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FILE NAME Brakes BRK DATE 1972 Jan 6 Correct Date is on Last Page DOC BRK199 DOCUMENT DESCRIPTION Report of the Illinois Pollution Control Board ILLINOIS POLLUTION CONTROL January 6 1971 BOARD In the Matter of ASBESTOS REGULATIONS ) ) R71-16 ) OPINION OF THE BOARD ON ADOPTION OF REGULATIONS BY MR LAWTON: to asbestos and spray insula- relating 1971 Hearings Proposed regulaitnioNneswsletter 24 dated June 14 in tion were published held in Granite City on October 6 regulations were October 19 1971 Notice on these Chicago on October 15 and in Waukegan on draft together with the form of regulation 1971 in News- of the proposed final on December 5 proposed for adoption were published invited and a small number have letter 37 Written comments were today in the form as pub- been received We adopt the regulations minor clarifying lan- 37 modified by some is to prevent lished in Newsletter in these regulations Our principal concern resulting from the use guage or limit the emissions into the atmosphere asbestos products and the resulting disasingestion and of asbestos and resulting from inhalation pathological consequences This Opinion will consider the source inhalation of this mineral of asbestos and asbestos bearing of asbestos the uses and their demonstrated and types the cause of asbestos emissions the measurement and monitor- community abatement products the health of the impact upon means available for emission of asbestos fibers and the the substative provisions ing modifications made in and ultimate and control The their original proposal of the regwuillaltiloinksewibseetwe be en discussed adoption of natural to variety The term asbestos is a name given indestructible character mined silicates of a virtually crocidolite amosite occurring minerals are chrysotile and actino- The major asbestos are tremolite Of lesser importance content and anthophylmliinteerals differ in their metallic elementteanlsile strength and harshness lite These of fiber diameter flexibility determine their indus- range and other attributes that retention surface properties affect their respirability uses and which in turn is mined and commercially trial and biologic reactivity Over 90 of what to as serpentine sometimes referred used as asbestos is chrysotile collectively referred to as The remaining minerals are fourth of the world asbestos amphiboles The United States mous se ts ofabowuhtich is imported from Canada production of this substance Ex 3 Air Pollution Aspects of Asbestos Litton Report Ex 19 and Africa of September 1969 1971. Asbestos U. S. Department Academy of Sciences Asbestos National Airborne the United States are located prin- value in North Carolina No deposits of commercial Arizona and California cipally in Vermont Aw 724 437 of asbestos are found in Illinois a commercially viable sources far more comprehensive set fact which might otherwise invoakned a industrial usefulness of the of regulations The uniquoefneistss flexibility tensile strength non- mineral is a consequence to acids alkalies and electricity inflammability and its resistance into the atmosphere from industrial Some asbestos fibers get Institute for Environ- See Aspestos Air Pollution Control sources mental Quality prepared by Colin F. Harwood Ex 20. These range and excavation for construction purposes from rock outcrops farming from rock outcrops occur to the use of talcum powder Emissions such as earthquakes of natural eroding processes as a consequence and rain Farming of soils in areas containing temperature wind emission of these fibers Con- asbestos rock will likewise cause containing rock for housing struction requiring excavation in asbestos of asbestos and road construction constitute a source that talcum laying Recent research indicates emission into the atmosphere does contain fibrous while basically a mineral rock dust powder threat of asbestos bodies material and represents a of the regulations does not seek to Obviously the thrust from these sources Further the absence control asbestos emiisnsiIolnlsinois eliminates this activity as a source of asbestos mining of asbestos in manufacturing and of danger It is the processing and asbestos and fiber containing the use and fabrication of asbestos are principally directed The start products to which the regiunlaatsiboensstos inhalation arise at the health dangers inherent and include the loading and storage of the asbestos processing cycle asbestos to the open- of milled asbestos the transporting of bagged of asbestos fluffing of compacted fibers and the mixing ing area fibers with other materials Ex 20 Harwood Page 7. and varieties of asbestos fibers Principal user of all grades asbestos pipe is the asbestos industryinpdruosdturciianlg and gaseous products and used to convey water sewage cables Other serving as conduits for electrical ianncdludteelerpohoofnieng shingles building asbestos industry products To manufacture board and laboratory bench tops boards marine these products willowed fibers are mixed with ground silica The end products of these and a slurry formed by addition of water asbestos industries require finishing steps twuhrincihngagadirnillgienngeraatned sanding emissions These include sawing of asbestos dust and some each producing large quantities items being worked upon again clinging to the surface of the becoming a potential emission source of asbestos fibers is in the manufacture A second major use vinyl floor tile and asbestos asphalt road paving of com- these of asbestos emissions result from the manufacture pounds Here again lesser degree from the use and ultimate processing products and to a ' 3- 3- 438 and fabrication Asbestos papers represent a great variety of heat and chemical products used for roofing insulation linings automotive exhaust insulation resistant insulation for pipes and of asbestos fibers and the mixing of asbestos processing ingredients constitute an emission source Again the ulti- of asbestos paper a further source mate cutting and processing represents emissions into the atmosphere Asbestos paint and coating fillers utilize asbestos shorts where their relative indestructi- recovered from the milling process increases the density or opaqueness of paint Where asbestos bility is used in the spraying operation the potential for bearing paint emissions is substantial Likewise the wearing and aging of the paint becomes an additional source of emissions Asbestos friction materials and gaskets represent a wide use minerals Emissions result from the fabrication molding of these Asbestos is also used in the pro- and trimming of these products refers to the finished duction of textile products The term roving textile product from which yarns are produced Blended fibers are carded in machines where the operation is essentially open pre- serious emission source due to the combing action of the mseancthiinnge a Both the production of this product and its ultimate use present substantial sources of emission The spraying of asbestos for insulation constitutes one of the uses of the product and undoubtedly one with the greatest * widest to the health of the workers involved but hes danger potential not only cement slurry is pumped to te, to the public at large Prepared asbestos alterna- the nozzle of a gun and sprayed directly isto puthmepedsut rofatchee o gr un and tively a dry mixture of asbestos cement The material comprisin mixed with water during the spraying operation and insulation is formed by combining asbestos cement the asbestos of 30 15 and 55 respectively The rock wool in proportions used is amosite possessing superior thermal mineral most commonly crocidolite or chrystotile fibers properties If color is required associated with asbestos cement used Among the unique properties are insulation are low thermal conductivity and inflammability and high features low cost easy thick- strength together with good acoustic of emissions from this control and application Initial cause ness results from dry mixing of the spestos cement and mineral the storage product wool components Care must also be exercised during of the bag mixture to prevent further emissions and transportation and the dry material At the construction site the bags are open The most signi- emptied into hoppers where further emissions of emissions of course is in occur the spraying operation ficant source dust concentrations can be seen and measured at con- itself High sites utilizing asbestos spraying methods Our regulations struction this activity and impose stringent house- impose an outright ban on fibrous materials keeping requirements on all spraying of asbestos Additional emission of asbestos results from the use of formed asbestos sections or blocks for insulation of pipes and boilers and in the use of materials applied in a wet or slurry state Asbestos cement products including roofing shingles building boards and drain pipes However emissions may have sealed result from surfaces and do not dust easily their cutting or breaking Other asbestos products used in construction and industry are asbestos paper blankets rope and sealing compounds Emissions resulting from the use of these products depend on the type of material being fabricated the amount and character of fabrication required the location and nature of the site and the quantity of material being processed Tightly bonded composites will have less potential for emissions than those loosely bound See R.116 and following testimony of Pundsack Thompson Ex 5 Asbestos as an Urban Air Contaminant Ex 4 Selikoff Asbestos Environment March 1969. Twentyseven industrial concerns in Illinois manufacture products using asbestos Exhibit 20 Harwood p 56. in virtually all building construction Asbestos products are used and utility installation A particularly obnoxious source of asbestos emission with extreme difficulty of control is the demolition of existing struc- tures Asbestos insulation and products present in demolished struc- tures generate substantial emissions into the atmosphere where control is difficult and the impact on persons in the vicinity both workers and residents is extreme For years asbestos has been incorporated in building materials In some forms of insulation and wallboard the amount present is less than 20 of the total but other materials consist principally or entirely loosened of asbestos asbestos are When a open to building is the ambient demolished areas of air and fibers are emitted In general family small amounts of asbestos residential insulation structures contain relatively Demolition of industrial and commercial buildings materials will prove that have been fireproofed with to be an emission source in the containing future requiring control measures Asbestos is emitted into the atmosphere from brake linings and clutches While these are unquestionably substantial sources of as- bestos emissions in the ambient air the character and potential of these sources have not been sufficiently documented to a point where we feel control See Ex they can properly be the subject of regulatory action and at the present time Harwood Ex 20 p 22 through 28 8 Brake Lining Decomposition Products Lynch Journal of the Air Pollution Control Association December 19 1968 Having described the principal sources of asbestos emissions we next consider their pathological implications The Litton Report states Ex 3 p 40 440 o Asbestos is an air pollutant which carries with it the potential for national or worldwide epidemic of lung cancer or mesothelioma of the pleura or peri- toneum Asbestos bodies have been observed in random autopsies of fourth to half of the population of Pittsburgh Miami and San Francisco and will probably be found in the people of every large city the effects of the asbestos being inhaled today may not be reflected in the general health of the population until the 1990's or the next century to The objective of the regulations must be fold first to protect those who by occupational activity or physical contiguity either to the asbestos use or the asbestos user become the potential victims of this pollutant in other words protect those with both occupational and environmental orientation and secondly to provide measures that will protect the ambient air against an asbestos build that will have adverse effect upon the general public beyond those occupationally or environmentally orientated at the source As stated by Thompson Ex 5 Because asbestos is virtually indestructible and so of the asbestos containing products are used in towns many urban dweller is theoretically exposed to the the average inhalation of asbestos fibers on a residential basis After posed reviewing the incidence of death to asbestos dust over a year states among asbestos workers ex- period Selikoff Ex 4 These experiences highlight one portion of the current spectrum of asbestos disease It is now recognized that direct occupational exposure to asbestos results in a hazard much more significant than formerly appreciated In the last several years however additional problems have been recognized which add another dimension the possibility that the utilization of asbestos is associated with a much wider risk perhaps one of the community at large This is less well defined much less well documented but because of its potential importance of considerable concern It is in this context that our regulations must be structured The onset of morbidity and lethal diseases have been attri- in buted to asbestos inhalation and ingestion Asbestosis pleural and mesotheliomas are known to result calcification lung cancer from exposure to asbestos Surveys of people living or working near asbestos mines and factories have revealed that many nonoccupational cases of asbestosis and mesothelioma have occurred either from asbestos the polluted air or from asbestos carried home on the clothing of workers 3-447 o The fate of the asbestos fiber once it is inhaled and de- questionable posited than .5 in the lung is still questionable microns in length have in the past The short fibers less been ignored probably because they are much too narrow to be visible under a light micro- scope The longer fibers are encrusted in an bearing protein form termed asbestos bodies which are more easily visible Among asbestos workers evidence of pulmonary asbestosis also known as asbestotic pneumoconiosis an asbestos induced scar- ring of the lungs is Common This condition results in a diffuse fibrosis in the lower lobes of the lunc Pulmonary asbestosis has been called a moncsymptomatic disease characterized by painful breathing and lung disorder See Nicholson following Ex 21 R.35 and following Litton Ex 3 P. 4 and characterized characterized statement Asbestosis usually develops after long exposure to high concentrations of asbestos dust the risk varying directly with the length of exposure and the dust concentration Following continued exposure to high concentrations of dust asbestosis may develop Fully in 7 to 9 years and may cause death as early as 13 years after the onset of exposure The common exposure period before recogni- tion of asbestosis as observed among asbestos workers is 20 to 40 years with death following about 2 to 10 years later Once established asbestosis progresses ever after the exposure to dust ceases illness or death can occur long after exposure to concen- trations not producing immediate effects The prolonged signs of asbestosis tionships latency period between exposure makes it difficult to establish and the first time rela- In 1946 700 cases of asbestosis were found in Germany among a total of approximately 8,000 125 cases of asbestosis of the employees in the asbestos industry lung in ray examinations of 476 as- bestos workers were found in one company in Finland The occurrence of asbestosis in members of this worker group appears to rise with the duration of the employment A morbidity of 80 percent among English asbestos workers with been reported Selikoff and others over 20 years of employment investigated 1,522 asbestos has has has insulation workers in the New York Jersey metropolitan area Among 392 exposure of these individuals examined more than 20 years from the onset of Ray evidence of asbestosis was found in 339. In half the asbestosis was moderate or extensive In individuals with less tosis was than less 20 years frequent of exposure radiological evidence of asbesand when present less likely to be extensive 3-442 3-442 3-442 The most common complicationcomplication of asbestosis is cancer of the Jung However cancer of of the the lung apparently induced by asbestos may appear unaccompanied by asbestosis oxtenosixveltyensiveloyxtensively oxtensively oxtensively oxtensively oxtensively 19 Nat'l documented documented documented association of lung cancer with exposure to of many investigations in recent documented in the literature See Ex 3 asbestos dust years and Litton a correlation between asbestosis appears definite It is recognized that cancer of the lung produced by asbestos reeds further study The latent period between exposure and evidence of of carcinoma may be even longer than for asbestosis Little is known about the dose relationship Cases of lung cancer have been observed when only a very short exposure or no exposure to asbestos was known Furthermore the low number of asbestos bodies ob- served in fourth to half of the urban population may be sufficient to cause cancer Because the long asbestos bodies re- nain in the lungs a person who has inhaled asbestos may carry the potential for the rest of his life to develop carcinoma of the lung Moreover it has not been determined whether more than one fiber S necessary to induce a malignant tumor It has been suggested that the probability of cancer induction is proportional to the number of asbestos fibers number of susceptible cells the concentration of carcinogens on the fibers and the time from exposure Why asbestos is carcinogenic is not clearly understood + least three hypotheses have been advanced 1 That the fibers act as a physical irritant which after 20 to 30 years of constant irritation induces a tumor 2 That the fibers contain small amounts of carcinogens such as pyrene nickel and chromium which are eluted from the fibers by the serum in the lungs 3 That the fibers accumulate in the lung and are immobilized as asbestos bodies which disintegrate after 20 to 40 years The resulting free particles cause asbestosis or carcinoma of the lung Primary tumors of the pleura and peritoneum are SO rare that for years they 1960 the first were considered large series of to be cases pathologic curiosities In of diffuse mesothelioma were reported in South Africa In trying to explain this mysterious epidemic asbestos bodies were found in the lungs of some of these patients An association with exposure to the Cape of Good Hone asbestos fields or the industrial use of asbestos was estab- lished in 32 of 33 patients with histologically proved pleural reso- thelioma The majority of these patients had not actually worked with asbestos but had lived in the vicinity of the mines and mills and some had left these areas of exposure as young children The average period between 20 to 40 years Later exposure and development of the tumor was studies verified this interrelationship between asbestos exposure and mesothelioma See Litton Report Ex 19 p 12 Nicholson Ex 21 Selikoff Ex 4 In an attempt to determine whether mesothelioma of the serosal surfaces was related in any way to asbestos exposure exposure in the United States Selikoff studied 307 consecutive deaths among asbestos in- sulation workers in the Northeastern United States They found 10 deaths caused by four pleural and six In addition these workers had a high peritoneal death rate mesotheliomas mesotheliomas attributed to cancer cancer of the stomach colon and rectum Of the 307 deaths 40.4 percent were attributed to cancer 5.5 percent to asbestosis and 54.1 percent other causes In second study viewed 26 consecutive autopsies of patients the investigators rewith asbestosis and found four mesotheliomas of the pleura and three of the peritoneum Mesothelioma is now considered a frequent cause of death among asbestos workers No attempt has been made to summarize the reports of mesothelioma since they appear almost weekly in the current liter- ature So far however there appear to be few cases among the gener- al population Selikoff reviewed 31,652 deaths among population of over 1,048,183 in the United States and three cases of mesothelioma Moreover he points out the general found only that asbes- tos is not the only cause of mesothelioma it has also been produced ed by silica and polyurethane While the exact cause of lung cancer or pleural periotoneal mesothelioma induced by asbestos is not known air pollution by other pollutants may accelerate the morbidity One form of air pollution which is easily koff recently studied the studied in individuals is mortality of 370 asbestos smoking Seli- insulation work- ers In this group 24 men died of lung cancer and all had a history of smoking See Weiss Ex 15 Cigarette Smoking Asbestos and Pulmonary Fibrosis American Review of Respiratory Disease Vol 104 1971. This rate was eight times greater than the expected mortality rate with age and smoking habits taken into account half The recent finding of asbestos bodies in fourth to oneof the urban population has added new impetus to the examination of asbestos as a general air pollutant An asbestos body has been defined as an elongated golden shaft or reddish structure usually with which often shows a segmented or beaded clubbed ends The appearance is usually straight but sometimes curvilinear with a tendency toward symmetry Usually it is from 3 to 5 microns in diameter and 20 to 100 microns in length The coating contains iron demonstrable by oa Perle's stain Prussian blue reaction and probably composed of or ferritin material It may cover the structure completely masking the centralcentral fiber from direct incomplete in the central portion of the shaft or view or may be in the interstices body revealing an expanse of naked fiber There is no doubt that the asbestos bodies formed in the asbestos lungs of the asbestos workers contain asbestos and it is probable that some are contained in those found in the lungs of the general poppopuullatiaontion Evidence that persons other than those working directly with asbestos minerals are being exposed to asbestos is of several types Asbestos fibers can not occupationally exposed be demonstrated in the lungs of persons In few geographic areas pathologic changes regarded regarded as representing pleural calcification exposure of occupational have . a reaction to asbestos such as been found in populations with no history Asbestos fibers have been demonstrated in ambient air Structures that appear to material were described in lung be fibers tissue as coated with a pigmented early as 1907 These exhibit structures were actually fibers those who work with asbestos coated with them a hemosiderin Because few months after starting work it was recognized not of asbestosis The that term they were asbestos evidence of exposure but body came to be the preferred designation As long as the coated fibers were found have been occupationally exposed to asbestos central fiber was seldom questioned although similar objects were found in persons with no asbestos in persons known to the identity of the from time to time known exposure to Identification of the core fibers nas proved to be a formidable technical technical task Without fiber analysis analysis all that can be soid soidsoid is that coated fibers resembling those in asbestos workers are presentpresentpresent present present in most persons in our urban centers Stripping the coating and and process and analyzing the cores by various techniques can sometimes demon- strate strate strate that the cores are asbestos but the is tedious and often often iinconnclusicve onclusive A A more term is ferrugineous body appropriate Attention Attention is now being directed toward study not of the ferruginous Atention At ention bodiebsodies alone but of the total fiber content of the lungs whether Atenio such fibers are coated or uncoated is strong that most human lungs harbor thousands or occupationally millions of of fibers Some of these are chrysotile asbestos and other millions millions of asbeasbestos stos minerals are probably there In most persons not types occupationally exposed to asbestos the numbers of fibers are rela- tively small compared with the numbers found in the occupationally exposed The systematic application of quantitative techniques 3-445 3-445 3-445 )) 1 end (( measuring both coated and uncoated fibers is needed to define a of accumulated fibers for correlation with incidence of gradient on disease on the one hand and history of environmental exposure the other Although there appears no doubt that asbestos fibers are va sent in many human lungs there are sources of airborne fibers other than asbestos Some are probably derived from the burning of leaves and plant products such as paper wood and coal Nar- made mostly vitreous fibers have also been identified in the sediment isolated from human lungs Talc often used as a dusting powder may contain a significant amount generously of tremolite asbestos fibers Information is sparse concerning possible increase of fibers in lungs tence of Selikoff with increasing use of asbestos and concerning the exis- significant differences between urban and rural populations populations and Hammond compared lung tissuetisssues obtained in 1934 and and found no significant increase in the promotion containing ferruginous bodies This suggested that despite increasing use of asbestos in New York City between 1934 and 11967. 91967. 67. fibers of a type producing ing rate over each ferruginous bodies had not been increasing at a correspond- Other commentators however have noted an increase decade in asbestos bodies in samples from per- sons who died in London in 1936 1946 1936 and A review of the literature related to bural calcification and asbestos exposure strongly suggests an assion assion assion betiv pleural calcification and nonoccupational exposures to asbestos See Nat'l Acad Ex 19 p 14 Industrial experience has shown that prolonged asbestos can increase the risk of neoplastic neoplastic disease Examination of lung tissue has much larger proportion of the general public public asbestos fibers then had formerly been realized in dwellers have some such fibers in their lungs The fact basic and ost retained arbon issue is whether the general public as well as persons working near co- tional sources living in the households of asbestos workers living random in the neighborhoods of asbestos plants or exposures have a detectably increased risk having occasion of malignancy or other disease because of airborne asbestos What information there is to answer these questions comes either from direct epidemio- logic studies of groups with various levels of nonoccupational exposure or by extrapolation from the experience of industrial populations with direct or indirect asbestos exposures 3-446 use Two general indices of asbestos exposure are available for in direct epidemiologic studies of groups not known to be occupationally exposed to asbestos The first is based on knowledge of each member's place of work and place of residence Because of the long latent must cover each periods of asbestos disease person's whole lifetime The second this is a knowledge quantita- tive estimate of each member's lung content of asbestos fibers There are few such direct epidemiologic studies and they are inade- quate to answer the questions at issue Of 42 persons with mesotheliomas reported in Pennsylvania 10 had worked in asbestos plants 8 lived or worked close to an asbes- tos industry and 3 were members of families workers in 11 no history of exposure could that included asbestos be obtained and the re- maining 10 had questionable random exposures mesotheliomas known to pathologists in Canada On 165 between fatal malignant 1959 and 1968 an association was confirmed with occupational exposure to asbestos but suggests that the excess was in the manufacture and industrial application It is apparent that no of asbestos quantitative rather than conclusions in mining and were possible milling from these studies which present serious methodologic problems to the epidemiologist residence in the They suggest a risk in immediate neighborhood household contacts and in of asbestos plants There appear tional to be different levels exposures and some of of risk in different types of occupa- these may be reflected in corresponding household and neighborhood experience Another source of evidence of the relative risks associated with inhaling moderate or small numbers of asbestos fibers is the exper- wt lence of persons who have had occupational exposures below those known to be definitely hazardous The maximal airborne fiber con- centrations recommended for prevention of asbestosis are much higher than any likely to be encountered in nonoccupational situations Occupation asbestosis can be effectively controlled with airborne fiber concentrations much higher than are likely to be encoun- tered in occupational situations It is important to determine whether workers whose exposures have been reduced to levels that prevent or greatly delay sures are indirect have asbestosis as well as others whose expoa lower risk of lung cancer than those with higher and more direct exposures Most series of case reports of mesothelioma include some persons who have worked in the construction or shipbuilding industries but in trades not involving direct contact with asbestos Such persons as plumbers electricians and metal ginous bodies in their lungs than do of occupational groups in California workers often have more ferru- collar workers A study revealed an excess of deaths from lung cancer cancer deaths in in insulation but other construction trades found There no excess lung- may be a definable gradient of effect within the construction trades More thorough studies of groups with indirect exposures are certainly needed 3 - 447 The mortality experience of those who are directly and indirect- ly exposed to asbestos in their employment is not directly applicable to the general public who have had moderate or slight exposures from ambient air The evidence suggests a gradient of effect from direct occupational to indirect occupational to family and neighborhood situations in probably high by comparison that there may be levels of all of which dust concentrations are with most community air This suggests asbestos exposure that will not be asso- ciated with any detectable risk What those levels are is not known However if we eliminate the known occupational household and neighborhood exposures we drastically decrease the potential for this risk For this reason our regulations must be directed to emission sources and limitations imposed at the origin as distin- from an effort to establish air quality standards as we have guished of demonstrated adverse done with regard to other air pollutants health effects Having considered the health impact inherent in asbestos emissions we now examine the available measurement and abatement procedures Sampling of asbestos fiber seeks to obtain a representative of the total air mass in sufficient quantity to make quantita- sample tive assessments statistically significant Methods employed in asbestos sampling and the possible sources of error are discussed at length in Ex 20 Harwood p 42 and following Of the several techniques available for emission sampling the membrane filter recommended by the U. S. Public Health Service has become the standard technique for environmental asbestos emission . sampling Air is drawn through a cellulose membrane filter where the particles are entrained Although the effective pore size of the filter 0.45 microns to 0.8 microns is larger than the diameter of of the asbestos fibers the surface charge properties of the many filter and the asbestos fibers plus the circuitous path through the filter result in collection of virtually all of the particles and fibers to which the filter is exposed The collected fibers must be analyzed This may be accomplished by using a microscopic photographic or electronic technique the fibers resulting from a known volume of air The fibers are counted are seen at a given magnification and the number to count which will vary The standard practice in industrial hygiene is to use a phase contrast microscope at a magnification of X430 The fibers counted are those having a length of greater than 5 microns with ratio of length to breadth at least 1 the cles The use of an to be counted electron microscope would allow all the partiHowever the expense time and expertise neces- 448 sary to count all the particles makes this procedure impractical it is basis In understanding important not to with those based control techniques and their efficiencies confuse efficiencies quoted on a weight on a particle count Considering efficiency based on a weight basis it is relatively easy to get a very high efficiency with particles whose size is in excess of 5 microns with a variety of con- trol devices However the efficiency does drop off considerably with decrease of particle size Dr. Harwood in his study considers what a collection efficiency as high as 99.999 the percentage of the total weight of the particulate matter which will be collected by the filter actually Ex 20 means in 47 terms of the He concludes of number that 10 fibers collected fibers actually will pass through the collecting filter for every 1 gram of material impinging upon it This is a situation not frequently brought out but is very significant when exposure levels are per cubic centimeter Thus quoting monitored in terms of fibers of efficiency in terms of mass efficiency is a statement that tends to be deceptive It bears no obvious relation to the number of fibers being emitted However based on tests which actually measure the number of fibers being emitted it would seem that both fabric filters and high efficiency wet scrubber arse capable of reducing the fiber counts to acceptable levels British experience is that 0.2 cc is routine and Johns Manville finds that 1 cc is an acceptable value when the results are averaged over a time period We adopt the two fibers per cubic centimeter and the micron standards because of the facility of both abatement over five and measure- ment utilizing these numbers and because they furnish a sound indication of asbestos content in the air However recognition that particles of smaller size may have adverse health consequences of equal or greater magnitude will require the Board to review this subject periodically in consideration of the available measurement technology See Ex 6 Lynch Ayer and Johnson The Interrelationships of Selected Asbestos Exposure Indices American Industrial Hygiene Association Journal September 1970 p 598. The direct index of asbestos fiber exposure proved to be the concentra- tion of fibers longer than 5 microns See Ex 27 Edwards and Lynch The Method Used by the U. tioonf Asbestos Dust on Membrane S. Public Filters Health Service for EnumeraU. S. Department of HEW wed the Consideration must be given to available control techniques fabrication and use of asbestos containing products and exposure resulting from activities involving asbestos emission potential Because of the demonstrated alternatives to asbestos spraying our regulations will flatly outlaw this activity Spraying of asbestos materials are permitted subject to stringent protec- tive measures Air ventilation systems can be employed to minimize emission during the mixing of fibrous fireproofing and insulation materials Hoods can be provided at opening and emptying areas The mixing area if not totally enclosed should be ventilated Conveying equipment to and from the mixer can be enclosed mixed material should be done under suction hoods Bagging of the site controls needed include enclosing the area to be sprayed and employing good housekeeping procedures both before and following the spray operation The filling of the spray machine hopper must be done carefully to minimize dust When the machine is not in use the hopper should be covered to prevent the material from being blown about Several states and manufacturing associations have published guidelines for emission control The recommendations include the following 1 All areas used for opening bags containing fibrous ) insulating materials and be enclosed Empty bags charging of hoppers should should be properly disposed of 2 Floor areas should be swept broom clean before spray- ing operations begin All unnecessary objects the spray area should be removed or covered with plastic or plastic coated tarpaulins 3 The entire area to be sprayed should be enclosed with plastic will be or plastic considered coated tarpaulins An enclosure satisfactory only if visible insulating material cannot escape from the closure 4 containing material that falls to the floor should be swept up immediately and placed in approved disposable containers 5 When spraying is completed in an area the entire work area and the materials used to form the enclosure should be thoroughly vacuumed The vacuum cleaner should contain a strong service disposal inner bag which shall be removed from the vacuum sealed Disposal is the same as for other cleaner and bagged waste materials 3 - 450 p> oh oo 6 Any plenum or other structure coated with asbestoscontaining insulation and intended for circulation of air in the building must be thoroughly cleaned of or debris plenum and waste Fibrous must be coated with insulation in a duct a sealer to preclude erosion of the insulation by circulating air Our regulations embody the essential features of these suggestions Asbestos emissions are likely in any process in which asbestos fiber is handled or containing materials are cut drilled or trimmed The quantity of asbestos dust generated by these oper- ations can be quite large Since it is impractical to completely seal a factory or a work area industry has adopted an arrest source technique for capturing this ventilation system comprised of capture dust utilizing a hoods ductwork complex fans and filters Benefits received from this system include 1 Reduced atmospheric emission when plant is open to ambient conditions i.e. doors and windows open. 2 Reduced external emission from fibers being carried outside on work clothing and manufactured products 3 Greater efficiency in plant operation because of reduced internal housekeeping chores vacuuming etc. 4 . Better personnel attitudes The ventilation system may eliminate the need which limit efficiency for and personal respirator units are generally disliked by workers The air ventilation system is an integral part of the emission of various systems in operation will control program and the components be considered Two types of ventilation systems are employed for dust emission control low volume high velocity and high volume low velocity Each requires a specific type of hood design The low volume high velocity systems induce an extremely high captive air velocity 10,000 to 12,000 min at the dust The air volume however averages only 10-250 cfm With source this system it is essential that the feed particles be carried by the air stream The entrainment force must exceed the gravitational or projectional force Low velocity high volume air ventilation systems on the other hand are utilized for operations where localized capture 15 3 - 451 not possible to the ducted For area such must hoods be at to be least effective 150 min the and air velocity should be such that the air flow direction is always toward the collection system A considerable amount of ductwork is required for a plant having a central collection no sharp bends are recommended point Circular Inspection ports ducts should provided near bends large having be Several types of collectors have been utilized by the asbestos industry for dust control Baghouses used filtering system Wet scrubbers represent the most frequently are also used Cyclone pre- cipitators may be used as primary collectors preceding baghouse filters Electrostatic precipitators tried by the asbestos industry have several deficiencies Asbestos is an insulator and builds upon the electrodes reducing efficiency higher than for baghouses An electrical Installation costs are failure would remove all emission control The most commonly used filter system is the fabric filter This device is found in a wide variety of forms from highly sophis- ticated systems containing thousands of bags to crude devices con- taining homemade burlap bags The baghouse is compartmentalized to allow continuous operation by alternately cutting off sections 6 ee for cleaning while other sections continue their dust removal func- tion The bags are cleaned by a mechanical shaking action either by a shaking floor or more commonly by More elaborate cleaning systems such as reverse a shaking cycle air support jets or sonic systems have not been considered worth the extra complica- tion The baghouse unit is frequently located outside the factory building to conserve space Usually the filtered air is exhausted to the atmosphere In some cases it is returned to the factory to conserve heat This air contains some asbestos fibers since no control technique is considered to be 100 efficient Waste products collected in the baghouse hoppper are removed by helical screw con- veyor Design of the hopper emptying mechanism should provide as foolproof an operation as possible Severe pollution can arise if the mechanism is opened for repair Other collection devices used either in filters or alone are various types of cyclone combination separators with fabric Low efficiency cyclones are used in the asbestos industry as first ful when stage separators preceding fabric the waste product is reusable and filters there is They are usea considerable quantity present Thus the load on the fabric filter is relieved 3 -452 -452 omy hy et Nay a? Further the life the removal of heavy of the filter bag abrasive waste material will prolong High efficiency cyclones are generally employed in multiple units They are used where high efficiency is required and where no use is made of backup fabric filters Wet cyclones are employed as emission control devices in some special instances where wet processes are used for production of asbestos products Although generally not as efficient as bag filters they eliminate the problem of filter blockage caused by condensation The fans which provide the air movement through the dust collection system may be mounted either upstream or downstream of the filter system the most common arrangement being downstream This places the ventilation system under a negative pressure assuring that ambient air will be drawn into the system in case of leaks rather than dust and fibers being exhausted to the atmosphere All asbestos product manufacturers are faced with the problems of storage and transportation of bagged asbestos fibers Emission controls for these operations depends to a great extent upon the conscientiousness of the individual user Manufacturers should provide clearly defined clean dry storage space for the bags where A rotation system should they are protected from accidental damage be employed to ensure that older bags are used first Damaged bags should be placed in larger slipover bags and resealed Small tears in bags should be patched with tape Jute bags are permeable and will allow fiber emission Kraft paper bags are liable to tearing when handled roughly The best compromise at this time seems to be bags of coated woven polyolefin Bag storage and the bag opening areas should be as close as practical lift trucks are usually employed the bags between these areas The route used by the to transport trucks should be smooth surfaced and free of obstructions which might cause damage to the bags The bags should be opened in a hooded area using a sharp knife to slit the bag Pressure packed fibers will hold together as a unit and can be slipped into an enclosed conveying system where they are transported to a fiber opener conveyor systems transporting asbestos willow or fluffer fibers or mixtures of All asbestos and other materials must be completely enclosed - 463 The emptied bags also present an emission source Care must be taken to dispose of them Since there are few manufacturing processes which will accept paper bags as part of the process asbestos paper being an exception they are usually bundled into large poly- ethylene bags and taken to dumps for disposal can be similarly utilized in some manufacturing Plastic shipping processes as the bags floor tile industry for example A possible source of emission the transport of fibers outside by control of this source of emission from manufacturing processes is the workers themselves The to date has not been very satis- factory At best booths from their clothing The are provided where workers may clean fibers booths are equipped with extraction fans in the ceiling and a flexible pressure hose Suction hoses would be preferable Separate lockers for work and street clothing is suggested See Ex 9 Cralley Identification and Control of Asbestos Exposures American Industrial Hygiene Association Journal February 1971 P. 82 Ex 18 Recommendations for Handling Asbestos Engineering Equipment User Assn No. 33 Rev. 1971. Ex 13 Recommended Health Safety Practices National Insulation Manufacturers Association Inc. Demolition and waste disposal are likely to be emission sources if appreciable amounts of asbestos are used in construction unless , operational procedures are strictly controlled Isolation enclosure and wetting down are useful Caution must be observed not to demolish during high winds and to keep sludge from drying out and becoming air- borne later through natural forces and from being introduced into sources of drinking water The subject of disposal of asbestos waste must be examined Re- cycling is possible if a plant the effectiveness of recycling has a ventilation system But varies with the kind of processing f a product such as water pipes is made in which asbestos is mixed with cement a chemical reaction occurs making use of much waste imprac- tical or impossible If asbestos paper is produced much airborne fiber can be collected and used However virtually all manufacturing of asbestos products can involve some recycling The dust collected in the filters the short fibers can be re- used in the manufacturing of transite pipe This pipe contains mostly long fibers used for their strength and thus only a limited amount of the shorts can be mixed in Recycling is especially feasible for large companies which manufacture transite pipe as well as other asbes- tos products In this case recycling is profitable as it involves only cleaning the filters and transporting the shorts in the area of the plant or to the division of the company which manufactures transite Recycling does not appear to be relied upon as much in plants which do not produce transite In such case the company 3 - 454 454 454 would have demand is to sell Nor Nor sel do its short fibers We do not know how great the we know the percentage of collected fibers which can be recycled under optimal economic conditions Manville in Waukegan claims to use most of the filtered short fibers But it manufactures transite brake linings sheet packing and gaskets which facilitates and makes cheaper the use of captured fibers in transite production Generally the asbestos collected through the filters or swept disposed into plastic bags A special disposal procedure is folowed folowed followed by some manufacturers of asbestos paper products Water thefolwedis used in the production which ^/rained off into settling ponds the water is then channeled back picks up asbestos fibers and is then The heavy material settles out and to the plant for use The sludge is at the bottom of the pond and is shovelled up and dumped The material is not buried We do not know if any factory directly or eventually discharges this water into natural water flows or sewage systems which could pose a considerable hazard The Manville Waukegan plant uses a pond syster but the water is recycled While our regulations are enacted in the context of other govern- mental controls of tions to deal with asbestos they necessarily go beyond these regulasignificant emission sources not covered elsewhere The Federal Environmental Protection Agency proposed asbestos standards on December 7 1971 under its authority to regulate hazardous air pollutants 40 CFR Part 6 All emission sources which exist in Illinois and which are proposed for coverage by the Federal Environmental Protection Agency are covered by today's regulation Also our regulation covers waste water pollution imposes procedural safeguards disposal and for construction and demolition and sets a numerical emission standard in addition to a no visible emission standard for manufacturing emissions beyond the plant The Illinois Department of Labor adopted the recommended safety standard of the American Conference of Governmental Hygienists for plant air The regulation we adopt today does not control the levels of asbestos inside a plant largely an occu- pational hazard beyond our jurisdiction Insofar regulation affects what transpires inside a plant tion site the impact is merely incidental to the as this Board's or on a construc- relationship be- tween certain plant activity and a significant hazard of air pollution beyond the site of such activity For example Sec 201 requires that facilities be provided at the work site to prevent the removal of visible amounts of asbes- tos from the site on the clothing of employees The evidence shows that human transport of asbestos fiber is a health hazard to those coming into contact with asbestos workers beyond the confines of the job 3 455 The Illinois Department of Labor also adopted procedures for enclosure and cleaning of construction sites on which asbestos is sprayed These procedures were intended to workers on the site although their effect protect the if pursued health of would be to reduce emissions to the ambient air The record shows that such procedures are cumbersome seldom obeyed to the letter difficult to enforce and insufficient when obeyed to protect the public beyond a construction site Hence we have banned asbestos spraying Again the impact which this Board's decision exerts on the actions of another state agency is made necessary by our mandate to protect all members of the public from air pollution A similar ban on spray asbestos has already been Cities of Chicago effective January 1 1972 and New being considered by several other cities taken York by the and is In consideration of the foregoing factors the Board submits a comprehensive regulation for asbestos controls To this end the regulations identify the significant contributors of asbestos as the commercial use of asbestos in construction work the demolition of containing structures the manufacturing and processing of containing products the transportation of certain asbescontaining products and the disposal of containing waste The use of asbestos in brakes while originally included as a sub- ject of control will be deferred for the time being Part II of the regulations imposes several general requirements upon all commercial construction repair alteration demolition manufacturing or processing activity from which asbestos fiber is discharged into the ambient air The persons responsible for manufacturing activity must obtain a permit from the Environmental Protection Agency The permit system will serve to produce the advanced assurance of compliance with the applicable control regula- tions and will thus reduce the cost and burden of field en- forcement In addition these commercial activities must provide facilities to prevent the removal of asbestos fibers from the site of such activity on the clothing of employees Indeed this poses a rather new concept of air pollution control Those who have died from lung ailments induced by long close association to an asbestos worker may be powerful proof of the need for novelty Finally the Regulation would provide for careful waste disposal procedures as blown to the volume of asbestos refuse heaps fiber in our and scrap air The piles contribute simple steps for control eliminate any excuse for such dangerously sloppy housework 3-456 3-456 3-456 In our final draft the permit requirement of Part II nas been restricted to manufacturing emission sources This is in accord with the Agency testimony that presently it has inadequate staff to handle the permit load created by a blanket requirement manufacturers of asbestos products must obtain a permit by June 30 1972 All Part III prohibits the spraying of containing insulation and fireproofing Experience has indicated that procedural safeguards are inadequate and their enforcement is an overtaxing burden would Procedural safeguards designed to be required to sp spray ray asbestos spray reduce fiber insulation emissions The biological biological effects of these fibers is unknown Prudence would seem to dictate reasonable efforts to soften the potential future blow from spray fiber aspiring to asbestos status Part III requires that various asbestos activities at construction sites be done within an enclosure It would also require that asbestos construction products be so installed as to preclude the emission of fiber into the circulating air In the interest of efficient enforcement the numerous restric- tions on the spraying of asbestos fibrous material have been reduced to requirements for enclosure and for vacuuming Also this section has been changed to make clear that these safeguards are required only when spraying of asbestos area open to the atmosphere This open to materials occurs in an the atmosphere modifica- tion has also been added to the section controlling the cutting trimming fitting or stripping a construction site Part III of containing materials at now contains a no visible emission standard which must be met regardless of adherence to the required procedural safeguards tend to insure greater This should permit compliance with the easier enforcement safeguards and The original proposal contained two regulations controlling the general application of containing materials and the application of asbestos materials This has been altered to require that in air ducts or plenums only containing mater- ials used in any construction work be so installed as to preclude emission of the fiber to the circulating air There is little medical data available to prove or disprove the toxic effects of the multitude of fibrous construction material although one such product fiberglass would appear to be biologically inert The Board prefers to act on the safe side of health in regard to spray- ing operations which can emit large quantities of fiber if uncon- trolled In any event such uncontrolled emissions constitute a nuisance dust and could be controlled on that basis alone These reasons do not apply with equal force to the spray application of asbestos materials in construction 457 ea? AppBOS eat Part IV expresses ironically what may be a key reason for banning spray asbestos It would require that procedural safe- guards be pursued in order to demolish a structure whose destruction would otherwise expose members of the public to asbestos fiber Clouds of dust are often raised by demolition work The fact that great numbers of persons may be exposed to this dust in urban areas and that the post generation of nigh rises were the first to use asbestos insulation extensively speak in favor of such buildings regula- tion Part IV is intended to require an enclosure only when neces- sary to prevent enclosure which dispersion of is reasonably dust during demolition and only an compatible with the structure to be demolished In some cases total enclosure can be feasibly achieved With other structures a ground level enclosure may be the limit of compatibility quire Part V controlling manufacturing sources is charged to re- an emission standard of two fibers per cubic centimeter and no visible emissions While some testimony indicated the difficulty in measuring compliance with a numerical emission standard overall the evidence establishes both the need proportion of invisible fiber and the protection against ease of measurement the great of such a criterion A no visible emission standard has been added to the numerical standard to simplify enforcement against exceptionally dirty emission sources A grace period until June 30 1972 has been added to permit acquisition of the necessary control equipment to attain the emission standard References are made to the method to be used in collecting and counting emission samples The sampling method is that generally used in sampling particulate emissions The counting method is that reliably used by the U. S. Public Health Service A requirement has been added at the Environmental Protection Agency's suggestion to channel all asbestos emissions inside the plant through control equipment and to exhaust such emissions through points where samples can be taken This is intended to prevent vent- ing through windows or doors or other avenues of escape on which sampling cannot be adequately performed The Agency is also given the power to inspect manufacturing premises at reasonable times to determine compliance Also the manufacturer must engage in monitor- ing and reporting The latter two additions are in keeping with the Board's practice in most areas of regulation The waste water discharge provision now requires no discharge of process water to which the manufacturer has added asbestos unless best available treatment technology is first utilized no visible enission standard has been added to the trans- portation portation regulation five five TTh he e emei mision ss emissi ion on microns microns microns microns microns microns microns The standard justification justification standard justification would measure For this only fibers seems to be longer than the adminis trative trative trative trative trative .5 trative from from dicated dicated dicated dicated dicateddicated dicated dicated convenience of avoidingavoiding difficulties in measuring fibers to to five microns in length Some medical evidence has in- that the very small fibers may be the most dangerous The Board Board w willill continue to examine the medical implications of the sub- five five five mimcircornon micron fibers and the means of measurement and control V Sec 501 - has been slightly draft to add the phrase into the clear that the emission standard does changed from ambient air not apply to the proin order the in- " 502 - the word enclose suggestion that as previously total enclosure of all has been changed to written the meaning facilities Our originaloriginal proposal would have prohibited the use of brake lining in vehicles manufactured after for use an Illinois It was believed January 1 1975 if brake lining and sold decomposition emits asbestos fiber then the tremendous number of vehicles using asbestos and the practicability of controlling these numerous small emission sources would appear to speak to the need for a pro- duct ban This proposal to ban asbestos brake lining has been dropped for being the time Lion 15 a While the evidence shows that brake significant source of background levels of lining decomposiasbestos these ambient health air levels are quite hazard although they small and have not been have not been shown not shown to to be be In addition addition adequate alternatives to asbestos brakes are not a yet available although closed braking systems preventing the emission of asbestos dust possible The Board will follow the medical and engineering aspects of this problem and possibly may return to Finally local governments are obliged to enforce these regulations except for the manufacturing provisions Much of the problem arises from numerous construction activities and the Agency cannot adequately emission supervise these many emission sources The no visible standard has been added especially to facilitate local government and citizen assistance in enforcement I Christan Moffett Clerk of the Illinois certify that 1972 by a vote the of4-0 above Opinion was adopted Pollut Control on the day of Board Christ N offi offi 3 - 459