Document qaxnxmG93nxDbqkmp8YEkzKqK
PLAINTIFF'S EXHIBIT
ASBESTOS INFORMATION ASSOCIATION
NORTH AMERICA
1660 L Street. N.W. / Washington. D.C. 20036 / (202) 223-4885
7 November 1975
Memorandum For: Subject:
Holders of AIA/NA Handbook, "AsbestosFederal Regulations"
Change No. 1 to "Asbestos - Federal Regulations"
EPA published amendments to National Emission Standards for Hazardous Air Pollutants (Asbestos) in the Federal 'Register, Vol. 40, No. 199, on October 14, 1975. Reproductions from the Federal Register were forwarded to members of the Association. Enclosed are page insertions to be incorporated in the AIA/NA handbook, "Asbestos - Federal Regulations."
The following changes should be made:
a. Under EPA. tab (Introduction)
Remove present pages B-l through B-7 and insert enclosed pages B-l through B-8.
b. Under EPA tab (Rules and Regulations)
(1) - Insert enclosed pages 48292 through 48309/ 48310 immediately following page 15398.
(2) - Remove present pages 7529 through 7535 and insert enclosed pages 7528 through 7535.
ASBESTOS REGULATION ENVIRONMENTAL PROTECTION AGENCY
BACKGROUND Section 112 of the Clean Air Act gives authority to the Environ
mental Protection Agency (EPA) Administrator to set emissions standards for hazardous air pollutants. On March 31, 1971, EPA published its first list of hazardous air pollutants (asbestos, beryllium, and mercury). On December 7, 1971, EPA proposed a standard for control of asbestos fiber emissions. After the rulemaking process, the standard was issued on April 6, 1973, as part of the National Emissions Standards for Haz ardous Air Pollutants (NESHAPS). The standard:
1. Prohibits any visible emissions of asbestos from milling, manufacturing, and demolition activities; and
2. Provides for the use of specified air cleaning procedures which may be used in lieu of meeting the no visible emis sions requirement.
Clarification of the terminology in the April 6, 1973 standard was published on May 3, 1974. EPA issued amendments to the standard on October 14, 1975.
Under the authority of the Federal hater Pollution Control Act Amendments of 1972, EPA, on October 30, 1973, proposed regulations on wastewater effluents. The proposal included effluent limitation guidelines for existing point source discharges of wastewater, standards of performance for new sources, and new source pretreatment standards for seven subcategories within the asbestos manufacturing point source category. These guidelines and standards, issued February 26, 1974, establish limits on the amount of total suspended solids (TSS), chemical oxygen demand (COD), and the level of pH in the wastewater that may be discharged to waterways.
On January 9, 1975, effluent limitation guidelines were issued for four additional subcategories in the asbestos manufacturing point source
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category, along with new source performance standards and pretreatment standards for new sources. On February 11, 1975, pretreatment standards for existing sources within the initial seven subcategories (A through G) were issued. Minor editorial corrections to the January 9, 1975 document were published on April 25, 1975.
EPA/ASBESTOS REGULATIONS--AIR: Federal Register, Vol. 38, p 8820, Apr. 6. 1973 Vol. 39, p 15396, toy 3, 1974 Vol. 40, p 48292, .Oct. 14, 1975
National Emissions Standards for Hazardous Air Pollutants were promulgated on April 6, 1973, and amended October 14, 1975. The regulations state:
1. There must be no visible emissions to the outside air from asbestos mills or from buildings in which the following types of products are manufactured: (a) textile materials, (b) cement products, (c) fireproofing and insulating materials, (d) friction products, (e) paper, millboard, and felt, (f) floor tile, (g) paints, coatings, caulks, adhesives, and sealants, (h) plastics and rubber materials, (i) chlorine, (j) shotgun shells, and (k) asphalt concrete;
2. Visible emissions are emissions which contain asbestos and which are visually detectable without the aid of instruments. Asbestos is de fined as actinolite, amosite, anthophyllite, chrysotile, crocidolite and tremolite. Asbestos wastes are defined as wastes containing coumercial asbestos.
3. Specified air cleaning procedures may be used rather than meet the no visible emission requirement. These procedures require the use of fabric filters that meet EPA specifications, unless a fire or explosion hazard exists. In that case, wet collectors may be used. Other collection devices may be used if they are deemed equivalent by EPA. Bypass devices may be used only during emergency conditions
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and then only for as long as it takes to shut down the process generating the asbestos emission; 4. Operators employing air cleaning procedures must report to EPA a description of the emission control equipment used in each pro cess. The report must include, as appropriate, the pressure drop across a fabric filter, airflow permeability, fabric density and minimum thickness; 5. Fabricators of cement building products, most friction products, and cement or silicate board must meet the no visible emission standard; 6. There must be no visible emissions to the outside air from any sprayon application of fireproofing or insulation material containing more than one percent asbestos. Twenty days before such operation may begin, notice of the work must be given to EPA; 7. It is the responsibility of the generator of asbestos wastes result ing from manufacturing, fabrication, demolition, renovation and spray ing operations to ensure that the waste is disposed of in a properly operated disposal site. No visible emissions may result from any dis posal operation. Alternatively, the wastes may be mixed with water and sealed in a labeled, leak-tight container and deposited at a disposal site or they may be formed into nonfriable forms and depos ited at a disposal site, hastes from asbestos mills are subject to the no visible emissions standard. That standard may be satisfied by wetting the wastes during transfer and deposition at the disposal site; 8. Active waste disposal sites that are acceptable for the deposit of asbestos wastes must not have visible emissions and must have warning signs and fences erected around the property. The standard may also be met by covering the wastes daily with nonasbestos cover material or by applying a resinous dust suppression agent. Naming signs and fences are not required if natural barriers deter public access to the site or if the site is covered daily with nonasbestos material; 9. Present owners of inactive disposal sites that once received wastes from sources covered by these regulations must meet the no visible emissions standard and must erect warning signs and fences around the site. Rather than comply with the above requirement, the owner may cover the site with nonasbestos material or, in the case of in active tailings piles, may apply resinous dust suppression agents. Where the covering material is applied or where natural barriers deter public access to the site, fences and warning signs are not required;
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10. Notification of intention to demolish a building containing friable
asbestos must be made to EPA at least 10 days prior to the start of
work. Notification must include dates of the work, location, type,
and method of demolition. Reports on demolition operations in
volving less than 80 meters (of pipe insulation) or 15 square
meters (of other asbestos insulation) need include only the location
and dates of the demolition and must be submitted to EPA 20 days
prior to commencement of work. Renovation work involving more than
80 meters or 15 square meters of asbestos must also be reported to EPA;
11. Planned renovations that involve a series of individually nonscheduled
operations must be reported to EPA if the total amount of asbestos esti
mated to be removed during the work is greater than 80 meters or 15
square meters. The estimate must be made for the maximum period (be
tween 30 days and one year) for which the amount of asbestos to be re
moved can be predicted. When the total amount of asbestos involved is
greater than the cutoff specified, all work may be reported on a single
form;
12. All demolition and renovation work involving more than 80 meters or 15
square meters of friable asbestos must use emissions control procedures
which require the careful removal of items and waste containing asbestos
and the wetting of asbestos wastes. If wetting would result in unavoid
able damage, local exhaust and ventilation systems may be used provided
the emissions from the system meet the- no visible emission standard; and
13. Roadways may not be surfaced with asbestos except in the case of temporary
roadways on asbestos ore deposits.
EPA/ASBESTOS REGULATIONS--WATER:
Federal Register, Vol. 39, p 7526, Feb. 26, 1974 Vol. 40, p 1874, Jan. 9, 1975 Vol. 40, p 6444, Feb. 11, 1975 Vol. 40, p 18172, Apr. 25, 1975
Effluent limitations guidelines for the first seven subcategories (A through
G) of the asbestos manufacturing point source category were promulgated on Feb
ruary 26, 1974. In addition to the guidelines, these regulations include stand
ards of performance for all new point sources within the subcategories as well as
pretreatment standards for new plants which discharge to municipal sewer systems.
On January 9, 1975, regulations were promulgated setting forth the effluent limita
tion guidelines, new' source performance standards, and newr source pretreatment requirements for subcategories H through K. Also, on February 11, 1975, pre
treatment standards for existing sources in subcategories A through G were prom
ulgated. (Pretreatment standards for existing sources in subcategories H through
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K will be forwarded for inclusion in this publication when promulgated.) The Federal Water Pollution Control Act Amendments of 1972 require
that all industrial sources treat their effluent by applying the best prac ticable control technology currently available (BPT) by December 31, 1977. That law also requires the same sources to use the best available control technology economically achievable (BAT) by December 31, 1983. The efflu ent limitation guidelines establish the degree of effluent quality that is necesary to meet the BPT and BAT requirements. Effluent quality is expressed in teims of total suspended solids (TSS) and pH for all subcate gories. Two subcategories also have a chemical oxygen demand (COD) stan dard.
According to the regulations, the effluent limitations, standards of performance for new sources, and pretreatment standards are as follows.
Subcategory A--Asbestos-Cement Pipe
one day maximum
30 day average
BPT requirements
TSS 1.14
0.38 (lb/ton of product)
pH within the range of 6.0 to 9.0
BAT requirement
No discharge of process wastewater to navigable waters
New source performance Same as BPT requirements standard
Pretreatment standards
(new sources)
No discharge of incompatible pollutants
(existing sources) Same as new sources, no limit on discharge of TSS or pH
Subcategory B--Asbestos-Cement Sheet
one day maximum
30 day average
BPT requirements
TSS 1.35
0.45 (lb/ton of product)
pH within the range of 6.0 to 9.0
BAT requirement
No discharge of process wastewater to navigable waters
New source performance Same as BAT requirement standard
Pretreatment standards
(new sources)
No discharge of incompatible pollutants
(existing sources) Same as new sources, no limit on discharge of TSS or pH
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Subcategory C--Asbestos Paper (Starch Binder)
one day maximum
30 day average
BPT requirements
TSS.1.10
0.70 (lb/ton of product)
pH within the range of 6.0 to 9.0
BAT requirement
No discharge of process wastewater to navigable waters
New source performance Same as BAT requirement standard
Pretreatment standards
(new sources)
No discharge of incompatible pollutants
(existing sources) Same as new sources, no limit on discharge of TSS or pH
Subcategory D--Asbestos Paper (Elastomeric Binder)
one day maximum
50 day average
BPT requirements
TSS 1.10
0.70 (lb/ton of product)
pH within the range of 6.0 to 9.0
BAT requirement
No discharge of process wastewater to navigable waters
New source performance Same at BPT requirements standard
Pretreatment standards
(new sources)
No discharge of incompatible pollutants
(existing sources) Same as new sources, no limit on discharge of TSS or pH
Subcategory E--Asbestos Millboard
BPT requirement
No discharge of process wastewater to navigable waters
BAT requirement
Same as BPT requirement
New source performance Same as BPT requirement standard
Pretreatment standards
(new sources)
No discharge of incompatible pollutants
(existing sources) Same as new sources, no limit on discharge of TSS or pH
Subcategory F--Asbestos Roofing
BPT requirements BAT requirement
one day maximum
50 day average
COD 0.029
0.016 (lb/ton of product)
TSS 0.020
0.012 (lb/ton of product)
pH within the range of 6.0 to 9.0
No discharge of process wastewater to navigable waters
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New source performance Same as BAT requirement standard
Pretreatment standards
(new sources)
No discharge of incompatible pollutants
(existing sources) Same as new* sources, no limit as discharge of TSS, COD or
Subcategory G--Asbestos Floor Tile
BPT requirements
BAT requirement New source performance
standard Pretreatment standards
(new sources) (existing sources)
one day maximum
50 day average
COD 0.30
0.18 (lb/ton of product)
TSS 0.13
0.08 (lb/ton of product)
pH within the range of 6.0 to 9.0
No discharge of process wastewater to navigable waters
Same as BAT requirement
No discharge of incompatible pollutants Same as new sources, no limit on discharge of TSS, COD or
Subcategory H--Coating or Finishing of Asbestos Textiles
BPT requirement
BAT requirement
New source performance standard
Pretreatment standard (new sources)
No discharge of process wastewater to navigable waters Same as BPT requirement Same as BPT requirement
No discharge of incompatible pollutants, no limit on discharge of TSS, COD or pH
Subcategory I--Solvent Recovery
one day maximum
50 day average
BPT requirements
COD 0.30
0.15 (lb/1,000 lb of finished asbestos product)
TSS 0.18
0.09 (lb/1,000 lb of finished asbestos product)
pH within the range of 6.0 to 9.0
BAT requirement
Same as BPT requirement
New source performance Same as BPT requirement standard
Pretreatment standard
(new sources)
No discharge of incompatible pollutants, no limitation
on discharge of TSS, COD or pH
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Subcategory J--Vapor Absorption
BPT requirement
BAT requirement
New source performance standard
Pretreatment standard (new sources)
No discharge of wastewater pollutants to navigable waters Same as BPT requirement Same as BPT requirement
No discharge of incompatible pollutants, no limitation on discharge of TSS, COD or pH
Subcategory K--Wet Dust Collection
one day maximum
50 day average
BPT requirement
TSS 5.0
2.50 (lb/million*std cu ft of air scrubbed)
pH within the range of 6.0 to 9.0
BAT requirement
No discharge of wastewater pollutants to navigable waters
New source performance Same as BAT requirement standard
Pretreatment standard
(new sources)
No discharge of incompatible pollutants, no limitation
on discharge of TSS, COD or pH
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