca. 100 gallons per day of asbestos slurry is removed from a rotoclone at an aluminum plant that was inspected by the Agency This slurry is transported by a dumpster and compactor to a landfill before it has time to dry and become dusty Baghouse waste from a large distributor of molten metal board is sealed in plastic bags and placed in trash dumpsters for transportation to a landfill The amount of dust generated from textile cutting operations is relatively small and can be disposed of in impermeable containers | Large quantities of dusty wastes are handled somewhat differently than small amounts Waste collected in large baghouses at a brake shoe fabricating plant from drilling and grinding operations is transported by truck to landfills and can amount to 12,200 kg ca. 27,000 pounds per month for a plant producing 40,000 shoes per day At this plant dust from the baghouse is dumped into a special covered dump truck using canvas dust suppressors around each spout Some visible emissions were observed around the bottom of the 44 baghouse which indicates that emissions can occur during the operation water is then added and blended with the dust using a large mixer before the loaded truck is washed to remove asbestos dust and driven toa landfill Some brake shoe fabricating plants use pelletizers which through the addition of water convert the dusty baghouse waste into small balls that are transported to a landfill Cement can be added to the pelletizer along with the | water as an additional binding agent for the asbestos Scrap asbestos wastes can often be handled in the same way as asbestos asbestos wastes if the asbestos fibers have been bound or | encapsulated so that emissions to the atmosphere are not likely to occur This is the case for many asbestos wastes from fabrication involving cement pipe cement boards cement building products | friction products flor tile paper products containing appropriate binders and many gasket materials Scrap boards from most operations inspected are placed in trash bins for disposal along with asbestos wastes One fabricator places scrap boards from the cutting operations inside cardboard drums which are lined with plastic bags These are sealed transported to a storage area covered with a plastic tarp and then -trucked to a landfill Scrap materials from fabricating operations using paper consist of two types scrap pieces of paper from cutting operations and scrap or rejected pieces of finished product In most cases finished product scrap has been modified by the addition of a binding or waterproofing material such as asphalt or vinyl and this material should not pose an air pollution threat repartless of disposal techniques used Unmodified Unmodified paper scran excluding nacer containing a rubber binder can be recycled by the paper manufacturers 45 Some types of asbestos scrap wastes are friable and waste disposal techniques similar to those used in handling asbestos dust should be used The installation and removal of asbestos molded pipe sheet and block insulation during new construction or repair from pipes boilers breechings turbines and furnaces is the largest source of friable asbestos waste materials At one shipyard asbestos waste is collected in plastic bags and put into hoppers for pickup and disposal by a private contractor The amount of waste varies depending on the extent of the repair job and the size of the ship but usually ranges between 0.7 and 4.5 metric tons ca. 3/4 and 5 tons per ship Because asbestos waste is not placed in separate dumpsters from other waste the private contractor handling the waste might not know it contains asbestos The wastes are trucked to a private Candfill The practice of transporting the waste to landfills along with asbestos waste using several types of equipment potentially presents a problem Most of this material is handled by company employees who are unaware of the potential hazard in breathing asbestos fibers Compactors open dumpsters , bulldozers and careless handling of the plastic bags can cause the bags to break open and create an asbestos emission problem Disposal of Demolition and Renovation Wastes -- The friable asbestos materials removed from demolition operations already covered under the asbestos standard are required to be wetted but no additional procedures are provided The Agency's investigation 46 indicates that the demolition debris is frequently deposited in landfill operations Disposal of Spraying Wastes -- Spraying wastes are generally collected and packaged before drying and the containers are subsequently deposited in landfills Disposal of Asbestos Mill Wastes -- Waste disposal practices at asbestos mills are usually different from the disposal techniques used by asbestos manufacturing sources because the mills generate much larger quantities of waste A large asbestos tailings disposal site may have a surface area of 400,000 m ca. 100 acres whereas a large manufacturing and fabrication waste disposal site may have a surface area of 12,000 m ca. 3 acres The largest mill in the United States located in Hyde Park Vermont disposes of over one million metric tons of asbestos tailings annually Smaller operations in California have to dispose of lesser amounts of tailings but such quantities are large compared to quantities manufacturing of wastes from most asbestos . sources Asbestos generally owned mills | dispose of wastes on a nearby area and operated by the mill The asbestos mill tailings contain from _ less than 1 percent asbestos by weight in the case of the Vermont mill to in excess of 30 percent asbestos by weight in California operations _ some Asbestos emissions from wind erosion can result if methods to prevent such emissions are not employed employed During its investigation the Agency visited all six of the major asbestos mills in the United States and conducted an ambient 47 . air study at the large Vermont mill in order to determine whether the disposal of tailings at asbestos mills is a major source of asbestos emissions see Appendix D The Agency's investigation included inspections of active and inactive portions of tailings disposal sites and the deposition distribution of the waste on the disposal sites Mill wastes are usually conveyed from the mill on an enclosed conveyor system to a disposal pile The conveyor system usually requires several transfer operations from one conveyor section to the next For example the Vermont mill conveys the mill tailings over 300 meters ca. 1000 feet to the tailings pile and the tailings conveyor has 13 transfer points Asbestus emissions from the enclosed conveyor and transfer operations are controlled controlled by the asbestos mill standard 38 FR 8820 A primary purpose of the investigation was to observe methods of controlling emissions during the dumping of tailings onto the disposal pile The tailings fall 2.5 to 3 meters from the discharge conveyor to the disposal pile and emissions from this operation are often uncontrolled One mill disposes of dry mill tailings by dropping them onto the pile through an inverted device intended to control emissions A portion of this device is ventilated to help reduce emissions during discharge of tailings through the hood and the ventilation stream is treated in a baghouse This type of dust control technique is evidently not very effective in reducing dust emissions since visible emissions 48 were noted at frequent intervals in an Agency inspection Two mills use another disposal method in which the tailings are wetted with a screw mixer before being discharged to the tailings pile The screw mixing device is usually arranged so that the mixing occurs at a conveyor transfer point One device consists of screw auger approximately 1.5 melt ong e whicr h ts urns in a trough where a spray system installed over the length of the auger wets the tailings _ with water and resinous or petroleum suppression agents No visible emissiownerse noted during the wet tailings disposal operation This method of disposal also helps to reduce windblown emissions from the tailings pile because the wetted tailings after drying form crust which reduces windblown emissions Even walking on one tailings pile did not break the crust layer The wet screw method is judged to be the most most effective method for controlling emissions from asbestos tailings disposal None ! _ of the mills presently operating in the United States would have any major problems installing this system . Freezing weather may cause some operational _ problems but a Canadian asbestos mill has successfully operated a wet asbestos tailings disposal system in _ most cold weather conditions The wet mixing operation is performed in the mill at the bottoomf the tailings conveyor and uses a screw mixer The coarse tailings plus 35 mesh are first mixed with water in the screw mixer with sufficient water to thoroughly coat each particle This wet mixture is deposited on the tailings conveyor belt and finer tailings are then deposited 49 on top of the wet mixture This layered mixture is progressively blended with each transfer point in the tailings system Freezing is not a major problem until temperatures become below -18 ca. F some freezing at conveyor transfer points then restricts the flow of tailings and causes tailings buildup in the transfer chutes This problem might be solved by insulating and heating the transfer points and using nonmetallic chute linings Since a wet tailings disposal system is operated routinely in freezing temperatures above -18 ca. 0 this method of tailings disposal should be generally applicable to asbestos mills in the United States Only one mill in the United States may experience some difficulty in wetting during the winter months because of freezing weather Waste Disposal Sites Control and Maintenance Practice-s- Disposal sites can be classified into two types active and inactive An inactive site or inactive portion of a site is an area where waste has been deposited but where no additional waste is being added and the surface of the area remains undisturbed by waste disposal activities All other sites or portions of sites are defined as active sites since waste is being added or the surface is being otherwise disturbed The basic procedures that are currently used to control emissions are to cover the asbestos waste with soil to grow vegetation or to apply resinous or petroleum suppression agents The coverage with soil or the application of a suppression agent to an active portioonf a site has to be frequent enough to prevent windblown emissions from the waste deposited between periods of 50 coverage or application The coverage or application at the end of the operating day or at least once in each hour period should provide effective control of such emissions . asbestos The _ emissions from an inactive site can be reduced by applying soil to cover the waste and maintaining a vegetative cover or by applying suppression agents to prevent windblown emissions When the waste is covered with soil and a cover of vegetation is planted and maintained the vegetative cover and roots of the vegetation reduce water erosion and prevent wind erosion Since this does not require as great a degree of care as is needed in maintenance for suppression agents it is _ in most cases the most desirable control method For very large sites however this method is not practical For example an asbestos mill waste disposal site can be as large as 400,000 m ca. 100 acres in area and have banked sides of up to 60 Vegetation does not grow naturally on such waste because of the alkalinity of the waste and coverage with soil is very expensive because of the large area Moreover obtaining sufficient soil to cover a large area could itself create land and water environmental problems However resinous or 5 petroleum dust suppression agents have been successfully used to control wind erosion from large sites see Appendix B - These methods are effective with proper site preparation application and maintenance of the agent The surface is wetted with the agent 51 after drying the dust and waste are bound by the adhesive quality of the agent and the waste forms a crust which reduces wind and - water erosion These agents have to be reapplied at intervals ranging from 1 to 3 years to maintain their effectiveness The methods proposed as alternatives to compliance with the visible emission standard for inactive sections of disposal sites require where practical the use of cover Where cover is judged to be impractical i.e. on most asbestos tailings piles another effective control method allowing the use of suppression agents is proposed Since suppression agents must be maintained more carefully than cover and since there may be a water pollution problem associated with improper use of such agents this control method is not specified where cover can be practically applied Ambient Asbestos Concentrations Near Disposal Sites -- The magnitude of emissions from asbestos waste disposal operations such as dumping and distribution and from wind erosion of deposited wastes is not easily evaluated by visual observations The Agency therefore measured ambient asbestos concentrations in the vicinity of the waste disposal area of a large manufacturing and fabricating operation in Ambler Pennsylvania and the vicinity of the tailings disposal area of a large asbestos mill in Hyde Park Vermont These concentrations were then compared to the ambient asbestos background concentrations for the respective areas of the sources Although existing asbestos measurement procedures are reproducible in laboratory comparisons only 52 to within a factor of approximately 5 according to experts the laboratory measured ambient asbestos concentrations analyzed by one making were judged to be useful in relative determinations of whether asbestos disposal sites are major sources of asbestos | emissions The individual studies indicate that the asbestos concentrations in the vicinity of the asbestos waste disposal sites are higher than the background levels by a factor of at least 13 The Administrator has thus determined that uncontrolled asbestos waste disposal operations and sites where asbestos waste is deposited are major asbestos emission sources , and proposing standards for the control of these sources Ambient Asbestos Study in Ambler Pennsylvania -- The potential asbestos emission sources that contributed to ambient asbestos -~',, concentrations monitored during the study in Ambler Pennsylvania are two asbestos manufacturing plants Plants A and B and their active and inactive waste disposal sites Plant A manufactures high- and density monolithic asbestos board and gasket material The manufacturing of boards and gasket material is performed at Building # and the density monolithic boards are transported to Building 2 for grinding and finishing Figure 5-1 Waste generated as a dust 40 percent asbestos from the sanding of monolithic board at Building from the 2 is collected in baghouses The dust is transferred | baghouse to containers where the material is wetted covered and transported to a settling pond about one kilometer away 53 fd a | ~ AOVAS LNY1d Old SLs ABSYLS PILE ALS A'S A'S DN METORLGICASAMPLER METEOROLOGICAL STATION METEOROLOGICAL ZH VO ee ~ LINYId ONIGNG ey LSNLS INISHO s olf / oR MAPLE STRET f an ' ug 3did., d3WNd SS M SEWAGE 00 0G Ma JN N "la|qiuty INVId Ul ee s uSIaTE ACTIVE wa. saga SOIAQGSE x08 JO Sadinas SITE ; . "[- S aunBy FILTER BEDS FILTER NEyaldwys NOILWS NW NW S OW Sources 15101 ae 54 The waste material is dumped into a section of the settling pond mixed into a slurry and pumped to the active disposal lagoon approximately 50 meters away Other containing waste generated at the plant empties into a wastewater system and - is channeled to the settling - Plant B manufactures various sizes of asbestos pipe that contains 10 to 12 percent asbestos generated from machining the pipe ends is collected in a baghouse and recycled rather than being discarded as waste Pipe scraps greater than 30 cm ca. 12 inches in diameter are not recycled and this waste is transported to the disposal pile A large amount of asbestos- containing sludge is created in the wastewater treatment operation recently installed by Plant B. Tank trucks transport the slurried sludge to the disposal lagoon each truck carries approximately 23,000 liters ca. 6000 gallons per load and emptics into the lagoon at rate of about 10 to 12 truckloads per week period When enough water has evaporated the semidry wasties shoveled from the lagoon and piled onto the adjacent disposal area A bullodzer then crushes the discarded pipe the semidried sludge is mixed with the crushed pipe and the mixture is spread uniformly on the disposal pile The crushing operation is performed for approximately 1-1 days of an week period The active disposal sites Plants A and B are adjoining Plant A's site is approximately 20 meters high 90 meters wide and 150 meters long ca. 60 feet high 300 feet wide and 500 feet 55 long while Plant B's site is approximately 6 meters high 90 meters wide and 210 meters long After water evaporates from Plant A's disposal lagoon portions of the lagoon have a dry cracked crust The top layer is light in color has a relatively low density and is fibrous The fibers appear to be bound securely enough so that they are not releasebdy wind action alone The sides of the disposal site are about 46 cm higher than the level of the lagoon and form a roadway approximately 4.5 meters wide Solid material is deposited and spread on this roadway when it becomes necessary to build up the sides of the lagoon Plant B's active waste disposal site is similar to Plant A's A waste disposal site located southwest of Plant A has been inactive for about 4 years and covers approximately 40,000 m ca. 10 acres Figure 5-1 The type of waste material deposited at the site differs from the material currently being disposed of at Plant A's active site Trees grass shrubs and weeds cover approximately 75 to 90 percent of the surface area but little vegetation grows on the north bank of the pile which borders one side of a playground and is close within 15 meters to occupied dwellings This bank is approximately 180 meters long approximately 15 meters high and has a slope of about 60 degrees A sampling network was designed to measure background concentrations to which the public would be exposed and to isolate emissions from specific sources at the disposal sites See Figure 5-1 for locations of the sampling sites The sampling network was composed 56 of ten ambient air samplers and two meteorological wind data systems times at The study was performed on October 15-18 1973. Sampling various sites were 24 hours 12 hours 1 hour and 30 minutes depending on site locations and operations to be isolated Table 5-1 summarizes the site location source of emissions to be isolated sampling time wind speed and direction asbestos concentration and the ratio R of the measured asbestos concentration to the background level It did not rain during the sampling period and therefore the measured concentrations do not reflect reduced emissions which could result from wetting of the various operations and piles . The only activity on Plant B's active disposal pile during testinwags a truck dumping scrap pipe onto the pile twice a day No activity was reported on Plant A's active disposal pile but residue from polishing construction panels was dumped into a section of the settling pond once a day. Samples that isolated specific emission sources were selected i by using measured wind direction and speed The ambient asbestos concentrations listeidn Table 5 range from 3.1 mnanograms per cubic meter to 2600 m The samples obtained were representative of all the potential . emission sources except pipe crushing by Plant B which could not be scheduled during the sampling period Agency personnel observed I the pipe crushing operatioonn October 1 and 2 1973 at Plant B's disposal pile Visible emissions were generated by this operation during approximately 25 percent of the bulldozer operating time Table 5-1 SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED OCTOBER 15-18 1973 IN AMBLER PENNSYLVANIA Case 1 2 3 4 5 6 7 8 9 10 12 Sample NominalNominal Sampling Site Time hr ... 12 2 12 3 12 4 12 5 12 6 12 6 12 7 1 1/2 7 12 8 12 6 24 870 24 Meteorological Data Wind Speed 1-13 mph 2-13 mph 2-13 mph 2-13 mph 2-13 m n . 7-14 mph 1-8 mph 1-8 mph 1-5 mph ' 2-13 mph 2-14 mph 2-14 mph Direction 60 -220 1606-280 1606-280 -270 -280 -270 -280 -270 90 -260 900-270 160 -280 160 -2807 -270 Asbestos Concentration _ Measured ng 3.1 11 12 22 19.0-210.0 29.0-53.0 5.5-16.0 97.0-130.0 48.0 160.0 890-2600 1200 7.2-12.0 13 23 27 49 210 500 Average m *** 12.0 1.0 114.5 41.0 _ 10.7 9.6 3.2 0.9 113.5 9.5 48.0 4.0 150.0 13.3 1745 145.0 1200 500.0 9.6 0.9 21 1.8 253 21.0 Case description 1 Background ambient concentration 2 Windblowr emissions from Plant B's active waste disposal pile 3 Windblown emissiors from Flant A's active bile Windblown emissions from Plant A's active disposal pile banks and roadways 5 windblown emissions from both Plant A's and 3 s active disposal piles Wirdblown emissions from Plant As As active disposal pile 7. Windblown emissions from Plant B's active disposal pile Emissions from dumping of polishing and grinding wastes into settling porc Emissions from wetting and mixing of polishing and grinding wastes Windblown emissions from Plant A s inactive tailings pile near children's playground Windblown emissions from Plant A's active disposal site and truck traffic Emissions from both active disposa piles Samble site descriptidesocripntion 1 Sewage disposal plant - background sampler 2 . Plant B's active pile sampler 3 East sector of Plant A's pile saapler meteorological station West sector of Plant A's pile sampler JAENE North sector of Plant A's pile sampler South sector of Plart A's pile sampler JAEN Plant A's settling pond sampler Playground on Locust Ave. Sammler meteorological station 10 South Chestnut Street sampler 10 far east street side of railroad tracks sampler *** aver concentration ~ aver concentration site # in this at sitc at background study 58 and the generated dust settled quickly . Maximum emissions were 15 percent opacity but averaged approximately 5 percent opacity Once during the crushing operation for a period of 15 seconds visible emissions were observed to go beyond the boundaroyf the disposal site Ambient Asbestos Stu indHyy de Park Vermont potential asbestos emission sources monitored during the study in Hyde Park Vermont are mines and mine roads ore storage areas near the mill ore crushing operations the asbestos mill mill tailings piles and plant roadways surfaced with mill tailings Emissions of asbestos from the mill are covered by the asbestos standard but the mill was operating under a waiver of compliance during the ambient air study The mill operations under waiver were the rock storage building are dryers and all except one of the tailings conveyor transfer points The asbestos ore is mined in two open quarries The ore is then transported by trucks approximately 1 kilometer to the 1 location where it is crushed and subsequently deposited by a conveyor * onto an exterior wet storage pile The crushed ore is charged into the dryers as needed and then conveyed to the dry rock storage building In the milling process dried crushed ore is processed through a series of screens and aspirators where the asbestos fibers are separated and removed from ore The rocks and dust remaining after the milling operation are conveyetdo the tailings pile for disposal 59 Yep eT , Four power shovels and two bulldozers are used to load the trucks with either ore or waste rock in the quarries Three ore trucks serve each shovel when the mine is in operation 8:00 a.m to 12:00 midnight during the sampling program The loaded trucks travel an average of 650 meters from the quarries to the mill over mine roads The roads have a minimum minimum width of 10 meters and a maximum maximum grade of 8 percent During the summer sumer , 1.5 cm -thick layer of mill tailings is applied to the mine roads for surfacing and during the winter the same material is added to improve traction over ericy roads has Ore which n passed through the primary and secondary crushers is stored in an open area called the rock storage area prior to being dried The capacity of the storage area is approximately 68,000 metric tons ca. 75,00075,000 tons ) of ore is The ore moved continuously fromstorage to the dryer by vibrating feeders which are located beneath the surface of the pile The majority of emissions from the storage area probably occur when the ore drops from the end of a conveyer belt tothe surface of the storage area approximately 4.5 meters below however wind could also entrain missions misions missions from the A moves | surface of the pile bulldozer the rock fairly continuously while the conveyer is in operation to keep the area level and to fill the vibrating feeders to ensure a consistent withdrawal rate : from the pile The opening screening aspirating and packaging of asbestos fibers are carried out in the main section of the millwhich has 60 a capacity of approximately 3,200 metric tons ca. 3500 tons of ore per shift day Material in the mill is transferred either by belt conveyor gravity or air stream depending upon the job being performed A dust collector vertical pressure air filter is used as the final filter for the ventilation and process air streams The filtered air from the open pressure baghouses is recirculated to the building to conserve heat during the winter The unit handles air at the rate of 9100 min ca. 320,000 cfm with a 10 cm Ca. 4 inch w.c. pressure loss Ore which has passed through the mill's screens and aspirating hoods is pile has transported been in use to the tailings pile by conveyors . The tailings for over 15 years and contains approximately 20 million 120 meters metric tons of tailings high and 240,000 m ca. The tailings pile 60 acres in area is approximately Several potential emission sources from the tailings pile are conveyor transfer points , vehicle traffic on the pile the deposit of tailings from the _ conveyor belt onto the pile distribution of tailings on the pile with pile a bulldozer and wind erosion The leading edge of the tailings is the portion that is most susceptible to windblown emissions The lower older part of the pile was observed to have a light crust and did not appear to contain finely divided dust A sampling network was designed to measure background concentrations to which the public is exposed and to isolate emissions from specific sources of asbestos emissions in the vicinity of the mine complex 61 See Figure 5-2 for locations of the sampling sites The sampling network was composed of ten ambient air samplers and five meteorological wind data systems The study was performed September 25 through October , 1973. Sampling times at various sites were 12 hours and 4 hours depending on site locations and operations to be isolated Table 5-2 summarizes the site location sourcoef emissions to be isolated sampling time wind speed and direction asbestos concentration and the ratio R of the measured asbestos concentration to the background level Table 5-3 lists the specific data for asbestos ambient concentrations from only the tailings pile from the tailings pile conveyor transfer points and disposal of the tailings and along a public roadway off plant property Table 5-4 presents the asbestos concentration of solid material samples taken from the roadway ore storage areas and mill tailings Asbestos concentrations are presented both for the material as obtained and for the fraction of the material that passes through a minus 140 mesh screen This fraction is of particular interest because particles of this size can be entrained by moderate wind speeds . It did not rain during the sampling period therefore the measured concentrations do not reflect reduced emissions which could result from wetting of the various operations and piles The testing program was completed without any major problems On September 29 1973 the plant agreed to close down certain operations 62 OVERBURDEN DISPOSAL AREA PRIMARY CRUSHER SITE 9 o WET ORE STORAGE SITE 4 3 SITE POWER STATION SITE 5 o SITE 6 oO MILLING DRYER DRY STORAGE SITE 7 QUARRY TAILINGS CONVEYOR -SYSTEM . ROAD ROAD ROAD ROAD PAVED PAVED PAVED PAVED PAVED 2 SITE 0 SITE 10 1@) SIT1E1 OVERBURDEN DISPOSAL AREA SITE 9 Scale 1,000 - ft _| Figure 5-2 Sources of asbestos emissions in Hyde Park Vermont 63 Table 5-2 SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED SEPTEMBER OCTOBER 1 1973 IN HYDE PARK VERMONT Meteorological Data Asbestos Concentration Case 2 10 10A Sariple Win | Wd ind Speed # 2-8 mph Direction 340 - 40 # 2-7 mph 90 - 270 2 2-8 mph 250250 - 295 2 6-9 mph 250 - 295 3 1-7 mph 200 - 230 # 6-9 mph 183 - 247 3 4-8 mph 200- 275 4 3-11 mph 190 - 230 44 3-5 mph 208 - 220 # &4 1-5 roh 135 - 180 01 350 .45 34 5 3-10 m r 140 - 210 5 1-3.5 mph 90 - 270 6 3-10 mph 200 - 230 6 1-9 mph 220 - 310 6 1-3 mph 100 ~ 150 7 3-1 mp 202 - 18 7 5-13 mph 210 - 30 #B 3-10 mph 210 - 120 8 3-5 mph 350 - 60 410 1-5 mph 30 - 90 511 & 1-5 mph - 30 - 90 - Range m Average m 0.012 - 0.180 0.096 0.002 - 0.02 0.008 0.05 - 1.5 0.445 0.15 0.12 - 13.6 0.15 7.35 g 4.2 4.20 -- 1.6 - 13.6 6.57 8 1.3 - 13.1 0.03 4.14 5 0.03 0.002 - 0.4 0.067 0.24 - 10.8 5.2 1.9 -106.5 0.03 - 50.0 0.71 - 8.1 0.03 - 67.6 4.78 - 46.1 0.06 - 7.6 5.2 - 22.9 0.25 - 1.1 0.14 - 0.94 0.06 - 1.2 5.15 5.2 33.56 18.81 3.78 22.5 24 3 9.76 0.54 0.53 0.410 6 E 4.1 2,0 A 28 3,0 1,1 10 - - 0.05 - 7.6 2.091 4 - - 0.002 - 13.6 64 2.33 Table 5-2 continued SUMMARY OF AMBIENT ASBESTOS MONITORING DATA COLLECTED SEPTEMBER OCTOBER 1 1973 IN HYDE PARK VERMONT Case 3Case Case Case Case 5 Case Case Case Case Case Case Case Case Case Case Case Case Case Case Case Case Case Case Case Site Site 2 Site Site 4 Site 2Site Case Description Windblown emissions from mine complex Background samples _ Windblown emissions from tailings pile with conveyor system operating Windblown emissions from tailings pile with conveyor system not . operating Windblown emissions from tailings pile rock storage and mill with mill operating Windblown emissions from primary crusher and are Windblown emissions from tailings pile and dryer shut down tailings pile and rock storage with mill mill with primary crusher not operating Windblown emissions from tailings pile rack storage mill and ore dryer with mill operating with Windblown emissions from tailings pile and rock storage with mill primary crusher and ore dryer shut down Emissions from roadways off plant property mill Windblown emissions from roadways tailings pile ore dryers mill and rock storage Windblown emissions from primary crusher and its conveyor Windblown emissions from tailings pile mill ore dryer and wet- rock storage . ; ' Windblown emissions from wet storage and primary crushing operation Ambient asbestos concentrations in and around working areas Windblown emissions from tailings pile and conveyors Windblown emissions from mill ore dryer and rock storage area Windblown emissions from tailings pile Windblown emissions from mill drying and crushing operations Windblown emissions from tailings pile and milling complex Windblown emissions from tailings pile and milling complex Windblown emissions from only the tailings pile Windblown emissions from tailings pile plus emissions from tailings conveyor transfer points plus emissions from dumping of tailings Ambient concentrations measured along public roadway off plant property Site Description C. Jones Barn Corez Pond Power Substation Far North Equipment Storage Working Area Site 7 Site 8 Site 9 Site 10 Site 11 Site 12 Dry Storage Quarry Road Lowell Quarry Disposal Area Far South Top of Tailings Pile *** = aver aver concentration at site concentration at site # background 65 Table 5-3 AMBIENT ASBESTOS CONCENTRATIONS FROM TAILINGS PILE AND ON PUBLIC ROADWAY Case A Windblown emissions from only the tailings pile Location Date Time hr Asbestos Conc m _ Site 2 Site 8 Site 8 Site 8 Site 8 9/30/73 10/1 10/1 10/1 10/1 1200-1600 . 0800-1200 1200-1600 0000-0400 0400-0800 150 400 1200 240 60 Case B Windblown emissions from tailings pile tailings conveyor transfer points plus of tailings plus emissions emissions from from dumping Location |. Date Site 2 Site 2 Site 2 Site 2 Site 8 Site 8 Site 8 Site 8 Site 8 Site 8 Site 10 Site 10 Site 10 9/26/73 9/26 9/27 9/28 9/27 9/27 9/28 10/1 10/1 10/1 9/28 ' 9/28 9/30 Time hr 1200-1600 1600-2000 1600-2000 1200-1600 0400-0800 0800-1200 2000-2400 0800-1200 1200-1600 1600-2000 0000-0400 0800-1200 0000-0400 Asbestos Conc m 90 50 140 1500 5600 2500 6500 400 1200 7600 260 1100 250 66 Table 5-3 continued AMBIENT ASBESTOS CONCENTRATIONS FROM TAILINGS PILE AND ON PUBLIC ROADWAY Case C Ambient concentrations measured along public roadway off plant property Location Date Time hr Asbestos Conc m Site 1 Site 1 Site 1 Site 1 Site 1 Site 1 Site 1 Site 1 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 2 Site 3 Site 3 Site 3 Site 3 Site 3 Site 3 Site 3 Site 3 Site 3 Site 3 Site 3 Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 9/28/73 9/29 9/26 9/26 9/27 9/29 10/1 10/1 9/26 9/26 9/27 9/28 9/30 9/30 9/28 9/27 9/27 10/1 10/1 10/1 10/1 10/1 9/26 9/26 9/25 9/27 9/27 9/27 9/29 9/29 9/30 9/29 9/30 9/28 9/29 9/26 9/26 9/26 9/27 9/27 9/27 0000-1200 * 1200-2400 0000-1200 1200-2400 0000-1200 0000-1200 0000-1200 1200-2400 1200-1600 1600-2000 1600-2000 1200-1600 1200-1600 0400-0800 1600-2000 0400-0800 0800-1200 0000-0400 0400-0800 0800-1200 1200-1600 1600-2000 0000-0400 0800-1200 1200-1600 0000-0400 1200-1600 1600-2000 0400-0800 0800-1200 1200-1600 1200-1600 0400-0800 0000-0400 2000-2400 0000-0400 0800-1200 1200-1600 0000-0400 1200-1600 1600-2000 12 180 5 2 15 20 3 4 90 50 140 1500 150 2600 180 40 70 50 70 20 83 170 2000 4500 12,700 120 8300 13,100 4500 13,600 4200 1600 2100 13 400 1300 1900 2500 1500 3500 6500 67 Table 5-3 continued , AMBIENT ASBESTOS CONCENTRATIONS FROM TAILINGS PILE AND ON PUBLIC ROADWAY Location Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 Site 4 Date 9/29/73 9/29 9/30 9/28 9/29 9/28 9/30 9/30 9/30 Time hr 0400-0800 0800-1200 1200-1600 0400-0800 2000-2400 0800-1200 - 0400-0800 0800-1200 0000-0400 Asbestos Conc m 13,100 2800 30 22 400 14 8400 150 1800 68 UL UOLzIevy Table ASBESTOS ASBESTOS CONCENTRATION MATERIAL SAMPLES aLQoshy YSAW Site Site INOWUSA siteabove test test NI - NFAVL SATIdWYS Wet tailings tail ngs storage pO z0 0 2.4 (02 OTL: TWIXSLVW30 sandsandsite rock pz Z 0 10.7 LOL 8Ol ~ NOILYFNOD siteDry site site % SOLIGSY UL peaeuB0} (quawred e6Pu04S abeuozs b-S ysnOL# Ysowpasn) sbut[pasn) pour OL UOLJTUDSag (sAemyBL afeuoys Sigel peou 93F1S a40- + sbulj zl led apes Z# : y20u~-Auq 8315 wou, aoge 483} 19M we/ln Led eudse yp/L uoy pues 3415 Aug82LS # aldues cd tf vd GZ SZ c3 69 to enable the isolation of potential asbestos windblown emissions from the tailings pile The sampling sites were located to isolate specific emission sources and also to have background samples for each specific emission source After the meteorological data and the plant operations data were checked samples were selected which represented emissions from specific sources For more information on the selection of sampling sites and validation of selected samples refer to Table 5-5 70 Table 5-5 LOCATIOONF SAMPLING SITES Site 1 - In order to determine background ambient asbestos concen- trations a sampler was placed at Mr. Jones barn Mr. Jones barn is approximately 1.51.5 kilometer SE of the mill with prevailing vailing winds from the SW the ambient concentrations obtained were representative background levels Site 2 - The Corez Pond location was selected as a sampling site to measure windblown emissions from the tailings pile With a westerly wind emissions from the mill were excluded and only emisions emissions from the tailings pile measured Site3 - In order to measure windblown emissions from the entire mine complex samplers were placed on the northern side of the mine complex With the wind prevailing from the S SW the power substation was directly upwind from the minemill complex complex Site 4 - A sampler was put at site 4 because although although this i location was also directly upwind from the mine complex it was more removed from the mine than } site 3. By selecting samples taken at site 4 with samples taken at site 3 at corresponding corresponding times the dispersion or fallout of emissions from the mine complex could be determined 71 Table 5-5 continued LOCATION OF SAMPLING SITES Site 5A 5A 5A sampler was placed at the Foundry Building to measure the emissions from the primary and secondary crushers and also from the wet storage pile The crushers Site 6 and ore storage pile are very close to each other which caused difficultiyn distinguishing the individual | emissions | A sampler near the Engineering Drafting Building measured fallout emissions from the two ore dryer stacks At this site the ambient asbestos concentration inhaled by workers in this area was measured Site 7 The main objectives in placing a sampler on the tailings pile near the dry storage area were to measure windblown emissions from the tailings pile and emissions from the Site 8 ventilation system of the rock storage building This sampler measured windblown emissions from the side of the asbestos tailings pile and served as background Site 10 for samples obtained at site 2 This sampler measured windblown emissions from the mill Site 11 and tailings pile and also served as background for samples taken at sites 3 and 4 This sampler measured background asbestos concentrations and emissions from blastinign the quarries 72 6. MERCURY EMISSIONS FROM SLUDGE INCINERATIAONND DRYING FACILITIES SUMMARY OF PROPOSED AMENDMENT Emissions to the outside air from sludge incinerat pliao ntns sludge drying plantosr a combination of these that process waste- water treatment plant sludges shall not exceed 3200 grams of mercury per hour period RATIONALE FOR PROPOSED AMENDMENT Disposal of wastewater treatment plant sludge is a responsibility of all major and many smaller municipalities and also various in- dustries that choose to dispose of their own wastewater treatment plant sludge the majority of casers aw waste is transported to centralized wastewater treatment plants where various waste treatment methods are used to process the raw waste into sludges that must be disposed of in the environment land water air or a combination of these media Mercury emissions result from the incineration and drying of sludge that contains small quantities of mercury At the time of proposal and promulgation of the national emis- - sion standard for mercury March 31 1971 36 FR 23239 and April 6 | - 1973 38 FR 8820 respectively available information indicated that sewage sludge incineration plants did not emit mercury in a man- ner that could cause the ambient concentration to exceed the inhala- tion health effects limit of 1 microgram per cubic meter averaged 73 over a day period Consequently the Administrator determined at that time that it was not necessary to regulate mercury emis- sions from this category of sources in order to protect public health with an ample margin of safety At the time of promulgation information available to the Agency included mercury stack emission tests at five sewage sludge incineration plants Of the five emission rates determined the maximum was 125 grams of mercury.per mercury.per day based on one test which was later judged to be invalid on the basis of mercury mass balance calculations Emissions for the re- maining four tests ranged from 1 to 40 grams of mercury per day After promulgation of the national emission standard for mer- cury questions concerning the impact on public health of mercury emissions from sewage sludge incinerators were raised by the Environmental Defense Fund et al in their Petition for Review of the national emission standards for hazardous air pollutants Similar questions arose in connection with proposals to construct several large sludge incineration facilities In response the Agency initiated a study to more completely characterize emissions of mercury from sewage sludge incinerators see Appendix D The results from one of two stack tests that were performed during the more recent investigation are available The emission results from this test and the four former tests suggest that a significant quantity of mercury is collected by water scrubbers 74 Mercury is emitted from the drying of sludge and the incin- eration of industrial wastewater sludge as well as from the in- cineration of municipal sludges There are approximately 280 municipal sludge incineration sites 17 sludge drying sites and an undetermined number of industrial industrial waste sludge incineration sites in the U.S. The pretreatment of industrial wastewater wastewater streams to remove mercury before discharge into municipal wastewater wastewater treatment streams may be required in the future This could produce industrial sludges might be incinerated higher concentrations of mercury than either municipal or combined industrial wastewater treatment plant sludges Mercury concentrations of sewage sludges nationally average about 5 ppm on a dry solids basis however approximately 10 percent of the sludge samples have mercury concentrations in excess of 15 ppm Very large sludge incineration facilities are being contem- plated for the future for example one existing facility will in the near future incinerate 900,000 900,000 kg ca. 2 million pounds of dry solids per day If sludge with the highest reasonably expected mercury con- tent of 15 ppm parts per million were incinerated and if only 50 percent of the mercury in the sludge were emitted into the atmos-atmos- phere the plant would emit 6,800 grams of mercury per day This amount is over twice the maximum allowable mercury emissions that will protect the public health with an ample margin of safety Sludge incineration facilities with capacities of 1,800,000 kg 75 ca. 4,000,000 pounds per day are being planned for operation in | 2005 In view of the potentially large mercury emissions from sludge incineration plants the Administrator has determined that it is prudent to regulate mercury emissions from this category of sources While no sludge incineration facilities are known to be exceeding the proposed mercury emission limitation at this time the proposed standard will prevent a mercury emission problem from occurring in the future by ensuring that new and modified facilities investigate and provide for limiting potential mercury emissions | prior to construction The proposed emission limit of 3200 day was derived from dispersion estimates as the level which would protect against the violation of an ambient mercury concentration of 1 microgram per cubic meter averaged over a day period The meteorological estimating procedure is the same as that used to develop standards for mercury ore processing facilities and mercury alkali plants 38 FR 8820 except that emission release conditions representative of sludge incineration sites are used The assumptions and equations used to make the dispersion estimates are discussed in AppendixC of this report Both the original national emission standard for mercury and the proposed amendments are designed to control the concentra- tion of mercury in the ambient air adjacent to the point source Since the standard is concerned primarily with the threat posed by inhalation of mercury in air immediately proximate to the point 76 source it does not deal with the poten ial range hazard posed by the addition of mercury from these point sources to the total environmental burden Not addressed for example is the mercury discharged from alkali ore processing and sludge incineration plants that can eventuallbye transportetdo water systems where it may potentially be methylataendd bioconcentrated in fish The Agency has become increasingly concerned about the total environmental burden of mercury however and is initiating studies to determine how this aspect can most effectively be addressed under the provisions of the Clean Air Act and other authorities Description of Industry Raw waste originates from a variety of sources which can be roughly classified into the major categories of industrial and residential sources The raw waste is transported to wastewater treatment plants Primary treatment of raw waste waste is designed to remove the bulk of the dissolved solids present In many cases the waste- water remaining after primary treatment is given secondary and in a few cases tertiary treatment prior to discharge Sludges produced by primary treatment can be combined with secondary and tertiary sludges . prior to final disposal . Average characteristics of dry sewage sludge solids range from 30.2 to 88.5 percent combustiblferosm 11.5 to 69.8 percent ash and from 9,300 cal ca. 16,750 Btu for grease and scum to 2,220 cal ca. 4,000 Btu for grit Characteristics of both raw and digested 77 sludge fall within these ranges Table 6-1 presents the average characteristics of various sewage sludges Sludge characteristics such as dryness of solids percent combustibles and percent ash can be modified significantly by the addition of filter aids such as lime ferric chloride and polymers Prior to incineration concentrations of elements and materials in sewage sludge are usually expressed on a dry solid basis Dry solids are also called total residue The residue after incineration is called ash or fixed solids The laboratory method for determining dry solids total residue and ash fixed solids is described by American Public Health Association APHA American Water Works Association AWWA and Water Pollution Control Federation WPCF .2 Sludge concentration data from approximately 42 sewage treat- ment plants indicate a range of mercury content on a dry solids basis from 0.6 ppm to 43 ppm the average value is 4.9 ppm Table 6-2 lists the individual values of mercury concentration in sewage sludges The upper limit would be 90 ppm but 90 ppm and three other values from Bergen County and Joint Meeting New Jerseiyn October 1971 seemed inordinately high compared to the other values in the table Additional sludge samples obtained from these same facilities in November 1973 averaged 9.2 ppm as compared to the October 1971 average of 75.5 ppm It is concluded that the October 1971 values are erroneous due to sampling or analytical errors .78 Table 6-1 7 1 AVERAGE CHARACTERISTICS OF SEWAGE SLUDGE Material Grease and scum Raw sewage solids Fine screenings Ground garbage Digested sewage solids and ground garbage Digested sludge Grit Combustibles % 88.5 74.0 86.4 84.8 49.6 Ash % 11.5 26.0 13.6 15.2 Heat Content cal 9300 5710 4990 4580 Btu 16,750 10,285 ( 8,990 ( 8,245 50.4 4450 ( 8,020 59.6 30.2 40.4 69.8 2940 2220 ( 5,290 ( 4,000 79 Table 6-2 MERCURY CONCENTRATION IN SEWAGE SLUDGES DRY SOLIDS BASIS Data No. 123 123 123 ALO3 ALO3 ALO3 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Sewage Treatment Plant Location Chicago Illinois Chicago Illinois Chicago Illinois 7 , . Chicago Illinois - Chicago Illinois Chicago Illinois 4 Greensboro North Carolina San Lorenzo California San Mateo California Edmonds Washington Morristown Pennsylvanial Lynwood Washington Tahoe California Tahoe California Tahoe California Tahoe California Tahoe California Tahoe California Tahoe California Barstow California Barstow California - Barstow California Lorton Virginia Lorton Virginia mo, Lorton Virginia Lorton Virginia Lorton Virginia Cincinnati Ohio Cincinnati Ohio Dayton Ohio Indianapolis Indiana Indianapolis Indiana Indianapolis Indiana Monterey California Monterey California Bergen County New Jersey Bergen County New Jersey Bergen County New Jersey Passaic Valley New Jersey Middlesex County New Jersey Joint Meeting New Jersey Date of Collection 3/18/71 3/19/71 3/22/71 3/23/71 3/24/71 3/25/71 7/71 7/71 7/71 7/71 7/71 7/71 7/15/71 7/15/71 7/15/71 7/15/71 7/15/71 7/15/71 7/16/71 7/21/71 7/21/71 7/22/71 7/71 7/71 7/77 8/5/71 8/5/71 8/20/71 8/20/71 8/25/71 8/23/71 8/23/71 8/23/71 10/14/71 10/14/71 10/26/71 10/26/71 10/26/71 11/1/71 10/25/71 10/27/71 Mercury _ppm 4.6 4.8 4.8 4.7 4.6 4.7 6.5 5.6 5.0 3.8 6.0 5.3 5.5 5.5 5.7 12.0 15.0 7.5 7.5 5.5 5.5 5.5 4.6 2.6 2.0 1.9 4.0 6.0 3.6 11.5 4.2 3.0 3.6 8.6 9.0 88.0 88.0 90.0 50.0 3.9 4.9 74.0 See text page 78 for discussion of these values 80 Table 6-2 continued continued MERCURY CONCENTRATION IN SEWAGE SLUDGES DRY SOLIDS BASIS Sewage Treatment Plant Location Location Northwest Bergen Bergen County New Jersey Northwest Bergen Bergen County New Jersey Cedar Rapids Iowa Iowa . Cincinnati Ohio Ohio Cincinnati Ohio Ohio Cincinnati Ohio Ohio Cincinnati Ohio Ohio Cincinnati Ohio Ohio Dayton Ohio Columbus Ohio Columbus Ohio Columbus Ohio Columbus Ohio Columbus Ohio Columbus Ohio Columbus Ohio Piscataway Maryland` Piscataway Maryland 6 City Unknown Indiana City Unknown Indiana City Unknown Indiana City Unknown Indiana City Unknown Indiana City Unknown, Indiana City Unknown Indiana City Unknown Indiana City Unknown Indiana Kansas City Missouri Missouri Kansas City Missouri Missouri Sioux City Iowa Iowa Joplin Missouri Grand Island Nebraska Nebraska Jefferson City Missouri N.W. Bergen Co. Waldwick New Jersey N.W. Bergen Co. , Waldwick New Jersey N.W. Bergen Co. , Waldwick New Jersey N.W. Bergen Co. , Waldwick New Jersey N.W. Bergen Co. , Waldwick New Jersey Joint Meeting Elizabeth New Jersey Joint Meeting Elizabeth New Jersey Joint Meeting Elizabeth New Jersey Date of Collection 11/18/72 11/18/72 2/22/72 1/24/72 1/25/72 1/26/72 - 4/3/73 4/3/73 4/4/73 2/27/73 2/27/73 2/27/73 2/27/73 2/26/73 2/27/2/27/73 72/237/73 2/27/73 8/8/73 8/9/73 Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown 11/12/73 11/13/73 11/13/73 11/13/73 11/13/73 11/13/73 11/13/73 11/14/73 Mercury 12.0 10.513.0 13.0 11.0 11.0 11.0 0.83 0.83 0.83 2.8 5.2 1.0 1.0 2.3 13.2 13.2 1.8 2.02.0 4.6 1.8 5.0 3.0 5.0 43.0 43.0 26.0 1.0 5.0 5.9 3.6 3.9 7.3 5.8 5.8 14.5 11.6 1 .6 81 Table 6-2 continued MERCURY CONCENTRATION IN SEWAGE SLUDGES DRY SOLIDS BASIS Data No. 83 84 85 86 87 88 89 90 91 92 93 94 95 96 98 Sewage Treatment Plant Location Bergen County Little Ferry Bergen County Little Ferry Bergen County Little Ferry Greensboro North Carolina 9 Pittsburgh Pennsylvania Pittsburgh Pennsylvania Hartford Connecticut Hartford Connecticut New Haven Connecticut New Haven Connecticut Detroit Michigan Detroit Michigan Chicago Illinois Chicago Illinois Indianapolis Indiana Indianapolis Indiana New New New Jersey Jersey Jersey Date of Collection 11/13/73 11/13/73 11/14/73 12/7/73 12/73 12/73 12/73 12/73 12/73 12/73 12/73 12/73 12/73 12/73 12/73 12/73 Mercury ppm 7.1 5.7.7 5.5 5.5 3.3 3.3 3.7 3.7 e * | 2.3 2.62.6 2.6 * !t' 2.0 2.0 Result not available at present time The total input of mercury to an incinerator or dryer may be ' calculated by multiplying the concentration of mercury in the sludge by the total incinerator sludge incineration or drying rate according to the following equation| CH9 Hg = CH9 x 103 1 , | where CHg concentration mercury ppm dry solids basis S = sludge incineration or drying rate day dry .,'. solids basis. Hg mercury incinerator input grams per day - x 103 conversion 83 Incineration of sludges involves combustion of greater than 99 percent of the combustible content of the sludges Drying is the removal of water from sludge by heating it with combustion gases to a temperature above 65 ca. 150 Flash drying is the almost instantaneous removal of moisture from solids by introduction into a hot gas stream Temperatures of incineration range from 700 to 980 ca. 1300 to 1800 Auxiliary heat or fuel requirements to maintain these temperatures depend upon the combination of moisture and combustible content of the sludge Dwell times of sludge at this temperature range from less than 10 seconds in a cyclonic reactor to a much longer time in a multiple furnace Inert ash is produced by incineration and this ash is disposed of mainly by landfill although it is sometimes used in the manufacture of building products The principal types of sludge incineration systems currently used in the United States are listed below in order of number in use 1. Multiple 2. Fluidized bed 3 Flash drying with incineration 4. Wet oxidation 5. Cyclonic reactor Flash drying is the major sludge drying process used in the United States and consists of the introduction of dewatered sludge 84 15 to 25 percent dry solids into a hot combustion gas stream that is normally maintained at a temperature of 590 to 700 ca. 1100 to: 1300 The sludge is heated to a temperature of approximatel6y5 to 95 ca. 150 to 200 and its moisture content is reduced to 8 to 10 percenThte dried sludge can then be usefdor various purposes including fuel and fertilizer Systems have also been designed so that sludge can be dried in modified multiple incinerators sludge temperatures are similar to those used for flash drying Existing capacities for incineration or drying of sewage sludge range from less than 4,540 day ca. 10,000 day to approximately 454,000 day ca. 1,000,000 day on a dry solids basis Table 6-3 presents the distribution of sludge burning capacities of existing plants The largest known capacities in the U.S. are presented in Table 6-4 Detroit Michigan will have the largest existing burning capacity at 862,600 day ca. 1,900,000 day and an actual burning rate of 408,600 day ca. 900,000 day as reported in Table 6-4 However Chicago Illinois is producing approximately 681,000 day ca. 1,500,000 day of dry solids an average of 408,000 day ca. 900,000 day are disposed of on land and 272,400 day ca. 600,000 day are flash to 97 percent dry solids for subsequent use as fertilizer Based on tests performed at the Southwest Treatment 10 Plant in Chicago approximately 40 percent 10 of the mercury that enters the dryer is volatilized 85 Table 6-3 DISTRIBUTION OF EXISTING PLANTS ACCORDING TO SLUDGE BURNING CAPACITIES" Dry solids burning capacity day day Less than 4,540 Less than 10,000 4,540 to 45,400 45,400 10,000 to 100,000 100,000 45,400 to 227,000 100,000 to 500,000 Greater than 227,000 Greater than 500,000 500,000 Number of plants 17 173 37 6 This tabulation derived from installation lists of major manufacturers 1973 represents approximately 83 percent of existing plants 86 Table 6-4 SLUDGE BURNING CAPACITIES OF LARGEST PLANTS Dry Solids Burned Location Detroit Mich . | J , Actual day ca. day 408,600 900,000 Capacity _ Actual Plus Current Construction | day ca. day 849,900 1,872,000 Cleveland Ohio Minn - St. Paul 136,200 = S =~*S 272,400 600,000 544,800 1,200,000 472,160 1,040,000 St. LouiMso. Bissell Louisville Ky : Cincinnati Ohio 76,270 : . 168,000 283,750 7 272,400 261,500 625,000 ( 600,000 ( 576,000 Pittsburgh Pa 108,960 240,000 217,920 480,000 Indianapolis Ind 136,200 300,000 181,600 ( 400,000 St. Louis Mo. Le May 54,480 Hartford Conn Kansas City Mo. 54,480 - 54,480 120,000 120,000 120,000 170,250 ( 375,000 163,440 | 150,270 360,000 ( 331,000 87 Raw waste supply to wastewater treatment plants and in turn to incinerators will increase because of increasing population consolidation of sewer systems tertiary treatment of sludges and increasing use of sewerable materials Direct land disposal ocean disposal and incineration and drying of sludges will continue to be used for sludge disposal An accurate prediction of the favored method of disposal is not possible at this time because of energy and economic considerations and land and water disposal site availability availability Table 6-5 shows the estimated sewage sludge incinerator increase through 1980. The figures may be reduced because of energy considera- considera- tions but are the best estimates at this time The size distribution of the additional incinerators is expected to be similar to those shown in Table 6-3 Existing sewer systems in the United States and potential future systems could produce large amounts of waste sludge Estimates of dry solids sewage produced per capita at present range from 95 to 182 day Using the average per capita figure of 136 day and assuming a New York City population of 10,000,000 served 1,362,000 day of sewage sludge on a dry solids basis would be produced This would require at present an incineration capacity three times as large as any in existence and would require an even larger burning capacity for contingency and future needs Detroit has range plans past the year 2000 for potential burning capacities of approximately 1,816,000 day of dry solids four times their present capacity Detroit currently has additional incineration capacity in construction and expects to have total capacity of 908,000 day of dry sewage sludge in operation in 1975. Chicago the Los Angeles area and other metro- 88 Table 6-5 NUMBER OF SEWAGE SLUDGE INCINERATORS 1970 THROUGH 1980" Year 1970 1973 1975 1977 1980 Number 200 275 oe Comments Manufacturer's estimate Manufacturer's estimate 375 515 Estimated 30 for 1974 and 70 for 1975 = Ssit^'iE Estimated year 725 Estimated year Factors such as the availability of alternative methods of sludge disposal and auxiliary combustion energy when necessary will have a significant effect on the actual rate of construction 89 politan communities produce large amounts of sewage sludge that are not disposed of by incineration at this time but could be in the future Presently New York City disposes of its sludgien the ocean and Chicaghaos the capability to use a variety of treatment and disposal methods Large population centers may in the future install much larger incineration capacities capacities than are currently in operation Although auxillary fuel is a consideration that will tend to discourage the short use of sludge incineration new more efficient sludge dewatering processes may make incineration more attractive as a . 7 7 sludge disposal method Mercury Emissions As previously stated stack emissions were tested at seven sewage sludge incineration sites Table 6-6 summarizes the test data Results from the Piscataway Md plant are not yet available All sites used a water scrubber particulate emission control device Operating scrubber pressure drops ranged from 6.4 cm water column w.c. ca. 2.5 in w.c. at the Fairfax County Virginia incinerator to 145 cm w.c. ca. 57 in w.c. at the Piscataway Maryland plant Mercury removal efficiencies of water scrubbers varied from a high of 96 percent at South Lake Tahoc California to a low of 68 percent at Waldwick New Jersey Data from the Barstow California test are considered invalid because they show that a quantity of mercury four times greater than the mercury content of the sludge incinerated was emitted from the stack during the test indicating a mistake in the sampling or in the handling or analysis of the samples No correlation has been established between the process or scrubber 90 . 4op2e} /P37 asbpon,sAAP MERCURY wa Table Table uoQ MERCURY - EMISIONS LW Table 6-6 lout Sp1|as 6SEWAGE SLUDGE INCINERATION of *ADULIZ6H kg day - / v8 Stack Hg name SY - 12,14 ,Aep/67,405 7,405 L've^'l Gel 12,15 38ay 5,176 , MOLD 5,176 IeS fisp 13,670 Ove Ode uw Plt B{y6 13,670 Le UO a C*LES2 ~ Water12,16 , 7,264 1971 0 82 LJRASULIAep/b 1,986 abpnyts wud 12,17 abemas * Nov. Ap 1973 butanp 8,535 23 ye $2 20Ur G75 ye Bergen 19741974 buLanp Sa] LOv|' O21'S LReseuldts 28-Gl 3.8 1.195 2537.0 62 34.0 124.1 LGPL LeAP i YoU 3 29 ^'lt 10.82 Sz [NSay - g 8 oo! L's avilable ; IVE" Seg 8 Lt Comm 40 st Le gs el UL E26L pi6l ZL 8Lqey 97eg 3saq Aine L261 Ainr L261 baLyL6L +9390 iZ6l cuer 64 AON 934 . Aguayo Aauqay ep Py ep 3p G1 git 2 "YULd aUeU eouel faoyR, gp yuel|g Saupe zp4aten DRWOIY UPL aye] aye] weld "e) *2unos PeauL RA ey UOJ dpue Smo] XO | MD1S4eg uGz4a] YRNoS pueld ypnos S4aRg JULeY 4AaKOT sbemas [0g ueqngs ula . "CoN usbueg PTN "Dig AaMesS AyUNO) SDLMBL 7S9Myq40N Ayuna)S4DMpL uvozb ryse Are} LURS ARMBIE S OM eM Id 91 ANQAawW SLY} SELS 0} 6-6 MERCURY EMISIONS contiued 6-6 Aewcontinued MERCURY EMISIONS ZOU WOU} . 9wYa}s obtained from Patz 49yZO file obtainedfrom from reports comunications Sumary Sumary Sewage Sewage Sludge Incinerator Informatin EPASumary Mercuy 01 1973 Mercury through performed to promulgation presnt perfomed prior Tests employed traversing impingers traversing traversing wer that 101 yo midget Method 9 JO introduce was this indicate stack was test indicate incinerator incerato into Therefore unlikely incerato Therefore highly SL unlikey ALLY Pesn |4oW 4L would higly 02 sem sHaburdwiAunday, UO ZeYZ higly uoZPesULD Sauopay, AYNISWN SzUOdeu BLeIPUL abpn|sSPeldi uOLudJobpiuLPpoOudLoW |YyZ pawuojzsed LeUsdZULWOU, shemesSEZ6EL OFUL paAo_dwe yo PLMOM Yqy LL (panutqos) JUaSeudauam 4$aq AL PadNnpOujzUL ALayeuN PoULe]GOWOus g BulseAaz\qeoud AuewNs,489090 9-9 Sem Pue SEM SLYY YBLy sem YyHnoay eLqey UO PelF? ueYy ueade PLAUL L | OU eZeP UOL}eWUT SUOL4eIO]> Z6L paem szsaL 4am yey? ay) ADeVSp_nom OUP. SALON e 92 parameters and the mercury removal efficiency of a scrubber The results of all tests suggest that a significant quantity of mercury is collected by water scrubbers Mercury removal efficiencies in Table 6-6 are calculated by the following equation RHg removal = 100 1 - EHg IHg 2 _ where RHg removal = removal efficiency % . EHg = mercury stack emissions grams . = -- ---- mercury input with the sludge grams day The stack test method used in the first five tests in 1971 and 1972 was _ designetdo measure gaseous mercury emissions stack traversing and isokinetic sampling were not performed Emissions measured in these tests are therefore not necessarily representative of the mercury in the stack emissions since particulate mercury may not have been representatively sampled The sixth and seventh tests were performed using Method 101 published in Appendix2 of the mercury standard 38 FR 8820 this method designed to accurately account for both gaseous mercury and mercury particulate matter The average mercury emission factor measured in the first five tests excluding the Barstow plant was 1.65 grams of mercury emitted per metric ton of dry sludge incinerated . and the emission factor measured in the sixth test was also 1.65 . grams of mercury emitted per metric ton of dry sludge Results from the seventh test are not yet available The similar results obtained 93 by both methods indicate that the mercury emitted in a sludge incinerator stack gas that has passed through a wet scrubber is in the vapor form Appendix C describes the method of determining atmospheric dispersion estimates and maximum allowable mercury emission levels Table C describes the source characteristics of a meteorologically restrictive hypothetical sewage sludge incinerator facility and Figure C describes the maximum allowable emissions Pasquill Class D stability applies to mercury emissions from sewage sludge incinerators since most incinerators are located away from the centers of cities at suburban and even more remote locations so that tall buildings that cause air disturbances are expected in the vicinity of such sites The diffusion model assumes a single emission point and a relatively low effective stack height of 20 meters The referenced restrictive assumptions in Appendix C were used in order to be reasonably confident that the calculated maximum emission rate would not exceed the ambient concentration guideline of 1.0 mfor a day average under realistic circumstances Under these conditions therefore the maximum allowable emission of mercury from a sludge incineration or drying site is 3200 gramosf mercury per hour period One of the assumptions used in deriving the maximum allowable mercury emissions from mercury cell alkali plants and mercury extrac tion plants differs from those discussed above An effective stack heigh of 10 meters which implies essentially ground emissions was used 94 because 1 alkali plants discharge some emissions directly from building vents frequently resulting in aerodynamic downwash and 2 many mercury extraction plants are located in mountainous areas where the relatively short stacks used result in impingement on the mountains The decreased stack height results in a lower emission limit of 2300 grams per hour period for these sources The solid line in Figure 6-1 is a curve showing the total daily mercury content of sewage sludge for incineration incinerator input for Pasquill stability assuming no control of mercury emissions which will result in mercury concentration of 1 min the ambient air The curve represented by the solid line is the locus of the equation ) 3200 day allowable mercury emissions . Allowable Mercury Input - 1- mercury removal efficiency 3 Available data indicate that various degrees of mercury emission con- trol are achieved but that the control efficiency of water scrubbers is not predictable and may be low in some cases If the level of control of mercury emissions can be established then a new curve of total mercury content of sewage sludge can be constructed according to equation 3 above as shown by the curve in Figure 6-2 for 50 percent control of mercury emissions Total daily mercury incinerator input for all known incineration sites with present maximum potential burning capacities greater than 149,820 day ca. 330,000 day of dry solids are plotted in Figures 6-1 and 6-2 Other selected daily mercury inputs are also plotted 95 *APIQEIS Apgels4) 40) ONO' Say1$ pue PUL WO) JO DES 14Y]O LUNWIKEL GO Z~ QC Q . iG] UDIsIa UDISsLa Ul Ul *22) SUM Aep/Sy payrajs Sutsapiuod suapisuo UOIyeVAUOS uorjedaquo? YES yoR)Ss a]eI ales PLGT SHISH Uy FH FY Turwing Bujwing Sa}IS SIAJEUP pOG'OGT payoid *agpnys adpays ayer LdBy1a AINSJaW Aundiaw AlNDJ9W VEU] ve JOWAUIL ajqemoyje Bqemoyje yim yim yerwayod jenuajod durwung pue aspnys aBpnis OU Jae013 Ayoedeo aygepiae YAMaGnug WxNeWw! JOnueo nAdsnuosyaw Winwixew jou\uoD *xewW -xew peMyre SpNys Iauyjewssng jenjae 40 ous adeiaeHaLiydMd Says Legend *payiojd saw JO Aep/s yO Aep/s yi yoy YIWUMGUY uy ay] uy Legend Limit |ILI] ONZE UoIsiWa WLI YOST Uolsiwa *] Z jtOaQ peyuayod TYLegend 320 Wo}aIO 03g :puada7 . CF 7 L3UID ILON Aep/a'y'C3NAN@ SAI70Add 00'rSb OOPsSt - Detroit \ 00'T go o0t Aeyqr GANunSaaitas Aud 9A stack aT maximum , concentration AIp Wid analysis conetraion - day 150,000 30, other Selected AMNIYAK te 40 e 1 NOULWHINOD eie eo - gy n0 'Ot suapisuo Suiapsuo UOIJEUAD UOIJZAUGD JOeIAUD! udIsiws aIqeMUOc]I}Seswa s]qemorje0G 20 Ajiqeyspue Aqiqeyspue WOI} IDO'OE JIYJO WNIXEW Q 4 GOZ~ p26] Ul Ul 22) SPM AeP/EYpajoajs H9E1S y>e]S ayes dyes $26] AUISN SIA|BUE . U! By azpnys BY agpnys Fulusng Fususng ayer Sazls J3y}a ANEW AINawW AINSIaw NO'OGT payojd UEU) ae yim yim jenuayod jenuajd Zuswing Pue spnys spNys OU UA 18]BAIZ Ayaed s "payjoid jediayjodAy ynduy yndus "ew "xew jenjoe aspnyS ayes Jo |enje ays Widd Says dujwang osje "alge|sae wnuyxew Jouwod wNuIxew SULWING Amoiaw Amau joquo> yd yo!*ydiW Aep/3 Aep/3 UMOUY uy ayy y jo UMOLY ae jo Jo T "z WI] QOZE uOIsiwe yw OST UOISsIwa ONaq yonag joujag |ELVa}oOd |}(Aep/q| says spuaday oOOJ7 JOYIO Legend I dep/2%'Ganuna somos Ava ana 454,0 0 tsp St 7 14,50 SEWAGE 00'01 sludge incineration incineration assuming 97 SUOI/WS JO (O1JUD stabilty 50 considering stabilty YOIyeauOUlmaximum Spljos JO} concentration from afpn|s conetraion sBemas ca. Jo ca. 30,1 Selcted JO Ainouaw NOLVYANOS |eIOL *z-9 asnBi4 0 0'OT No presently known sludge incineration site has a total daily mercury incinerator input in excess of 3200 grams per day The highest known input is 1000 grams per day at the Detroit Michigan incineration site The Detroit value is based on a sludge incineration rate of 408,600 kg ca. 900,000 lb of dry solids burned per day and on a mercury concentration of 2.5 ppm Hg dry solids basis which is the average of two sludge analyses in December 1973. If mercury concentrations of sludge corresponding to the upper limit of the range of mercury content as shown in Table 6-2 occurred at the maximum burning capacities shown in Table 6-4 the total daily mercury content of the sludge produced would far exceed 3200 grams The largest sludge incineration facility that is contemplated for the near future would incinerate 908,000 kg ca. 2,000,000 lb of dry solids per day if sludge with the highest reasonably expected mercury content of 15 ppm were incinerated and if 50 percent of the mercury in the sludge were emitted into the atmosphere the plant would emit 6,800 grams of mercury per day The production of sewage sludge in excess of 1,362,000 day ca. 3,000,000 day of dry solids is approaching reality in New York City other smaller municipalities could produce amounts well in excess of 681,000 day ca. 1,500,000 day of dry solids Although our investigations were mainly focused on the incineration of municipal sewage sludge it became apparent during 98 the investigation that the incineration of wastewater treatment plant sludges and pretreatment sludges from various industries could present the same problems as the incineration of municipal sludges Information obtained from the City of Chicago indicates that approximately 40 percent of the mercury content of sewage sludge can be emitted during the drying operation For this reason the proposed standard is made applicable to the incineration and drying of all wastewater treatment plant sludges The proposed standard also applies to the incineratiaonnd drying of industrial wastewater sludges The most direct method for demonstrating compliance with the emission standard is performing an approved stack emission test demonstrating that the actual stack emissions are below the maximum allowable emission level of the regulation However the mercury stack emission test Method 101 can cost in excess of 5,000 If the mercury input into the incinerator or dryer is determined and if it is further assumed that all of the mercury that enters into the incinerator or dryer is emitted to the atmosphere an effective method of compliance would be to demonstrate that the mercury input into the process is less than the emission standard An advantage of this method of compliance compliance is that it is relatively inexpensive and would cost less than 200 per compliance test Asplant whose input measured to be less than the standard is in compliance An operator of a plant whose input is in excess of the standard has the option of testing mercury emissions by the 99 stack sampling method In the latter case any collection efficiency achieved by the control system will be reflected in the results For a facility in excess of the standard after stack testing no mercury removal processes for sludge or stack gases are currently available A plant in this situation would have to reduce mercury emissions by 1 reduction of the burning rate 2 determination of sewage system users if any which put high mercury content sludges into the sewage system and the requirement that those users pretreat their sludges to remove mercury and 3 any other acceptable means to achieve reduction of emissions to acceptable levels Most affected facilities will probably choose the less expensive sludge sampling compliance option relatively few if any will find it necessary to sample stack emissions 100 REFERENCES 1. Balakrishman S. Williamson D.E. and Okey R.W. State of the Art Review on Sludge Incineration Practice Federal Water Quality Administration Program 17070 DIV Contract 14-12-499 Cincinnati Ohio April 1970 p 5 Water APHA AWWA WPCF Standard Methods for the Examination of and Wastewater Twelfth Edition Boyd Printing Co. Inc. Albany N.Y. 1965 Krup M. internal memo in the Metropolitan Sanitary District of Greater Chicago MSDGC to D. Zenz April 5 1971. Telephone confirmation October 30 1973 by T. Ward EPA with King Zenz and Krup MSDGC that data in April 5 1971 MSDGC memo are dry solids basis Data Nos 1-6 in Table 6-2 Salotta B.V. Environmental Protection Agency internal memo to T.E. Ward October 11 1973. Data Nos 7-57 in Table 6-2 Acting Agency 58 and Director Annapolis internal memo to Z. 59 in Table 6-2 Field Office Environmental Protection Antoniak August 21 1973. Data Nos 6. Chaney R.L. U.S. Department of Agriculture memo to Environmental Protection Agency Sludge Disposal Work Group Ken Johnson Chairman Attachments B and C February 26 1974. Data Nos 60-74 in Table 6-2 Neulicht R.L. Environmental Protection Agency OAQPS- ESED File No. SSI 1974. Data Nos 75-79 in Table 6-2 Ward T.E. Environmental Protection Agency QAQPS- ESED File No. MISC 1974. Data Nos 80-85 in Table 6-2 Ward T.E. Environmental Protection Agency OAQPS-OAQPS- ESED File No. SSI 1974. Data Nos 86-98 in Table 6-2 10. Hing Cecil Metropolitan Sanitary District of Greater Chicago letter to S.L. Roy EPA October 23 1973 11 Background Information - Proposed National Emission Standards for Hazardous Air Pollutants Asbestos Beryllium Mercury APTD Environmental Protection Agency Research Triangle Park N.C. December 1971 12. McCarthy J.A. Environmental Protection Agency internal memo to J.F. Durham Summary of Sewage Sludge Incinerator New Source Performance Standard Development May 18 1972 101 13 York Research Corp. South Lake Tahoe Public Utility District Sludge Incinerator South Lake Tahoe California EPA Contract No. 70-131 Report No. 7394 Sept. 28 1971 14 York Research Corp. Barstow Reclamation Plant Sludge Incinerator Barstow California EPA Contract No. 70-131 Report No. 7394 Sept. 29 1971 15 York Research Corp. Lower Potomac Sludge Incinerator Fairfax County Va EPA Contract No. 70-131 Report No. 7394 Sept. 1 1971 16. York Research Corp. Monterey Water Pollution Control Plant Sludge Incinerator Monterey California EPA Contract No. 70-131 Report No. 7394 December 8 1971 17. Engineering Inc. Northwest Bergen County Sewer Authority Sludge Incinerator Waldwick N.J. EPA Contract No. 68-02-0225 Task No. 7 May 1972 ADDITIONAL SOURCES OF INFORMATION Background Information on Development of National Emission Standards for Hazardous Air Pollutants Asbestos Beryllium and Mercury Publication No. APTD Environmental Protection Agency Research Triangle Park N.C. March 1973 Control Techniques for Particulate Air Pollutants Publication ~ No. AP Environmental Protection Agency Research Triangle * Park N.C. January 1969 Task Force Report Agency Office of April 1972 on Sludge Disposal Environmental Protection Research and Monitoring Washington D.C. Sewage Sludge Incineration Environmental Protection Agency Task Force for Office of Research and Monitoring Report No. R2-72-040 August 1972 102 / 1 ENVIRONMENTAL IMPACT ASBESTOS | The proposed amendments to the asbestos asbestos standard will have significant beneficial effects by reducing emissions of asbestos and mercury to the outside air they may also have limited adverse effects on land and water resources In the judgment of the Admini- strator however the beneficial effects of the proposed amendments outweigh the following potentially adverse effects that were con- sidered . 1. More asbestos waste will be collecteidn control devices and will have to be disposed of 2. The use of suppression agents to preve,, twind erosion of asbestos waste may cause water pollution 3 Other possibly harmful fibers such as fiberglass and mineral wool are substituted for asbestos in friable insulating materials 4. Alternative disposal methods to the incineration of wastewater treatment plant sludges may cause mercury llution of land and water The proposed amendments will force more efficient cleaning of _, gases now being emitted to the outside air from some asbestos manu- facturing and fabrication plants this action in turn will result in the production of more containing material for disposal 103 However the land disposal of such waste wilble regulated by the proposed standard which will ensure protection against emis- sions to the outside air during all steps of the disposal process Further potential asbestos water pollution problems at disposal sites can be prevented by proper selection design and operation of the sites All landfill sites where asbestos wastes are deposited should be selected so as to prevent horizontal and vertical migration of asbestos fibers to ground or surface waters In cases where geologic conditions may not reasonably ensure this adequate precautions such as the installation of impervious liners for the waste disposal site should be taken to ensure long protection of the environment Further the intrusion of moisture into land disposal sites for asbestos should be minimized To assist in the appropriate future use of asbestos waste disposal sites the loca- tion of such sites should be permanently recorded in the appropriate office of the legal jurisdiction where the site is located The asbestos waste disposal standard will be beneficial in reducing the amount of asbestos wastes that are disposed of since it will stimulate some manufacturers who produce large quantities of poten- tial wastes to reuse more of these wastes in their processes The proposed standard will not increase the total quantity of asbestos waste to be disposed of from demolition and renovation operations but will result in the segregation of the asbestos waste from large quantities of other demolition and renovation debris Because the asbestos waste will then be more concentrated strict control of the disposal operations under the proposed standard will be more economical and manageable 104 The use of suppression agents as optional methods to control wind erosion on all portions of asbestos mill tailings piles and on active sections of other asbestos waste disposal sites should reduce the total amounotf asbestos entering surface waters from such sites Such agents have been used successfully to pre- vent wind erosion of dust from various sources such as dirt roads mine tailings disposal areas farm lands and airports Although these agents could possibly cause land and water pollution problems the history of usage over a period of more than 10 years has not re- vealed any substantial pollution problems These agents are not toxic in the dilute form in which they are applied After the agents have cured for a few hours they will erode away only with term weathering Although asbestos is no longer used in manufacturing friable insulating materials in the United States the proposed standard bans the use of asbestos and therefore allows the use of substitute fibers such as ceramic wool mineral wool and fiberglass In contrast with asbestos there is no evidence that these materials cause adverse health effects in the concentrations found in Occupational or ambient environments MERCURY The proposed mercury standard will limit mercury emissions from wastewater treatment plant sludge incinerators and dryers No known existing incinerator sites are exceeding the standard Should an incineration or drying site exceed the maximum allow- able emission and have to reduce its capacity there are three known major alternatives for disposal of sewage sludge 1 burning at an acceptable separate location or in acceptable separate incineration systems 2 land disposal or 3 ocean disposal Wet oxidation and pyrolysis are other less used alternatives The first alternative includes burning or drying at additional locations burning in conjunction with municipal solid waste or burning in conjunction with fired boilers Land disposal includes soil improvement by addition of liquid and dry sludge landfilling of sludgeansd composting of sludges with solid wastes Few new ocean disposal sites for sludges are anticipated In summary no presently known facilities will be affected The number of potential affected facilities is small and in those facilities only a fraction of sludge production would have to be disposed of by alternative methods The relative significance of the quantity of sludge that may have to be disposed of on land as a result of the proposed standard is anticipated to be insignificant compared to the amounts of sludge that are already being disposed of on land The impact of the standard on air is considered to be positive in every conceivable case Therefore the adverse environmental impact of this standard is considered to be minimal 106 8. ECONOMIC IMPACT ASBESTOS Although the proposed amendments are not based on economic considerations EPA has evaluated the economic impact and judges it to be reasonable Costs for compliance among the various sources covered by the amendments are variable In most cases impact is not based on detailed cost estimates because the economic | such information is not available for example detailed information concerning the number size and characteristics of additional sources covered by the proposed demolition and renovation regulation is not available Although the amendments may adversely affect some marginal plants or companies the impact to the asbestos industries as a whole should not be large A summary of the economic impact is given in Table 8-1 Asbestos Manufacturing Only one known shotgun shell manufacturing plant in the United States uses asbestos This plant already has mechanical . particulate collectors and spray scrubbers which reduce the asbestos emissions however it may be necessary for the plant to install the fabric filtration devices specified by the regulation Such additions would include two min ca. acfm * baghouses at an installed cost of approximately approximately 8400 The annual operating cost would be approximately 2100 which amounts to about 1.5 cents per 100 boxes of shells or about 0.005 percent of the product value The plant is expected to be able to manage this increased cost if additional controls are necessary to comply with the proposed regulation 3 am min = actual cubic cubic ; meters per minute acfm = actual cubic feet per minute 107 ($) 0 ATSNPUT }uaUpuy TableTable SUMMARY SUMMARY OF ECONOMIC ECONOMIC OF PROPOSED 000 000 0 000 Lenuy 00 OS OF Table AMENDMENTS ECONOMIC ASBESTOS STANDARD PROPOSED aSz* 059 OSL pasodag to 7509 | 1 wnWLxey yyim ($) Amendt Manufctring Leqides Manufacturing o0r0s00 2b Manufacturing 0 0 000 Controls Oz p8 QO0* 0 O00 000000 Anual SZ 8b Sy $6 00P B.Fabrication Asbetos Buildng Buildng B. Products Friction Intermediate Intermediate . L 0 0 OZ OL OOL 100 O00| Intermediate C. ii Board Fabrictors Asbestos Board Demolition =! 0 10,0 < 0 420,00 420,00 9 9 Ol 21,0 0 | DemolitnAdWAS $0 Le (4Be/0S) ayewl4ysa t-8 daquiny LjuayodSB0UNnOs L estimate QZ OSE OOL 1000 DyeOWL g 9 90 OSZl OOEE ISS G1 50,0 OCS Disposal ON ON estimate estimate L ews B SAQPRIAGE, LaygqlLeydsy estimatestimate ~ PAeog aIeLpwszuy ~ abseq Operated unbyous olseq y Sque tg sojeqsy SOJsaqgy(1)(LL) sozeqsy 10 = BulLanzoeguy 120-0 *y g 1200-2000 g 500 Sanitary UOLIeGy g 150,0 saysem jo 48,00 48,0 95,0 SLLM 95,00 landfil Lesodsiqty 400,00 400,00 400,00 S^'ilgasl payeuadg150,0 [esodsiqYSLliI)W (Pas0|)Auysnpur150,0 15500,,0000(1510,)0 aysem = Y *g 39 1 2 Ee "fF s 9 The asphalt concrete industry consumes approximately 4500 tons of asbestos per year and the total amount of asbestos concrete produced nationwide is estimated to be 136,200 metric ca. 150,000 tons per year This amount of asbestos concrete represents less than 0.1 percent of the total amount of asphalt concrete produced in the United States and involves approximatel5y0 plants annually of the estimated 5000 asphalt concrete plants in the United States Ever for these plants asbestos concrete represents less than 10 percent of the total amount of asphalt concrete produced EPA estimates that approximately 10 percent 500 of the existing plants can already comply with the proposed regulation no additional expense would be required if such plants chose to manufacture asbestosasphalt concrete The existing asphalt concrete plants that cannot comply with the proposed amendment approximately 4500 plants will have to install additional controls if they desire to manufacture asbestos concrete Such plants will probably install a small control device to treat only the contaminated gas streams rather than a control device for all emission streams from the facility For an average plant the maximum amount of ventilation air flow attributable to the mixer and the ventilation system for asbestos materials handling would be approximately 28 amThe installed capital cost of a baghouse of this size would be 4200 and the annual operating cost would be 1100 The capital cost of the small ba~ house represents approximately 1.5 percent of the total capital invested in an average plant The annual cost amounts to 0.5 percent of the value of the asbestos concrete produced If as many as 10 asbestos concrete plants per year installed 109 such a baghouse the capital investment for the entire industry would be 42,000 and the annual operating cost would be 11,000 The additional control required by the provisions of the proposed amendment will be taken into consideration in the calculated profitability of manufacturing asbestos concrete by each plant operator on a case basis If the venture is profitable the operator will add the appropriate control device and manufacture asbestos concrete If it is not the operator will not use asbestos and will still manufacture asbestos asphalt concrete The Agency estimates that some 80 to 90 percent of the new and modified asphalt concrete plants will install fabric filter collection devices and the remainder will install venturi scrubbers to comply with the Federal new source performance standard for particulates 40 CFR Part 60 New fabric filter collection devices can meet the requirements specified under 40 CFR 61.23 Most of the scrubbers installed on new and modified plants are also expected to be able to comply with the emission requirement of the proposed amendment | The economic impact of the proposed amendment for new and modified . plants is therefore expected to be minimal Asbestos Fabrication The Agency's investigation of the asbestos fabrication industry which included inspections of fabrication sites and air pollution control equipment and consultations with industrial representatives and trade associations was used as a basis for the estimates presented in this section 110 All of th1e2 estimated fabricating facilities for asbestos building products are estimated to be able to meet the proposed amendments with existing control equipment Therefore the proposed amendments are expected to have no impact on these sources An estimated 20 large facilities fabricate asbestos friction products and most of these already comply with the proposed amendments Approximately 100 of an estimated 380 friction product fabricators of intermediate and small size will have to add controls Most of these sources will require control devices no larger than 28 amrin in capacity Ifa baghouse of this size is chosen the installed capital cost would be 420,000 for the entire asbestos friction product fabrication industry and the annual operating cost would be 110,000 Approximately 20 of the estimated 100 asbestos or asbestos board fabrication facilities subject to the proposed amendments will be required to add or upgrade control equipment If one min fabric filtration device is added at each facility the estimated installed capital cost for the industry would be 84,000 and the annual operating cost would be 21,000 AsbestoAsbestos Demolition andRenRovatioen novation The general economic impact of the demolition demolition regulation discussed in the background information document for the promulgated standard is incrementally increased by the proposed amendments to the stancard The only proposedamendments that are expected to have a significant economic impact are the renovation provisions 111 and the extension of demolition coverage to apparatus other than pipes boilers and supporting structural members i.e. to tanks reactors turbines furnaces and load- supporting structural members The stripping of friable asbestos materials from tanks reactors turbines furnaces and supporting structural members or the removal of such apparatus from buildings with the asbestos materials intact will increase the number of sources subject to the demolition standard by an estimated 10 percent Although the demolition standard was estimated to increase demolition costs by 45 million annually based on the demolition of 26,000 buildings per year 1 experience in enforcing the standard since promulgation indicates that the actual number of demolition operations and the additional cost imposed by the demolition standard is much less than previously predicted Based on the number of demolition operations reported to one Agency Regional Office in the period since promulgation and adjusting this value to reflect additional demolition operations covered by the promulgated standard that were unreported it is estimated that the number of demolition operations performed in the United States and covered by the standard is less than 3000 per year The estimated cost of complying with the demolition provisions is therefore only 5.2 million per year instead of the 45 million that was previously estimated The impact of the additional coverage of the proposed amendments 112 to the demolition standard is estimated to be 10 percent of the total impact of the demolition standard or an annual operating cost of 520,000 The number of renovation operations subject to the proposed amendment is large but will probably be less than the number of building demolitions The additional cost required to comply with the proposed regulation will be the cost of stripping friable asbestos asbestos materials from pipes and other specified apparatus The amendment will apply only to relatively large residential and residential building renovation operations for example where heating systems are removed since only operations involving the removal of more than 80 meters of pipe or more than 15 square meters of boiler tank reactor turbine furnace or structural member insulation are covered The rebuilding of industrial plants will in most cases involve the removal of pipes and apparatus in sufficient quantities to be subject to the proposed amendment The replacement of apparatus in residential buildings and chemical plants will also be covered by the proposed amendment in certain cases For a relatively scale renovation involving removal of pipes and apparatus the total renovation cost will be about 50,000 The additional cost required to comply with the proposed amendment for such a renovation operation would be the cost of labor for wetting and stripping the friable asbestos | materials from the pipes and apparatus during this operation The stripping cost for such an operation is estimated to be 250 113 The cost required by the proposed amendment for stripping and wetting should thus be no more than 0.5 percent of the cost of the renovation operation If 1,000 renovations per year are subject to the proposed standard and the average total cost for each renovation is 100,000 the total industry annual operating cost to comply with the proposed standard is estimated to be 500,000 Within a broad range of costs the demand for demolition or renovation services is inelastic because of the lack of feasible alternatives Even if old buildings and structures are abandoned local government agencies will eventually be forced to have them demolished Because the demand for these services is inelastic the increased cost of demolition or renovation will be borne by the consumers of these services rather than by the contractors and any additional renovation or demolition costs will be passed on Disposal of Asbestos Wastes Several asbestos mills will have to adopt control methods for the tailings disposal process to comply with the proposed amendments The installed capital cost of a screw mixer and associated equipment for wetting tailings prior to dumping is estimated to be approximately 25,000 per mill and the annual operating cost is estimated to be 8000 Six asbestos mills are currently operating One mill uses a wet milling process and therefore produces wet tailings and two other mills have already installed screw mixers and wetting systems For the three operating asbestos mills that may have to add screw mixers the total capital investment cost to the industry estimated to be 75,000 and the total annual operating cost is estimated to be 24,000 114 A substantial number of asbestos manufacturing and fabricating operations already comply with the proposed amendments and will therefore therefore incur no additional expenditure It is estimated that 50 percent of these sources may already comply with the asbestos waste disposal standard _ The proposed amendments will increase the trend of recycling wastes at manufacturing operations and thus will not increase the amount of asbestos waste that must be disposed of However some manufacturing and fabrication operations will incur increased costs for wetting packaging and labeling the waste The average additional cost imposed by the proposed amendments is estimated to be approximately 2000 annually annually per source This estimate does not include additional costs for collection transportation or deposition deposition on a disposal site since these operations | are currently being performed For a few large manufacturing sources , the additional annual cost may be significantly higher than 2000 but for many other sources the additional waste disposal cost would be less Approximately 500 fabrication sources and 750 manufacturing sources will be subject to the proposed amendments and 50 percent 625 are estimated to already be in compliance The total additional cost imposed on this indus- try by the proposed amendments is estimated to be 1.25 million per year The amount of friable asbestos matetrhait amul st be disposed of to comply with the proposed amendments will be relatively small for most demolition and renovation operations While pipes and other specified items covered with friable asbestos material may be disposed of intact the salvage value of the metal will probably provide sufficient incentive to strip the insulation from such items The additional cost incurred in disposing of the stripped 115 115 115 friable asbestos wastes is expected to be no more than 500 per demolition or renovation source even for large renovation and demolition operations This figure includethse cost of consolidating the stripped materials wetting the waste material packaging the material in impermeable containers and labeling the containers The annual cost of complying with the proposed waste disposal standard is estimated to be 1,650,000 Other waste disposal disposal costs such as transportation and deposition in a waste disposal site are incurred even in the absence of the proposed amendments and cannot logically be assessed as an additional cost imposed by the proposed amendments As previously explained any additional cost for disposal of renovation and demolition waste will probably be borne by the owner of the building being demolished or renovated Since it appears that asbestos waste from spraying operations is now being disposed of in accordance with the proposed waste disposal amendments it is expected that there will be no economic impact on this source category Waste Disposal Sites Asbestos wastes generated by sources subject to the proposed amendments are deposited on large asbestos mill tailings piles usually operated by the mill waste disposal sites owned by asbestos companies and private and municipal solid waste disposal sites The proposed amendments require that there be no visible emissions from the disposal sites or optionally that the owners or operators of the site comply with certain specified procedures In addition the proposed amendments require the posting of warning signs and the fencing of specified waste disposal operations 116 An estimated six asbestos mill tailings piles are in current usage and six are completely inactive The Agency's investigation indicated that completely inactive sites will probably be in compliance with the emission provision of the proposed amendments Warning signs and fencing must be installed where not already in place Assuming that the average completely inactive tailings pile covers 200,000 m ca. 50 acres the cost of installing fencing and warning signs is estimated to be 8000 per site or 48,000 for the six existing inactive tailings disposal | sites One and perhaps two of the six asbestos mill tailings piles in current usage will probably be able to comply with the proposed emission provision without additional expenditures The average size of such tailings disposal sites is approximately 200,000 m ca. 50 acres The majority of this area is inactive with the recent working face and vehicle roads on the tailings pile the only active portions The Agency's observations during inspections of tailings piles indicated that many of the inactive portions of dis- posal piles are unlikely to discharge visible emissions and therefore expenditures for suppression agents or other control measures would not be required to comply with the proposed amendments Where controls are needed on the inactive portions of a disposal site a suppression agent will probably be applied The annual expenditure for application to a tailings disposal area would be 15,000 Since most asbestos mills will use the method of wetting tailings with a suppression agent to comply with the proposed a 117 tailings disposal provision the active face of the disposal site will probably meet the emission provision without additional expenditures If suppression agents must be applied to the active portions of a disposal site the annual operating cost is estimated to be approximately 10,000 In cases fencing may already be installed thus not requiring additional expenditures The capital costs for fencing and warning signs are estimated to be approximately 8000 for a 200,000 m disposal site While the actual expenditures to be made by currently used tailings disposal sites as a result of the proposed amendments are not known a worst case would require an annual operating cost of 25,000 for suppression agent application and also a capital cost of 8000 for fencing and warning signs On an industry basis six tailings disposal operations would have to spend 150,000 in annual operating costs for applying suppression agents and 48,000 in capital costs for installing fencing and signs An estimated 10 to 15 asbestos waste disposal sites are operated by asbestos manufacturing and fabrication sources Several of these disposal sites will probably require additional control methods to comply with the emission provisions of the proposed amendments The optional compliance method requires that inactive sections be covered with 60 cm centimeters of containing material or with 15 cm of asbestos- containing material and a vegetative cover The average area of m such sites is estimated to be 12,140 m ca. 3 acres The most costly method of compliance would be to cover the entire inactive section of the disposal site with 60 cm of soil which would cost approximately 118 20,000 The establishment of a vegetative cover including 15 cm of covering soil initial cultivating seeding and fertilization is estimated to cost 7000 for a 12,140 site the annual vegetative maintenance would cost an estimated 1000 per year for a 12,140 ca.3 acres site The optional compliance method for active sections requires that either a suppression agent or a cm cover of asbestos material be applied at the end of each operating day The estimated annual operating cost for applying a suppression agent at the end of each operating day is 4000 The cost required to put on 15 cm of cover at the end of each operating day will probably be . more than the cost of applying a suppression agent but will not require the installation of a fence when used in conjunction with an optional method for inactive sections of a disposal site. The capital cost for fencing where required and warning sign installation is estimated to be 2500 per site For a disposal site to comply with the standard the capital investment cost would be 9500 and operating costs would be 5000 per year The choice of a 60 cover rather than the less costly option of a vegetative cover would require a capital investirent of 22,500 and an annual operating cost of 5000 Only a few of the disposal sites will have to expend such sums of money to _ comply with the proposed standard However capital cost would be 95,000 95,000 and annual operating cost would be 50,000 if as many as 10 disposal sites had to adopt the optional control methods of the proposed standard 119 Many states have recently instituted permit systems for solid waste disposal sites and the operating status of many sites is in a state of change The current and future trend is to the operation of such sites as sanitary landfill operations While the proposed standard for asbestos waste disposal sites could require changes in operating practices at a large number of private and municipally operated waste disposal sites these changes are consistent with the trend to operate as sanitary landfills The total number of private and municipally operated waste disposal sites is not known though various estimates have been made Based on a 1968 estimate that was updated in 1971 by the Agency 1500 landfill sites in the United States use some type of cover and 14,000 disposal sites do not use cover The Agency has recently made another estimate based on a survey of four states with results prorated on the basis of population to the entire United States This estimate indicates that there are 6000 disposal sites that do not meet the criteria of a sanitary landfill site and 2000 sanitary landfill sites If a site that accepts containing waste meets the criteria for a sanitary landfill it will comply with the provisions of the proposed amendments except for the installation of warning signs The capital cost for installing signs around a landfill site coveri 161,880 m ca. 40 acres is estimated to be 500 Disposal sites that are not sanitary landfills but which accept asbestos wastes will probably upgrade a section of the site to meet Federal sanitary landfill guidelines and will have to add warning signs The amount of containing waste deposited at a landfill will be rather small 120 in most cases compared to the amounts of other solid wastes that are landfilled It is estimated that less than 1.8 metric tons of asbestoscontaining waste will be deposited at an average site Based an estimated sanitary landfill operating cost of metric ton the annual operating cost for sanitary landfilling only containing waste would be approximately 2000 It is estimated that 500 sanitary landfills and 300 open disposal sites will dispose of asbestos- containing waste The estimated total additional cost incurred on waste disposal site operations by the proposed standard is estimated to be capital costs of 400,000 for signs and fencing and an annual operating cost of 600,000 The increased cost of disposing of containing waste would probably be passed on to the waste generator and the economic impact of the proposed amendment on the operators of disposal sites would therefore be minimal MERCURY The proposed standard for mercury emissions from sewage sludge incineration and drying plants is based on maintaining the ambient air guideline deemed safe by the Administrator as required by section 112 of the Act and does not require that economics be considered The economic effect will however be minimal for the following reasons 1 no known affected facilities will be required to make sludge handling adjustments 2 even in the few situations which conceivably could require the alternative disposal of sludges only a fraction of the sludge production would be affected and 3 for future plants or expansion of existing plants the emission limit will allow relatively large incineration plants to 121 be operated If the sludge mercury concentration is 5.0 ppm dry solids basis and the collection efficiency is 50 percent these large installations can incinerate or dry up to 1,225,800 kg ca. 2,700,000 pounds of dry solids per day The actual allowable burning rate with respect to mercury will depend ultimately on the actual sludge | mercury concentration and removal efficiencies The cost impact of sludge mercury analysis is considered to be relatively small approximately 200 per compliance test and some treatment plants already routinely perform mercury sludge analysis The cost of a compliance stack test using Method 101 can exceed 5000 and will be significant for small facilities Most facilities however will be able to use the less expensive sludge sampling option to determine compliance 122 REFERENCES 1 Background Information on Development of National Emission Standards for Hazardous Air Pollutants Asbestos Beryllium and Mercury APTD U. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park N. .. March 1973 Decision Guide in Solid Waste Management U. S. Environmental Protection Agency Office of Solid Waste Management Programs no date 123 APPENDIX A. OPTIONAL CLEANING METHODS FOR COMPLIANCE WITH ASBESTOS STANDARD As an alternative to meeting the emission requirement of the proposed amendment to the asbestos standard a source owner or operator may fulfill the following requirement*s a Fabric filter collection devices must be used except as noted in paragraphs b and c of this section Such devices must be operated at a pressure drop of no more than 10 cm ca. 4 inches water gauge as measured across the filter fabric The airflow permeability as determined by ASTM method D737-69 must not exceed 30 min for woven fabrics or 35 min for felted fabrics except that 40 min for woven and 45 min for felted fabrics is allowed for filtering air from asbestos ore dryers Each square meter of felted fabric must weigh at least 475 grams ca. 14 ounces per square yard and be at least 1.6 mm ca. sixteenth inch thick throughout Synthetic fabrics must not contain fill yarn other than that which is spun b If the use of fabric filters creates a fire or explosion hazard the Administrator may authorize the use of wet collectors designed to operate with a unit contacting energy of at least 102 cm ca. 40 inches water gauge pressure c The Administrator may authorize the use of filtering equipment other than that described in paragraphs a and b of These requirements are quoted from 61.23 of the standards promulgated April 6 1973 38 FR 8820 124 this section if the owner or operator demonstrates to the satisfaction of the Administrator that the filtering of particulate asbestos material d is equivalent to that of the described equipment All cleaning equipment authorized by this section must be properly installed used operated and maintained Bypass devices may be used only during upset or emergency conditions and then only for so long as it takes to shut down the operation generating particulate asbestos material APPENDIX B. CHEMICAL STABILIZATION OF WASTE DISPOSAL SITES More than 1 billion tons of processing waste are produced annually in the United States Approximately 40 percent of this is sized material and stabilization measures must be taken to prevent air and water pollution problems from arising.1 arisng.1 The initial step is the planning of waste disposal operations to ensure that the wastes not haphazardly deposited in piles with dangerously steep banks which could increase runoff or windblown emission problems Although establishing a vegetation cover might be the preferred stabilization method for aesthetic considerations it is often not practical because of the high cost As a recourse a vegetative or chemical method of stabilization must be considered Chemical stabilization of waste piles involves the reaction of a reagent with the waste to form a crust or layer resistant to air and water erosion There is a wide variety of suppression agents with different hase materials The majority of the reagents have a bituminous resinous adhesive or elastomeric polymer base Although chemical stabilizers are not as durable as vegetation they are more versatile For example chemicals can be used in very dry regions where there is not enough moisture to support appropriate vegetative growth The application method is usually determined by the size and topography of the pile The most common application methods are spraying the waste pile with either a 126 tank truck an airplane It may be possible to employ different spraying techniques at smaller waste disposal sites For instance hand sprayers or trucks equipped with a pressure hose can | be used to apply the chemical agent Chemical stabilizers or suppression agents have been used successfully to control windblown emissions in a wide variety of applications At a uranium tailings pile in Arizona vegetative procedures were investigated and determined to be unsuitable because of the extremely low annual precipitation.1 preciptaion.1 The use of a soil or rock covering was considered to be too expensive In May 1968 U.S. Bureau of Mines personnel applied suppression agents to two portions of the uranium tailings pile The chemicals were applied with a propelled lightweight sprinkling device because only a few acres were stabilized The sprinkling device is mounted on two wheels and as the spraying arm rotates to distribute the chemicals the device moves along a predetermined route The treated sections of the disposal pile were inspected each year and in 1972 the inspection indicated that approximately 40 percent of the dike area that had been stabilized with an elastomeric polymer showed disruption of the surface layer The primary reason for the disruption was determined to be physical disturbance rather than weathering of the stabilizing agent Although this test may reflect an extended durability of the agent due to the lack of appreciable rainfall it does indicate that chemical stabilizers are effective in reducing windblown emissions from tailings piles The second stabilizing agent used was 127 calcium lignosulfonate which was applied to the pond area The 1972 inspection showed that the crust was still intact and unbroken Another example of chemical stabilization is the control of emissions froma copper mill tailings pond An emulsion of petroleum and water was sprayed on the pond at a rate of 2.7 liters per square meter ca. 0.6 gallon per square yard This treatment demonstrated effective dust control in winds up to 27 mps ca. 60 mph The installed cost at this particular facility was approximately 0.044 per square meter ca. 178 per acre Other techniques that were tested and proved unsatisfactory for this application were water sprays snow fences and plowing of the site Chemical stabilizers have reportedly been used successfully to control dust emissions in many other situations Amusement parks airfields construction areas playgrounds roads and schools are just a few of the other applications Effective application rates have been determined for many of the promising agent,s and U.S. Bureau of Mines personnel have been involved in most of these tests By performing rate screening tests various application rates can be studied Chemical stabilizers are applied to samples at different application rates Each sample can then be tested under controlled wind velocities and the amount of wind erosion loss can be measured Durability of the chemical stabilizer can be tested by exposing samples to 128 various weather factors and measuring the amount of sample lost by wind erosion The percent of sample lost can be used to indicate the effectiveness and life expectancy of the chemical stabilizer The installed cost of suppression agents varies from approximately 0.016 per square meter to 0.235 per square meter ca. 65 per acre to 950 per acre The effectiveness of suppressing agents is governed by a number of factors for example the homogeneity permeability reactivity pH and salt content of the surface These parameters frequently exhibit a wide range of variation over the surface of a waste disposal pile Each type of waste should be tested by the manufacturer of the suppressing agent so that ' these factors are considered in determining the application rates Some waste disposal piles may have steep slopes and special techniques such as high pressure spraying or airplane and helicopter applicatimoany have to be employed Chemical stabilization can remain effective for a period of several years provided 1 the site is properly prepared by considering the previously mentioned factors 2 prior compacting or grading is performed where necessary and 3 annual maintenance is ys performed Two manufacturers of suppression agents were contacted by the Agency 4,5 to obtain information on whether the agents would cause water pollution problems Although no tests have been performed on runoff water from chemically stabilized waste piles 129 the toxicity of several chemical stabilizers has been determined The products of the two manufacturers contacted had been shown to have a very low level of toxicity Both manufacturers stated that after the agent has cured in place the agent's adhesive bond to the soil particles is very strong as evidenced by the durability and long life of the products Ample time should be allowed for a chemical stabilizer to cure before rainfall to avoid dissolving the agent in water runoff No concrete evidence is available to show that suppression agents do not create a water pollution problem but the lack of reported complaints and problems concerning the reagents over a period of approximately 10 years of use indicates that they do not cause significant land or water pollution problems If the agent should get into a river or stream the low erosion rate of the material indicates that it would be so dilute that it would be very unlikely to cause problems Additional sources of published information on chemical stabilization are listed at the conclusion to this Appendix 130 REFERENCES 1. Dean Karl Clyde et al Methods and Costs for Stabilizing Sized Mineral Wastes U.S. Bureau of Mines Washington D.C. 1974 a .. Dean Karl C. and Richard Havens Stabilizing Mineral Wastes U.S. Bureau of Mines Washington D.C. 1971 3 Armburst D.V. and J.S. Dickerson Temporary Wind Erosion Control Cost and Effectiveness of 34 Commercial Materials J. Soil and Water Cons 26 154-156 1971 4. Canessa William Manager Products Engineering Witco Chemical Corporation letters to Archie Lee EPA July 1 and September 6 1974 i" 5 Parks C.F. Dowell Division of the Dow Chemical Company letter to Archie Lee EPA September 13 1974 enclosing An Evaluation of Stabilization of Active Tailing Ponds with Swellable Polymers prepared for the Environmental Quality Conference for the Extractive Industries of the American Institute of Mining Metallurgical and Petroleum Engineers Inc. Washington D.C. June 7-9 1971 ADDITIONAL SOURCES OF INFORMATION Dean Karl C. Richard Havens and Kimball T. Harper Chemical and Vegetative Stabilization of a Nevada Copper Porphyry Mill Tailing Bureau of Mines RI 7261 Washington D.C. May 1969 Havens Richarandd Karl C. Dean Chemical Stabilization of the Uranium Tailings at Tuba City Arizona Bureau of Mines RI 7288 Washington D.C. August 1969 Jaines A.L. Stabilizing Mine Dumps with Vegetation Endeavor London 96 154-157 1966 , Chepil W.S. et al Vegetative and Nonvegetative Materials To Control Wind and Water Erosion Soil Soc Am Proc 27 86-89 1963 Lyles Leon et al Spray Adhesives for Temporary Wind Erosion Control J. Soil and Water Cons 25 190-193 1969 Investigation of Fugitive Dust Volume I Sources Emissions and Control Publication No. 3-74-036 Environmental Protection Agency Office of Air and Waste Management Research Triangle Park N. Carolina June 1974 131 APPENDIX C. ESTIMATION OF ALLOWABLE MERCURY EMISSIONS FROM SEWAGE SLUDGE INCINERATION FACILITIES A hypothetical sewage sludge incineration facility was modeled to estimate maximum allowable day average mercury emissions The basic restriction on emissions is that the ambient day ground concentration of mercury 1.0 mmust not be ex- ceeded The source characteristics assumed for this analysis are presented in Table - Table C SOURCE CHARACTERISTICS OF A HYPOTHETICAL SEWAGE SLUDGE INCINERATION FACILITY Building Height Height of Mounted Stack Above Ground Level Stack Gas Exit Speed Stack Gas Flow Rate Stack Gas Temperature 20m ca. 65 ft 23m ca. 75 ft fc 305 min ca. 1000 min 57 min ca. 2000 acfm 32 90 Sewage sludge incineration facilities are usually located adjacent to a river and some are located in pronounced valleys Thus the dispersion modeling techniques and relatively restrictive meteorological assumption of a day average wind speed of 2 mps and maximum wind direction frequency of 40 percent used in EPA document APTD are applicable to the present analysis am= actual cubic meters per minute 132 The only difference between the present analysis and that . in APTD is in the assumed day average effective stack height plune height In APTD an effective stack height of 10 meters equal to the height of the facilities modeled in that document was assumed In the present analysis however a 20- meter average effective stack height is assumed because of the | greater building height and physical stack height at sewage sludge incineration facilities see Table 1 That assumption is based on the fact that over a day period the net effect of modest plume rise during light winds and aerodynamic downwash of the ef- fluent during stronger winds will be an effective stack height ap- proximately equal to the building height _ Using the methodology and assumptions in 0753 with the exception of effective stack height Figure C was developed Note that curves are presented for two atmospheric Pasquill stability classes In general as noted in APTD stability C curves ap- ply when large buildings or other major obstructions to the wind , cause significant mechanical atmospheric turbulence occ asuocrcus rs A in major urban areas In small communities and rural areas the curves for D stability may be more representative There is an important caveat concerning Figure C Close to the source the indicated allowable emissions curve sharply upward However the methodology used in developing those curves does not consider one particular aspect of the downwash phenomenon viz downwash of the plume to ground level immediately to the lee 133 day day day Kg Kg 0 : EMIS IONS '] EMISSIONS EMISSIONS EMISSIONS EMISSIONS EMISSIONS MERCURY MERCURY 4 MERCURY MERCURY MERCURY MERCURY AL OWABLE 3 ALLOWABLE ALLOWABLE ALLOWABLE ALLOWABLE ALLOWABLE ALLOWABLE ALLOWABLE es 0 100 200 300 400 500 600 700 DISTANCE FROM SOURCE meters Figure C Calculated maximum allowable mercury emissions from a sewage sludge incinerator under applicable Pasquill stability classes C and D and wind speed of 2 mps \ 134 of the building Thus emissions will be limited closteo the source even though that is not indicated in Figure - Since the causative factors involved in such a phenomenon climatoloclgimatoylogy and source characteristics vary so widely from one source to an- other it is impossible to generalize as to how the facilities in . the present analysis would be affected Designers of sewage sludge incinerators should carefully 2,3,4,5 observe good engineering practices to ensure that the effluent is emitted in such a manner that the frequency with which it is entrapped in eddies and wakes of the structure itself is ~ minimized 135 REFERENCES 1. Background Information National Emission Standards for Hazardous Air Pollutants Asbestos Beryllium Mercury Publication No. 0753 Environmental Protection Agency Office of Air Programs Research Triangle Park North Carolina December 1971 Turner D.B. Workbook of Atmospheric Dispersion Estimates Publication No. 26 Environmental Protection Agency Office of Air Programs Research Triangle Park North Carolina . Revised 1970 Briggs G.A. Plume Rise AEC Critical Review Series U.S. Atomic Energy Commission Division of Technical Information Oak Ridge Tennessee 1969 Smith M.E. Recommended Guide for the Prediction of the Dispersion of Airborne Effluents American Society of Mechanical Engineers United Engineering Center New York New York 1968 Slade D.H. Meteorology and Atomic Energy U.S. Atomic Energy Commission Division of Technical Information Oak Ridge Tennessee 1968 136 APPENDIX D. SOURCES CONSULTED DURING STANDARDS DEVELOPMENT .. Plants Visited A. Asbestos 1 Manufacturers a Manville Products Corp. N. Billerica Mass 8/1/73 Asbestos board b Remington Arms Co. Bridgeport Conn 8/2/73 Shotgun shell C. Nicolet Industries Ambler Pa 8/29/73 Textiles asbestos board d CertainTeed Industries Ambler Pa 8/29/73 Asbestos pipe e Nicolet Industries Norristown Pa 8/30/73 Asbestos paper f Certain Industries Riverside Ca. 9/19/73 Asbestos pipe g Manville Plant Manville N. J. 10/29/73 Various asbestos products h Washington Asphalt Co. Seattle Wash 9/73 Asphalt concrete i During the course of previously developing new source performance standards for asphalt concrete plants 64 asphalt concrete plants were visited 2. Fabricators and Distributors a Bird & Son Roofing Norwood Mass 8/1/73 Fabricator of asbestos paper felt b P. S. Thorsen Co. Boston Mass 8/3/73 Distributor of asbestos board C. Johnson Construction Specialties Houston Texas 8/16/73 Distributor of asbestos cement products .d Kaiser Aluminum Chalmette La 8/17/73 Fabricator of asbestos board into molten metal flow costal device 137 e Thomas L. Green & Co. Indianapolis Ind 8/28/73 Fabricator of asbestos board for ovens f Hopeman Brothers Waynesboro Va 8/28/73 Distributor of asbestos board for marine industry g Long Beach Naval Shipyard Long Beach Ca. 9/17/73 Asbestos insulation products h E. J. Bartells Renton Wash, 9/24/73 Distributor of asbestos products 1 Pacific Car and Foundry Renton Wash 9/73 Fabricator of asbestos textiles j Sun Shipbuilding and Dry Dock Chester Pa 10/26/73 Fabricator of asbestos board k Bendix Auto and Electronic Division Newport News Va 11/7/73 Fabricator of asbestos friction products 1. Wilson & Emerson Construction Co. Cary N. C. 12/7/73 User of asbestos pipe m Sears Mart and Rigsbee Tire Sales Durham N. C. 12/7/73 12/7/73 Brake shoe installers Demolition Sites a Chicago Ill 225 E. 35th St. 3/26/74 b Chicago Ill 36th & Michigan 3/26/74 c Chicago Ill 43rd & Calumet 3/26/74 d Chicago Ill 63rd & Kenwood 3/26/74 e Chicago Ill 63rd & Harper 3/26/74 f Chicago Ill 63rd & Stony Island 3/26/74 9 Chicago Ill 69th & Stony Island 3/26/74 h Chicago Ill Taylor & Canal St. 3/26/74 i Chicago Ill Morgan St. & Fulton Ave. 3/26/74 j Chicago Ill Orleans St. 3/25/74 Chicago Ill Orleans St. boiler plant 3/26/74 Chicago Ill E. Ernie 3/26/74 Several other buildings located in and around Chicago area 2/13/74' Waste Disposal Sites a Lancing Ill 3/26/73 General landfill Nicolet Industries Ambler Pa 8/30/73 Asbestos waste disposal site Certain Industries Ambler Pa 8/30/73 Asbestos waste disposal site Asbestos Mill Tailings Piles a GAF Corp. Hyde Park Vt 9/10/73 b Pacific Asbestos Co. Copperopolis Ca. 3/26/74 C. Coalinga Asbestos Co. Coalinga Ca. 3/27/74 d Atlas Asbestos Co. Coalinga Ca. 3/27/74 e Calidria Asbestos Co. King City Ca. 3/28/74 B. Mercury 1. Municipal Sewage Treatment Plants. a N. W. Bergen Co. Waldwick N. J. 11/12/73 b Piscataway Piscataway Md 2/27/74 Joint Meeting ElizabetNh. J. 11/13/73 Bergen County Little Ferry N. J. 11/13/73 Greensboro N. C. 12/7/73 PittsburPga h 12/73 Hartford Conn 12/73 New Haven Conn 12/73 139 1 Detroit Mich 12/73 j Chicago Ill 12/73 k Indianapolis Ind 12/73 II Tests Conducted A. Asbestos 1. Ambient Asbestos Samples a GAF Corp. Hyde Park Vt 10/9/73 Asbestos tailings disposal site b Nicolet Industries Ambler Pa 10/16/73 Asbestos waste disposal C. Certain Industries Ambler Pa 10/16/73 Asbestos waste disposal 2 Asbestos Material Samples ] a GAF Corp. Hyde Park Vt 10/9/73 Asbestos tailings disposal site b Nicolet Industries Ambler Pa 10/16/73 Asbestos waste disposal site C. Certain Industries Ambler Pa 10/16/73 ' Asbestos waste disposal site B. Mercury 1. Municipal Sewage Treatment Plants a Stack tests i N. W. Bergen Co. Waldwick N. J. 11/12/73 ii Piscataway Piscataway Md 2/27/74 | b Sludge Samples & Analysis i N. W. Bergen Co. Waldwick N. J. 11/12/73 ii Joint Meeting Elizabeth N. J. 11/13/73 iii Bergen County Little Ferry N. J. 11/13/73 iv Greensboro N. C. 12/7/73 Fa 4 140 v Pittsburgh Pa 12/73 vi Hartford Conn 12/73 vii New Haven Conn 12/73 viii Detroit Mich 12/73 ix Chicago Ill 12/73 x Indianapolis Ind 12/73 III Meetings A. Asbestos Asbestos 1. Department of Environmental Defense Fund 7/9/73 2. | National Association of Demolition Contractors 9/24/73 3. National Association of Demolition Contractors 11/16/73 National Association of Demolition Contractors 2/11/74 5. Environmental Defense Department of Justice 2/25/7 National Association of Demolition Contractors 4/17/74 7. Asbestos Information Association of North America 3/1/7 National Air Pollution Control Techniques Advisory Committee Chicago Ill 5/22/74 9. EPA Working Group on NESHAP 5/29/74 B. Mercury 1 National Air Pollution Control Techniques Advisory Committee Chicago Ill 5/22/74 2 EPA Working Group on NESHAP 5/29/74 Envirotech 6/21/74 147