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FILE NAME Manville JMA DATE 1971 DOC JMA208 DOCUMENT DESCRIPTION Illinois Pollution Control Board Regulations - AIA Document ot ENVIRONMENTAL HEAT 1 TASK FORCE - M. Ball D. R. P. Carter T. H. Davison M. D. J. E. Hesse E. M. Fenner H. M. Jackson J. B. Jobe K. V. Lindell A. B. Marchant F. L. Pundsack W. P. Raines Ivan Sabourin C. L. Sheckler F. J. Solon Jr. A. C. Smith M. M. Swetonic Carl Thompson W. L. VanDerbeek G. W. Wright M. D. AIA MEMBER COMPANIES George Barge J. D. Christian A. H. Fay R. Power Fraser W. E. Gatewood J. H. Marsh C. G. Morgan J. L. Rainey Kurt Schwarz F. J. Solon Jr. E. W. Swain S. D. Weaver AIA ADMINISTRATIVE COMMITTEE W. P. Raines M. M. Swetonic E. M. Fenner L. J. Woodward Carl Thompson James Callaghan CC R. Goodwin P. Gibbons W. Hendry R. M. Hutcheson Poutiatine A. Cross L. Goodman Dr. S. Holmes W. R. Janes Dr. P. V. Pelnar Michael Howe J. PRODUCED PRODUCED 83 - GHQ. December 3 1971 TO MANVILLE ENVIRONMENTAL HEALTH ~ AIA MEMBER COMPANIES AIA ADMINISTRATIVE COMMITTEE TASK ; FORCE CC Dr. Joseph L. Ike Weaver Goodman Ed Drislane C. R. Wikel R. F. Winkworth H. J. Roesch Frank Zimmerman Bradley Walls ILLINOIS POLLUTION CONTROL BOARD REGULATIONS ON ASBESTOS Attached is the Proposed Final Draft Pollution Board regulations on changes of a positive nature have been section of the regulations as compared last summer of the State of Illinois asbestos Substantial made with in nearly the draft ' every published Among the most important changes are the following 1. The section banning the use of containing brake linings after 1975 has been eliminated While it might appear from the comments in the Explanation section of the regulations on page 10-11 that this question is not completely settled it is our belief that the Board will take no further action against brake linings unless the Federal Government does first in which case any action taken by the state would be rather academic 2 The plant emission standard has been raised from a level of .5 fibers per cc to a more acceptable level of 2 fibers per cc In addition the standard of .05 fibers per cc at the boundary line of a plant has been eliminated completely 3. A no visible emissions standard has been included in various sections of the regulations where enforcement of a stricter standard would have been a problem if not impossible 4 ae The segment of the regulations requiring total enclosure of a structure under demolition before toppling of walls could begin has been altered to a more do the best you can standard PRODUCED PRODUCED - 83 5 The section requiring the use of a sealant on all fibrous materials used inside ducts or plenums has been changed to containing materials , only 6 The section prohibiting the discharge of asbestos- containing process waste water into the rivers streams and sewers of the state has been changed to permit such discharge if the waste water is given the best available treatment consistent with technological feasibility and economic reasonableness 7 Under the Proposed Final Draft only manufacturing : plants will be required to obtain a permit from the state The first draft required permits for any operation or activity involving asbestos The vast majority of the above and other positive changes in theregulations reflect specific recommendations and corroborative evidence presented to the Board by Dr. F. L. Pundsack of Manville and Dr. Joseph L. Goodman of Manhattan on behalf of the AIA at the public hearing on the regulations held October 15 in Chicago and by Dr. George W. Wright and an industry team at a meeting held with Board staff representatives in September Also participating in the overall cooperative industry effort were NIMA and the Friction Materials Standards Institute . Attached is a copy of the specific changes submitted by the AIA at Board request following the Chicago hearing Because of the many changes in the final draft the section and section numbers on the AIA recommendations do not correspond to those in the final the basic changes recommended by , by the Board draft However as you can see the AIA have been adopted It is indeed an encouraging sign to find that in this era of national environmental panic a documented and presented industry case can those obtained in produce results as fair the state of Illinois and reasonable as Much credit must go to the responsible Control Board and yet fair attitude of the Illinois Pollution to all those in the industr whyo worked long and hard on this project W. P. Raines PRODUCED PRODUCED JM - 83 ILLINOIS POLLUTION CONTROL BOARD November 30 1971 9 In the matter of ASBESTOS REGULATIONS R71-16 _ NOTICE OF PROPOSED FINAL DRAFT Following hearings the Board on November 23 1971 authorized of the following proposed final draft of asbestos publication emission regulations for final public comment Written comment will be accepted until December 15 1971 with final adoption ex- pected in late December 1971 or early January 1972 ILLINOIS POLLUTION CONTROL BOARD Rules and Regulations Proposed final draft published for public comment November 30 1971. Not adopted by the Board Comments are invited and should be directed to Samuel T. Lawton Jr. Title I Chapter V Hazardous Substances Asbestos and Spray Insulation and Fireproofing Part I Part II Part III Table of Contents Introduction 101 Authority 102 1.03 Policy Definitions ' General Requirements 201 Safety and Waste Disposal 202 Permit for manufacturing : Construction Alteration and Repair of Structure 301 302 303 Spray asbestos prohibited asbestos spray insulation Enclosure for asbestos construction 304 305 No visible emission Preclude exposure to circulating air Part IV Demolition 401 PRODUPROCDUCEED D Necessary and practicable safeguard : - Part V Part VI : -2- Manufacturing 501 Emission standards Sampling & Counting Procedures 502 Venting of all emissions to central sources 503 504 505 Inspection Monitoring and reporting Process waste water effluent criteria 506 507 Sludge disposal Transportation of asbestos - containing 508 products No visible emission Local Enforcement 601 Obligation to enforce PART I INTRODUCTION 101 - Authority Pursuant to the authority in Sections 9 10 and 13 of the Environmental Protection Act which empower the Board to adopt regulations forbidding the sale offer or use for reasons of air pollution control of any article and to set standards standards specifying the maximum amounts or concentrations of various contaminants that may be discharged into the atmosphere and to set standards for the issuance of permits for the operation or of any equipment facility capable of causing or contributing to air pollution and to promulgate conditions regarding the use of article determined by the Board to constitute an air pollution hazard and to adopt effluent standards limiting the amounts of contaminants that may be discharged into the water of Illinois the Board adopts the following rules and regulations 102 ' Policy It is the purpose of the General Assembly in adopting the Environmental Protection Act to maintain and enhance the purity of the air and water of Illinois in order to protect health welfare and the quality of life Accordingly it is hereby determined that the uncontrolled discharge of asbestos fiber into the environment tends to severely endanger the public health and welfare and that the uncontrolled spraying of containing materials unreasonably interferes with the enjoyment of life and property -3- amount ! ! . of purpose It is the purpose of these asbestos fiber released into regulations to control the amount the environment from the major not { sources of emission Such control is necessary only to those members of the public who are in proximity to heavy protect fiber but also to safeguard the health concentrations of asbestos of future generations endangered by the continuous discharge of asbestos fiber which can be toxic and which tends to be cumulative both in the atmosphere and in the human body Where health can be protected by the adoption of an emission standard or of procedural safeguards such a course has been In those instances where restriction is unfeasible pursued of the unusual nature of the emission source spray asbestos because at construction sites a product ban has been resorted to This prohibition has been made with full consideration given to the available alternative materials It is also the purpose of these regulations to reduce the emission of asbestos particulate from fireproofing and insulation To protect against these emissions the biological effects of which are unknown procedural safeguards have been . enacted 103 Definitions Agency The Illinois Environmental Protection Agency i Asbestos eb , mo Any fiber or any mixture containing fiber of hydrated silicate mineral which on the basis of its crystalline structure falls into one of s+ two categories ee aE 1 pyroxenes - chrysotile fiber . - crocidolite amosite eerdee a te0S , t Pa e2e atmrpehmiobloiltees actinolite or anthopm ho it liet,e me, a fot Beet ea. fiber -..! . ae ; . - _ a a Board . Th^' Pollution Control Board of Illinois _ Activity Debris , activity done for hire or having financial profit as a primary aim containing waste producebdy the demolition of a structure Spraying The pneumatic application of material used for fireproofing or insulation Waste PRODUCED Any containing matter which has or is intended to be discarded JM83 been -4- PART II General Requirements 201 After June 30 1972 no commercial activity not otherwise hereinafter prohibited involving the potential discharge of visible amounts of asbestos fiber or containing materials into the environment from the construction alteration repair or demolition of a structure or from the processing or manufacturing of containing products shall be conducted unless the person or entity in charge of such activity complies with the following regulations a Personnel shall be designated to exercise time supervisory authority over all aspects of the activity from which the release of asbestos fiber into the environment could result in such a manner as to insure compliance with the pertinent asbestos control regulations b Each employee engaged in such activity shall complete a course of instruction on the potential hazards of exposure to asbestos fiber including the precautions that must be observed to prevent or restrict the dispersion of asbestos fiber into the environment shall c Facilities be provided and procedures instituted and supervised that prevent the removal from the site of visible amounts of containing. material on the clothing of the employees d containing wastes shall be immediately vacuumed or otherwise collected where vacuuming is impossible and shall be placed in a container resistant to tearing or | breaking under normal handling conditions which shall be __ tightly sealed and clearly marked as containing asbestos waste Such containers shall be placed directly upon a _ - vehicle for disposably burial at a sanitary landfill Section 201 shall not apply to the demolition of a structure except as provided in Section 401 d and e or to the disposal of sludge waste except as . provided in Section 506 202 After June 30 1972 the manufacturing or processing of asbestos containing products is prohibited unless the person or entity in charge of such activity has obtained a permit from the Agency Before obtaining such permit the applicant shall demonstrate compliance with Sec 201 and such additional standards are hereinafter specifically required PRODUCED JM - 83 \ : -5- * ' PART III Construction Alteration and Repair of a ~ Structure 301 The spraying of containing material is prohibited . after March 31 1972 302 area asbestos fibrous matter shall open to the atmosphere unless the are taken not be sprayed in an following procedures a The entire floor or be enclosed with plastic area to be sprayed shall or plastic tarpaulins in a manner which shall preclude the escape of fiber- containing material from the enclosure All interior . areas such as elevator shafts and stairwells shall open be enclosed in a manner which shall prevent the escape of containing material from the working area b The entire sprayed area all ledges and surfaces including tarpaulins within the enclosure shall be thoroughly vacuumed upon completion of the spraying operation and immediately before the enclosure is : dismantled a The cutting trimuning fitting or stripping of containing material in the construction alteration or repair of a structure which is done at the site of such structure in an area open to the atmosphere shall be conducted within a special enclosure designed to preclude the escape of asbestos fiber from the immediate area of such enclosure , of b The mechanical exhaustion dust from such enclosure to the ambient air is prohibited unless such exhaust system is equipped with a properly sized fabric filter for dust collection or an equivalent device as approved by the Agency 304 Compliance with Sections 302 and 303 notwithstanding visible emissions of containing material in an area open to the atmosphere shall be considered a violation 305 containing material applied in the construction alteration or repair of a structure shall be coated with a sealant provided with a cover or installed some other . manner so as to preclude emission of the containing material to the circulating air Any plenum or other structure coated with or containing containing insulation and used in the circulation of air in a building shall inPRODUCED inPRODUCED thoroughly cleaned of all debris and waste -6- | PART IV Demolition 401 Where the risk of public exposure to asbestos fiber from the dislodging of containing materials is present no demolition of a structure shall be initiated unless all safeguards necessary and practicable to reduce the emission of dust are taken . . se Such procedures shall include but are not necessarily limited to a Boilers and pipes and steel members insulated or fireproofed with containing material shall be wetted and stripped before toppling of walls is begun atte This procedure shall be followed where practicable to all other asbestos surfaces Such asbestos waste shall be immediately bagged and disposed of in as accordance with Section 201 d b When enclosure demolition by toppling occurs such reasonable for dust emission control as is compatible with the character of the structure shall be employed c Before the demolition or toppling of any section ' or wall of the structure adequate wetting to suppress the dust shall be employed d containing debris shall not be dropped or thrown from any floor but shall be transported by dusttight chutes or buckets containing debris in chutes or buckets shall be sufficiently wetted to preclude dust dispersioant the point of discharge e All containing debris shall be thoroughly wetted before loading into trucks other vehicles or containers During transport such waste shall be enclosed or covered so as to prevent dust dispersion Asbestoscontaining debris shall be disposed by burial at a sanitary , . . landfill PART V Manufacturing 501 a After June 30 1972 a factory plant or enterprise ~~~ which engages in the processing or manufacturing of any containing product shall discharge no visible emission of particulate matter from such manufacturing or processing into the ambient air and shall emit no concentrations of asbestos fiber in excesosf 2 fibers oe per cubic centimeter of air PRODUCED PRODUCED 83 i 1 Sampling of emissions shall be by the membrane filter method and according to the procedures recommended in the ASME Power Test Code 27-1957 or other procedures generally accepted persons knowledgeable in the state of the art 2 Counting shall be according to the procedure outlined in Edwards G.H. and Lynch J.R. The Method Used by the U.S. Public Health Service for _ Enumeration of Asbestos Dust on Membrane Filters Ann Occupational Hyg Oxford 11 1 1-6 Jan. '68 with 20 fields per sample counted at random using phase contrast microscopy at 430x magnification and counting only fibers 5 microns or greater in length with a length to breadth ratio of 3 to 1 or greater 502 Any factory plant or enterprise which engages in the or manufacturing of any asbestos containing product processing facilities so that exhaust shall enclose all asbestos handling air can be ducted through necessary air pollution control equipment and samples taken of the gases which are emitted ; into the ambient air 503 ' i be to Any factory planotr enterprise for which sought or has been granted pursuant to Sec 202 shall subject inspection by the Agency at time without prior notice a permit is hereunder any reasonable wee 504 At a frequency to be determinebdy the Agency any factory plant or enterprise which engages in the shall processing or manufacturin sample the exhaust from of any containing product and submit the emission data such factory plant or enterprise to the Agency _ 506 - 507 A factory plant or enterprise the manufacturing processes of which add asbestos fiber to water shall not discharge such waste water to the sewers or waters of Illinois unless process waste water is given the best available treatment csounchsisptroecnetsswith technological feasibility and economic reasonablene Waste sludge containing asbestos and collected from sett- ling ponds shall be enclosed during transport and shall be disposed by burial at a sanitary landfill No product which may emit portation shall be transported so as to preclude the emission air asbestos during its transunless such product is enclosed of asbestos fiber into the ambient a mer PRODUCED JM - 83 -8; 508 - Nothwithstanding compliance with Sections 506 and 507 in the visible emission of particulate matter the course of transportation shall be considered a violation such PART VI Local Enforcement 601 It shall be the obligation of local governments as well as the Agency to enforce by appropriate means the requirements of Section 201 of Parts III IV and of Sections 506 507 7 and 508 -9- . R71-16 Asbestos Explanation Revision of Proposed Regulation The regulation proposed and explained which public hearing was held is generally final draft A summary of the significant follows in Newsletter 24 on similar to the proposed substantive changes I. The permit requirement of Part II have been restricted to manufacturing emission sources This is in accord with the by Agency testimony that presently it has inadequate staff to handle |. the permit load created by a blanket requirement All manufacturers of asbestos products would have to obtain a permit , June 30 a . 1972 II Parts III and IV of the original proposal have been combined under one heading covering construction uses of asbestos products A period until March 31 1972 has been added to the proposed ban on spray asbestos In the interest of efficient enforcement the numerous restrictions 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 materials occurs in an area open to the atmosphere This open to the atmosphere modification has also been added to the section controlling the cutting trimming fitting or stripping of containing materials at a construction site Part III now contains no visible emission standard which must be procedural safeguards tend to insure greater met regardless of adherence to the required This should permit easier enforcement and compliance with the safeguards to The original proposal contained two regulations con- trolling the general application of containing materials and the application of asbestos materials in air ducts or plenums This has been altered to require that only asbestos- construction work be so installed containing materials used in any 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 biologi- cally inert The Board prefers act on the safe side of health in regard to spraying operations which can emit large quantities of fiber if uncontrolled 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 non- spray application of fibrous materials in construction | : oa : peg PRODUCED | PRODUCED 83 -10- | | III Part IV controlling demolition remains unchanged except for a rewording of the requirement for enclosure The final proposal is intended to require an enclosure only when necessary to prevent dispersion of dust and only an enclosure which is reasonably 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 com- IV Part V controlling manufacturing sources is changed to dirty quire an emission standard of 2 fibers per cubic centimeter and no visible emissions While some testimony indicated the difficulty in measuring compliance with a numerical emission standard over- all the evidence establishes both the need protection against the great proportion of invisible fiber and the ease of measurement of such a criterion A no visible emission standard has been added to the numerical standard to simplify enforcement against exceptionally emission sources A grace period until of the June 30 1972 has been added to permit acquisition necessary control equipment to attain the emission standard re- 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 Protec- emissions inside tion Agency's suggestion to channel all asbestos the plant through control equipment and to exhaust such emissions through points where samples can be taken This is intended to - prevent venting through windows or doors or other avenues of escape on which sampling cannot be adequatemlaynufpaecrtfuorrimnegd preTmhieses Agency is also given the power to inspect to determine compliance Also the manufacturer at reasonable times The latter two additions must engage in monitoring and reporting are in keeping with the Board's practice in most areas of regulation charge unless The waste water discharge provision now requires no disof process water to which the manufacturer has added asbestos best available treatment technology is first utilized A no visible emission transportation regulation standard has been added to the . to - The original proposal ban asbesttohse bervaikdeencleinisnhgows has been dropped for the time being While source of back- that brake lining decomposition is a significant ground levels of asbestos these ambient air levels are quite health hazard although they small and have not been shown to be a alternatives have not been shown not to be In addition adequate to asbestos brakes are not yet available although closed PRODUCED | JM 83 -11- to braking systems preventing the emission of asbestos dust are possible The Board will follow the medical and engineering as- return it pects of this problem and possibly may are I. Finally local governments obliged to enforce these regulations except for the manufacturing provisions Much and of the problem arises from numerous construction activities the Agency cannot adequately supervise these many emission sources The no visible emission standard has been added especially to facilitate local government and citizen assistance in enforcement os eamws eS ern ames+e | PRODUCED JM 201 202 203 301 302 ' 401 402 RECOMMENDED CHANGES IN ILLINOIS POLLUTION CONTROL BOARD REGULATIONS ON ASBESTOS PART II GENERAL REQUIREMENTS No commercial activity not otherwise hereinafter prohibited involving the potential discharge of visible amounts of asbestos fiber into the environment from the construction alteration repair or demolition of a structure or from the processing or manufacturing of containing products shall be conducted unless the person or entity in charge of such activity complies with the following regulations No recommended changes Facilities shall be provided and procedures instituted and supervised that preventhte removal of visible amounts of containing material from the site on the clothing of employees No recommended changes PART III SPRAY FIREPROOFING AND INSULATION Norecommended changes - No recommended changes Sections a thru f g Any plenum or other structure coated with or containing containing insulation and used in the circulation of air in a building shall be thoroughly cleaned of all debris and waste insulation All applied asbestos containing insulation within a plenum or duct shall be coated with a sealant which precludes exposure of the asbestos containing material to the circulating air PART IV CONSTRUCTION ALTERATION AND REPAIR OF STRUCTURE a Visible emissions from the cutting trimming fitting or stripping of containing material in an area open to the atmosphere are prohibited ' b Visible emissions of containing particulate matter into the atmosphere from the construction alteration or repaiorf a structure are prohibited Loosely containing insulation materials used in the construction alteration or repair of a structure shall be coated with a sealant provided with a cover or installed in some other manner so as to preclude exposure of the asbestos fiber to the circulating air PRODUCED PRODUCED JM PART V DEMOLITION 501 502 601 Where the risk of public exposure to asbestos fiber from the dislodging of containing insulating orfireproofing materials is present no demolition of a structure shall be initiated unless all safeguards necessary and practical to prevent the emission of visible amounts of dust are taken Such procedures shall include but are not necessarily limited to a Boilers pipes and steel members insulated or fireproofed with containing material shall be wetted and stripped before toppling of walls is begun This procedure shall be followed where practical as to all other containing insulating products Asbestos waste from such products shall be immediately bagged and - disposed of in accordance with section 203 b Eliminate this section as unnecessary c Before the demolition or toppling of any section or wall of the structure adequate wetting to suppress the dust shall be employed a d No recommended changes e No recommended changes .. No recommended changes PART VI MANUFACTURING a Emissions to the atmosphere from any factory plant or enterprise which engages in the processing or manufacturing of any containing product shall be controlled as follows 1 All direct forced gas streams containing particulate matter resulting from the manufacturing or processing of containing products shall be treated in fabric bag filter installations or where special process conditions exist in high energy wet collectors' b Visible emissions of particulate matter from any manufacturing or fabricating operations in an area directly open to the atmosphere 602 603 701 702 are prohibited Eliminate this section as unnecessary Visible emissions from waste sludge containing asbestos collected from settling ponds are prohibited during transport Such waste sludge shall be _ disposed by burial at an approved site PART VII CONTAINING PRODUCTS PJRMOD-UC83ED No product which may emit asbestos during its transportation ow shall be transported unless such product is enclosed in sucha manner as to preclude the visible emission of asbestos fiber into the ambient air Eliminate this section as unnecessary oy om