Document nkm5wknoeGMV4zj7YMa2bzGL8

JliWIftg ff 'TtfllBfHM1 c t. 1. ou Pont de Nemours & Company Wilmington. Delaware 15898 trCAC OCPAATMCNT September 27, 1978 MANUFACTURING ENVIRONMENTAL COMMITTEE ASBESTOS REMOVAL REPORTING AND DISPOSAL Prior to removing asbestos from pipes, containers or structural members, notice and controls are required in certain circumstances. This is a consequence cf asbestos being desig nated a hazardous air pollutant under Section 112 of the Clean. Air Act. 40 CFR 61.20, reprinted in "Environment Reporter" (3KA) at 121:0466. These requirements have been in effect since April 6, C 1973. Because of several recent questions, and since the regu lation is worded so awkwardly, I .feel this letter is warranted. i CC inSlUSS material* -- any material that contains more than one percent asbestos by weight and that can be crumbled, pulverized or reduced to powder, when dry, by hand pressure. RENOVATIONS The most common situation at the plants is called renovation. It involves removing or stripping away asbestos from pipes, ducts, boilers, tank reactors, furnaces or struc tural members. If a load-supporting structural member is actually removed or wrecked, the operation is not a. renovation, but a demolition, covered below. Larce Renovations If you plan to renovate and therefore must remove or strip asbestos from over 80 meters (260 feet) of pipe or over 15 square meters (ISO square feet) of ducts, etc., you must notify the Regional E?A office "as soon as possible" prior to renovation. 861.22(d)(2). This notice must include the name and address of the C owner, description and address of `Ggrfacility, amount of DUP 09nfi?dQ ..T^MMEigff IB--. HJCMUiMHEEii * 2 asbestos present, renovation dates, nature, of renovation, dis posal procedures and disposal site. To determine the quantity of asbestos involved in a renovation, the regulation provides the following: (i) Planned but not individually scheduled renovations. If you plan to or routinely'renovate on a non- scheduled basis, you should make a long-range preciction of the total amount of asbestos that will be removed or stripped. Long range means at least a 3Q-day period, but not over a year. If the totals exceed the 80 meters or 15 square meters, or both, you ahoull send in the r.rtire. I suggest that 20 days notice is adequate for as soon as possible." (ii) Planned scheduled renovations. For planned and scheduled renovations, consider just the amount of assestos you plan to remove or strip. (iii) Emergency renovations. In the event of an emercencv renovation, consider the amount of asbestos'to be removed or stripped as a result of just the emsr notir* *hnniid be as soon as pusdM.6 -- onovotion ---- for an emergency the notice might only occu after the act in some situations. See below for emission controls and disposal of asbestos. Small Renovations If your "aonscheduled," "scheduled* or "emergency" renovation involves less than the 80 meeers and 15 square meters, notice is not necessary. See below for emission controls and disposal of asbestos. DEMOLITIONS A demolition occurs only when asbestos is removed or stripped prior to the wrecking or taking out of a load-supporting structural member (beans or load-supporting walls). Large Demolitions If you plan a demolition that involves over 80 meters (280 feet) of asbestos-coated pipjarr 15 square meters (160 DUP 0906250 square feet) of asbestos on ducts, structural members, etc., you must notify.the Regional ERA office at least 10 days prior to demo lition. This notice must include the name and address of the owner, description and address of the facility, amount of asbestos present, demolition dates, nature of demolition, disposal proce dures and disposal site. See below for emission controls and disposal of asbestos. Small Demolitions If you plan a demolition that involves less than both 80 meters and 15 square meters., you "st notify the Regional EFA office at least 20 days prior to demolition. This notice must in clude the name and address of the owner, address of the facility, demolition dates and amount of asbestos present. See below for emission controls and disposal of asbestos. EMISSION CONTROLS Larce Demolitions cr Renovations The following emission controls apply to demolitions and n*n<"!v*tions over the SO meters or 13' sfT::ar* lisiis. For demolition operations asbestos must be removed from any pipe, duct, botier, tank, reactor, furnace or structual member prior to any taking out or wrecking of the item, unless the item can be removed intact with its asbestos coating. For demolition and renovations asbestos must be adequately wetted during stripping or cutting. During demolitions large units may be removed, intact. rather than wetting. A local exhaust ventilation and collection system may be employed if it is sufficiently efficient to result in no visible emissions. During renovations this system may be used if .the source demonstrates that water would damage equipment. Removed asbestos must be kept wet during handling. Asbestos may not be thrown to the ground and must be transported to the ground in dust-tight chutes or containers if removed or stripped more than 50 feet above ground level. Wetting is not necessary when the temperature is below 0*C (32*F). In this situation, for demolitions, removal of intact units, with asbestos, is reqtC^Tftd to the maximum extent DUP 0906251 Small Demolitions or Renovations The above emission controls do not apply to small demo litions or renovations (under 80 meters and IS square meters). TRANSPORTATIONS During collection, processing, incineration, packaging, transportation or disposition, no visible emissions -are allowed. Specially marked drums are not necessary m mis If an asbestos dust collector is used, a water slurry type of control is permitted. In this latter case, the slurrv must be put in drums marked: DISPOSAL CAUTION CONTAINS ASBESTOS AVOID OPENING OR BREAKING CONTAINER BREATHING OF ASBESTOS IS HAZARDOUS TO TOUR HEALTH Asbestos must be disposed of at a site that is either properly fenced and marked with the above legend or is protected by a natural barrier or which covers waste on a 24-hour'basis by either 15 cm (6 inches) of compacted, nonasbestos material or a petroleum-based dust suppression agent. BJR: slg B. J. REILLY c- DUP 0906252