Document ypdvMD5kq0zRw5jXgpeX8KBD3

A/C Pipe Producers Association 1600 Wilson Bovfevcvd. Suit* 1308 Arlington. Virginia 22209 (703) 641-1556 February 10,1982 Mr. James F. Reis Director, Asbestos Policy Johns-Manville Corporation Ken Caryl Ranch Denver, CO 80217 Dear Jim: This is in response to your letter of January 12, 1982 regarding the activities of the Building and Construction Advisory Panel of the Asbestos International Association. It is our understanding that the Panel will use industry input to prepare a "package of positive facts" which, in turn, could form the basis of technical or promotional materials prepared by individual countries and companies. The approach of developing a nucleus of technical, economic and medical information adaptable to specific national interests or priorities will be far more productive than attempting to produce promotional materials that can be used in all countries. AACPP's experience in providing health issue literature and audio visual progra ms to its international members bears this out. Materials have maximum impact when developed specifically for or slanted towards the interests of a given national market. As successful as the "A/C Pipe and Drinking Water" audio visual program has been, we still have heard criticisms, even from North Americans, that it is too United States oriented. With those thoughts in mind, specific comments on "Positive Facts of A/C Products" follow. These comments are obviously colored by AACPP's focus on A/C pipe and should be considered accordingly. Generalities and Policy The question mark on the phrase "good quality of the A/C products" is well taken. Quite frankly, the prevailing view among customers and industry alike seems to be that A/C pipe has been sold more on its good price rather than its "good quality." Considering the world economy, the merits of selling on cost or cost-effectiveness may never be better and should be fully exploited by the Panel. If there is a major void that the Panel can fill, it is the consolidation of long term technical performance data on A/C products. Such an approach requires sound and credible technical research, preferably of an independent nature. Current data are not readily available for A/C pipe and have not been so since the mid-1960's. AACPP has underway a technical research program to provide contemporary information on A/C pipe performance and comparative product analyses. These data should be available in mid-1982. With appropriate approvals, the results could be released to the Panel. CAPCO JEN 0004778 A/C Pipe Producers Association 1' ' Mr. Jim Reis February 10,1982 Page 2 Suggested Contents Under Section 2.1, it is recommended that "economical and social significance" encompass the human element of the industry i.e. that x thousands of asbestos cement workers are provided jobs, and in turn, provide shelter products, drinking water systems, industrial development, economic ripple effects, etc. for their fellow countrymen. Technical Data Sheets and Information Page 2 - Under A/C pressure pipes, ductile iron should be added as a main competitor. AACPP does not have any publishable data on A/C pipe's estimated U.S. market share. Page 3 (A/C Pressure Pipe vs. PVC) - Under economic strong points include price, particularly in sizes up to 16" (470mm), although this has declined with reduced PVC resin prices. Also include easy installation, early determination of improper installation and low operation and maintenance cost. Under technical advantages, list resistance to cyclic fatigue and ultra-violet degradation, no restriction on applications in very cold or very hot climates. Under drawbacks, list material weight (in comparison with PVC), additional men - equipment for installation, lack of impact resistance in handling and installation, pipe lengths and more stringent bedding requirements. Frozen A/C pipelines also cannot be thawed electrically as can metallic pipes. Page 4 - AACPP cannot release annual shipping statistics for sewer and pressure pipes without Executive Committee approval. With respect to installation time, it is likely that this is a range of values dependent on number of workers in the installation crew, laying equipment, soil conditions, excavation requirements, bedding requirements, etc. Perhaps Member Company installation specialists can provide typical values. OSHA's RTI report claims that a three to four person work crew can install an average of 222.5 feet of A/C pipe per day. We have seen articles documenting rates as high as 5,000 feet per day. * Page 5 - According to the RTI report, about 17,000 hours may be spent annually on cutting and machining operations. This is 59,000 man hours of exposure or 0.53 percent of total work hours. If those operations are conducted in accordance with industry recommended work practices, the hypothetical "hours with health risk" would be zero since none of those operations exceed, individually or collectively, ceiling or TWA exposure standards. The information on pages 6 through 21 is of such a general and country specific nature that its value for anything other than reference is questionable. For example, lined A/C pipe appears to be used for gas pipelines in France. No such use exists in the U.S. Most of this information e.g. number of plants and employees, asbestos content of product, pollution abatement measures, energy consumption, and physical and chemical properties is already common knowledge. One must question the value of providing such information for the sole purpose of having the Panel assemble it and return it to United i CAPCO JEN 0004779 r A/C Pipe Producers Association Mr. Jim Reis February 10,1982 Page 2 States A/C pipe manufacturers in a different form. From the U.S. perspective, it is doubtful that this information has any sales or marketing value anyway. Asbestos and Health ? As a rudimentary source of information, this section probably would suffice, notwithstanding its negative approach. The health issue has long been the object of inter-country and intra-country educational/promotional efforts. This document does little to advance the state-of-the-art. If the panel proceeds with this section, it is recommended that a more comprehensive and cohesive paper be prepared. Topics might include the following:, regulations germane to fixed and non-fixed (construction) work sites, exposures during manufacturing and installation, environmental exposures (e.g. from weathering of sheets, corrosion of A/C pipe), industry-recommended work practices, etc. Each section could include an expanded . introduction and a bibliography of important scientific studies (pro and con) relative to the topic discussed. The section on the ingestion of asbestos in drinking water appears to have been extracted in large measure from the "A/C Pipe and Drinking Water" booklet. In selectively using the booklet, the authors have destroyed any semblance of continuity. This should be corrected by careful editing. It is recommended that the section on the Aggressive Index (AI) be deleted. The'AI never was developed to "predict" asbestos fiber release and the industry itself may have perpetrated this misperception by placing it in the "A/C Pipe and Drinking Water" booklet. Also, recent studies by the U.S. Environmental Protection Agency (Schock and Buelow, The Behavior of Asbestos Cement Pipe Under Various Water Quality Conditions: Part 2, Theoretical Considerations, J. AWWA, December, 1981) state the AI " ... has generally proved to predict falsely pipe deterioration more often than to predict falsely pipe stability in field situations." By deleting reference to the AI, the industry avoids the suggestion that corrosion indices can be used as acceptability criteria for product use or quantitative predictors of asbestos fiber release. Und,er "animal experiences (sic)" add the following: 1. The Summary Minutes of the National Toxicology Board of Scientific Counselors' Peer Review of the Carcinogenesis Bioassay of Asbestos Fed to Syrian Golden Hamsters. The conclusions state: "Under the conditions of the bioassay, the ingestion of short range (S.R.) and intermediate range (I.R.) chrysotile asbestos was not carcinogenic in male and female Syrian golden hamsters." Similar conclusions were drawn with respect to amosite. 2. Hilding, et al, "Biological Effects of Ingested Amosite Asbestos, Taconite Tailings, Diatomaeeous Earth and Lake Superior Water in Rats," Archives of Environmental Health. 36:298-303 (November - December) 1981. i CAPCO JEN 0004780 A@ A/C Pipe Producers Association Mr. Jim Reis February 10,1982 Page 4 3. Bolton, et al, "The Pathological Effects of Prolonged Asbestos Exposure in Rats," Environmental Research (in press). The epidemiologic evidence on ingestion of asbestos should acknowledge the existence of the Kanarek study and emphasize its scientific shortcomings. The comments of EPA, California Department of Health Services, and Ian T. T. Higgins, M.D., are germane. In addition to these comments, also enclosed are the following information materials: 1. Promotional literature - "A/C America's Choice" 2. Exposure data - "Asbestos Exposures During the Cutting and Machining of A/C Pipe" (two volumes). If we can be of further assistance in this effort, please do not hesitate to call. Very truly yours, JFW/ajb Enclosure cc: A. Kahn, Esq. N. Rahn, Esq. Public Affairs Committee International Affairs Committee John F. Welch Vice President A030E20901 Chrono i. CAPCO JEN 0004781 121:0466 FEDERAL REGULATIONS (1} Adopting and enforcing any emis cluding commercial asbestos, and the but not limited to, highways, roads, sion limiting regulation applicable to a processing of this combination into a streets, parking areas, and driveway*.- stationary source, provided that such productasspedfied.ln i 61.22(c). (w) "Asbestos-containing waste mate emission limiting regulation Is'not less stringent than the standards prescribed under this part '(2) Requiring the owner or operator of a stationary source, other than a sta tionary source owned or operated by the .United States, to obtain permits, licenses, or approvals prior to Initiating construc (j) "Demolition" means the wrecking or taking out of any load-supporting struc tural member and any related removing or stripping of friable asbestos materials. (k) "Friable ashestos material" means any material that contains more than-i percent asbestos by weight and that cad be crumbled, pulverized, or reduced to powder, when dry, by hand pressure. rial" means any waste which contain*, commercial asbestos and Is generatec L a source subject to the provisions of uus subpart, Including asbestos mill tailings, control' device asbestos waste, friable as bestos waste material, and bags or con tainers that previously contained com mercial asbestos. [40 FR 48292, October 14, 19751 tion, modification, or operation of such (l) "Control device asbestos waste" (x) "Structural member" means any source. means any asbestos-containing watte load-supporting member, such as beams (Sec. Ilf of the Clean Air Act as amended (42 U.S.C. 7414.) 6 61.17 Circumvention. . No owner or operator'subject to the provisions of this part shall build, erect. Install, or use any article.' machine, equipment, proaess, or method, the use of Which conceals an emission which.would otherwise constitutor* violation of an applicable standard. Such, concealment Includes, but Is not limited to, the use of gaseous dilutants to .achieve compliance with a visible emissions standard, and the piecemeal carrying out of. an opera tion to avoid coverage by a standard that applies only to operations larger Jthaa a specified size. (40 FR 48292, October 14,1975] Subpart 8--NationalEmission Standard for Asbestos 61,20 Applicability. The provisions of this subpart are ap material that- Is collected In a pollution control device. <m) "Renovation" means the remov ing or stripping of friable asbestos ma terials used on any pipe, duct, boiler, table, reactor, turbine, furnace,, or structural member. Operations in which load-supporting structural members are wrecked or taken out are excluded. |Pira|raj>h (m) revised by 43 FR 26373, June (n) "Planned renovation" means * renovation' operation, or a number of such operations, In which the amount of friable asbestos material that will be removed or stripped within a given pe riod of time can be predicted. Operations that are Individually non-scheduled.are Included, provldeda number of such op erations can be predicted to occur during a given period of time based on operating experience. (o) "Emergency renovation" means a and load-supporting walls; or any nonload-supporting member, such as ceilings and non-load-supporting walls. [42 FR 12127, March 2, 1977J j 61.22 Emission standard. (a) Asbestos mills: There shall be so visible emissions to the outside air from any asbestos- mill except as provided In paragraph (f) of test) section.' [39 FR 15936, May 3, 1974] (b) Roadways; The surfacing of* road ways with asbestos tailings or with asbes tos-containing waste that is generated by any source subject to paragraphs (c), (d), (e) or (h). of-tbts section-is- prohibited, cxcapt-fbr temporary roadways.owtrtFBrea of asbettoe-ore depeetts. The deposition of asbestos tailings or asbestos-containing waste on roadways covered with snow or ice is considered "surfacing." plicable to those sources specified In i 61.22. renovation operation that results from a (c> Manufacturing: There shall be no sudden, unexpected event, and la not a visible emissions to toe outside air, es/ S 61.21 Definition!. Terms used In this subpart are defined In the act. In subpart A of this part, or In this section as follows: (a) "Asbestos" means actinollte. amo- site, anthophylllte. chiysotile, crocidolite, tremolite. <b> "Asbestos material" means as bestos or any material containing as bestos. <c) "Particulate asbestos material" means finely divided particles of asbestos material. <d> "Asbestos tailings" means any solid waste product of asbestos mining or milling operations which contains as bestos. <e) "Outside air" means the air out side buildings and structures. * planned renovation. Operations necessi cept as provided In paragraph (f) of tola tated by. non-routine failures of equip section, from any of the following op ment are Included. erations If they use commercial asbestos (p) "Adequately wetted" means suf or from any building or. structure In ficiently mixed or coated with water or which such operations are conducted. an aqueous solution to prevent. dust [40 FR 48292. October 14, 1975| emissions. (q) "Removing" tpeans. taking out friable asbestos materials used on any pipe, duct, boiler, tank, reactor, tur bine, furnace, or structural member from any building, structure, facility, (I) The manufacture of doth, com. wicks, tubing, tape, twine, rope, thread, yarn, roving, lap, or other textile ma terials. , (2) The manufacture of cement prod ucts. or Installation. (r) "Stripping" means taking off fri able asbestos materials from any pipe, duct, boiler, tank, reactor, turbine, fur nace, or structural member. [Paragraph (q) and (r) revised by 43 FR 26373, (3) The manufacture of fireproofing and insulating materials. - (4) The manufacture of friction products. (5) The manufacture of paper, millboard, and felt. June 19,1978] (6) The manufacture of floor tile. (f) "Visible emissions" means any (s) "Fabricating", means any process (7) The manufacture of paints, coat emissions which are visually detectable ing of a manufactured product contain ings, caulks, adhesives, sealants. without the aid of Instruments and which ing commercial asbestos, with the ex (8) The manufacture of plastics and contain particulate asbestos material. ception of processing at temporary sites rubber materials. (g) "Asbestos mill" means any facility engaged in. the conversion or any Inter mediate step in the conversion of asbestos ore Into commercial asbestos. Outside storage of asbestos materials Is not con sidered a part of such facility. <h) "Commercial asbestos" means any variety of asbestos which Is produced by extracting asbestos from asbestos ore. (1) "Manufacturing" means the com bining of commercial asbestos, or In the case of woven friction products the com bining of textiles containing commercial asbestos, with any other matjgjaKs), In for -the construction or restoration of (9) The manufacture of chlorine. buildings, structures, facilities or Instal (10) The manufacture of shotgun lations. shells. (t) "Inactive waste disposal site" (II) The manufacture of asphalt con means any disposal site or portion crete. thereof where additional asbestos-con taining waste material will not be depos (d) Demolition and renovation. The ited* and where the surface Is not dis requirements of this paragraph shall turbed by vehicular traffic. apply;,.to* any. owner'or operated;,of. & (u) "Active waste disposal site" means demolition or renovation, .operation any disposal site other than an inactive who Intends to demolish any Institu site. tional, commercial, or Industrial buildj. (v) "Roadways" means surfaces on lng (including apartment bulldlnfcl which motor vehicles travel Including, having more than four dwelling units).'- Environmant Reporter [Sec. 61.22(d)] 126 1 CAPCO JEN 0004782 HAZARDOUS EMISSIONS S-580 121:0487 structure, facility. Installation, or por (vil) Procedures to be employed to paragraph as units or in sections pro tion thereof which contains any pipe, meet the requirements of this paragraph vided the friable asbestos materials ex duct, boiler, tank, reactor, turbine, fur and paragraph (1) of this section. posed during cutting or disjoining are nace, or structural member that is cov .(viii) The name and address or loca adequately wetted during the cutting ered. or coated .with' friable asbestoa tion of the waste disposal site where the or disjoining operation. Such units materials, except as provided in para friable asbestos waste will be deposited. shall not be dropped or thrown to the graph (dXl) of this section: or who In (lx) Name, title, and authority of the ground, but shall be carefully lowered tends to renovate any institutional, State or local governmental representa to ground level. commercial, or Industrial building, tive who has ordered a demolition which (iv) The stripping of friable asbestos structure, facility, installation, or por is subject to paragraph (d)(6) of this materials used on any pipe, duct, tion' thereof where more than 80 meters (ca. 260 feet) of pipe covered or coated, with friable asbestos materials are stripped or removed, or more than 15 square meters, tea. 160 square feet) of friable asbestos materials used to cover or coat any duct, boiler, tank, re actor, turbine, furnace, or structural member are stripped or removed, <1> (1) The owner .or operator of a demolition operation Is exempted from the requirements of this paragraph: Provided, (A) The amount of friable asbestos materials In the building or portion thereof to be demolished Is less than 80 meters (ca. 260 feet) used on pipes, and less than 15 square meters (ca. 160 square feet) used on any duct, boiler, tank, reactor, turbine, section. (3) (1) For purposes of determining whether a planned renovating operationconsUtutes a renovation within the meaning of this paragraph, the amount of friable asbestos material to-be re moved or stripped shall be: (A) For planned renovating opera tions involving Individually non-scheduled operations, the additive amount of friable asbestosmaterial that can be pre dicted will be removed or stripped at a source over the maximum, period of time for which a prediction can be made. The period shall be not less than 30 days and not longer than one year. (B) For each planned renovating op eration not covered by paragraph (d) (3) (1) (A), the total amount of friable as bestos material that can be predicted boiler, tank, reactor, turbine, furnace, or structural member that has been jremoved as a unit or in sections as pro vided In paragraph (dX4Xill) of this section.shall be performed In accord ance with paragraph <dX4Xii) of this section. Rather than comply with the wetting requirement, a local exhaust ventilation and collection system may be used to prevent emissions to the outside air. Such local exhaust ventila tion systems shall be designed and op erated to capture the asbestos particu late matter'produced by the stripping of friable asbestos materials.1 There shall- be-, no. .visible emissions to the outside air from such local exhaust ventilation and collection' systems gxcgpt as provided in paragraph (f> o1 furnace, or structural member, and (B) will be removed or stripped at a source. this section. the notification requirements of para (li> For purposes of- determining I^OMiv) revised by 43 FR 26374, June 19, graph (dXIXii) are met. whether an emergency renovating op (11) Written notification shall be eration constitutes a renovation within (v) All friable asbestos materials that postmarked or delivered to the Admin the meaning of this paragraph, the have been removed or stripped shall be istrator at least 20 days prior to com amount of friable asbestos material to adequately wetted to ensure that sucb mencement of demolition and shall In be removed or stripped shall be the total materials remain wet during all remain clude the Information required by amount of friable asbestos material that ing stages of demolition or renovation paragraph (d)(2) of this section, with will be removed or stripped as a result and related handling operations. Sucb the exception of the information re- of the sudden, unexpected event that materials shall not be dropped or thrown - qutred by paragraphs (d)(2) (Hi), (vi), necessitated The renovation. to the ground or a lower floor. Such ma (vtl), (viii), and (lx) of this section, and (4) The following procedures shall be shall state the measured or estimated amount of friable asbestos materials used to prevent emissions of particulate asbestos material to outside air: which is present. Techniques,of estl- (1) Friable asbestos: materials, used matlon.shall be explained. on any pipe, duct, boiler, tank, reactor, |Pan|raj>h (d) revised by 43 FR 26374, June turbine;- furnace, or structural member, shall -be removed from any terials that have been removed or stripped more than 50 feet above ground level, except tliose materials re moved as units or in sections, shall be transported to the ground via dust-tight chutes or containers. (vl) Except as specified below, the wet (2) Written notice of intention to de- building, structure, facility or installsmolish or renovate shall be provided to tlon. subject to this paragraph. Such ting requirements of this paragraph an suspended when the temperature at the the Administrator by the owner or opera removal shall occur before wrecking or tor of the demolition or renovation oper dismantling of any portion of such ation, Such notice shall be postmarked building, structure, facility, or installa or jdelivered to the Administrator at least tion that would break up the friable 10 days prior to commencement of demo asbestos materials and before wreck lition. or as early as possible prior to ing or dismantling of any other, por point of wetting is below 0*C (32"F) When friable asbestos materials are not wetted due to freesing temperaiurw,such materials on pipe*, duet*, boiler* tanks, reactors, turbines,'furnaces, or structural members shall, to the maxiarum extent commencement of emergency demolition tion of- such building, structure, facili- possible, be removed as nnit*-er hr sec subject to paragraph (d) (6) of this sec ty,.or installation,.that would preclude tions prior to wrecking. In no case shall tion, and as early as possible prior to .access to such, materials, for subse the requirements of paragraphs (d> (4) commencement of renovation. Such no quent-removal. Removal of friable as (Iv) or (d> (4) (v) be suspended due tc tice shall Include the following informa bestos materials used on- any pipe; freezing temperatures. tion: duct, or structural member which are (vli) For renovation operaUonsTlocal (I) Name of owner or operator. encased in concrete or other similar exhaust ventilation and collection sys (II) Address of owner or operator. (lu) .Description of the building, structural material-is not required Prior, to demolition, but such.materials tems may be used. Instead of wettlng-as specified in paragraph (d> (4) i>, to pre structure, facility, or Installation to be demolished., or renovated, including th,e_*sixe. .age, and prior use of the structure, .. and the approximate amount of. friable asbestos materials present. (Paragraph (iii) revised by 43 FR 26374, June 19.1978J <iv> Address or location of the build ing. structure, facility, or installation. (v) Scheduled starting and comple tion dates of demolition or renovation. shall be adequately wetted whenever exposed during demolition. (11). Friable asbestos materials, used on pipes, ducts, boilers, tanks, reac tors, turbines, furnaces, or structural members shall be adequately wetted during stripping, except as provided.in paragraphs (d)(4)(lv),' (d)(4Xvi>, or (dXvii) of this section. vent emissions of particulate -asbestos material to outside air when damage tc equipment resulting from the wetting would be unavoidable. Upon request and supply of adequate Information, the Ad ministrator will determine whether dam age to equipment resulting from wetting to comply with the provisions of this par agraph would be unavoidable. Such local exhaust ventilation systems shall be de (iii) Pipes, ducts, boilers, tanks, reac signed and operated to capture the asbes tors, turbines, furnaces, or structural tos particulate matter produced by th< members that are covered or coated stripping and removal of triable asbesto: (vi) Nature of planned demolition or with friable asbestos materials may be material. There shall be no visible emis renovation and method(s) to be em ployed. taken out of any building, structure, sions to the outside air from such local facility, or Installation subject to this exhaust ventilation and cohfctton sys- 12-4-81 ISk. 61J2Id)(4)WU Published by TilE BUREAU OF NATIONAL AFFAIRS, INC.. WASHINGTON, D.C. 20037 4: 1 CAPCO JEN 0004783 121:0463 FEDERAL REGULATIONS terns, except as provided In paragraph fore such emissions escape to, or are waste disposal sites which are operated (f) of this section. vented to.'the oufsldt air. in accordance with the provisions of (5) Sources subject to this paragraph <g) Where the presence oriincomblned i 41.25. are exempt from the requirements of water Is- the sole reason for failure to (C) The containers specified under {3 81.05(a).61.07,and61.09. . qteet tfie no-.v4efMe 'gmleelna require paragraph (J)<3>(1>(B> of this section (6) The demolition ot a building, struc ment el paragraphs (>, (c), (d), (e), ture, facility, or Installation, pursuant to (h), (J). or (k) of this section, such fail an' order ot an authorized representative ure shall not be a violation of such emis ot a State or local governmental agency. sion requirements. Issued because that building Is structur (h) Fabricating: There shall be no ally unsound and In danger ot Imminent visible emissions to the outside air, ex collapse Is exempt from all but the tol-. cept as provided In paragraph (f> of this lowing requirements ot paragraph (d) of section, from any of the following op this section: <I) The notification requirements spec erations if they use commercial asbestos or from any building or structure In ified by paragraph (d> (2) of this section: which such operations are conducted. (II) The requirements on stripping of (1) The fabrication of ceihent building friable asbestos materials from previously products. removed units or sections as specified In (2) The fabrication of friction prod paragraph (d) (4) (lv) of this section: ucts, except those operations that pri (III) The wetting, as specified by para marily Install asbestos friction materials graph (d> (4> (v> of this section, of fri on motor vehicles. able asbestos materials that have been removed or stripped; <iv> The portion of the structure being demolished that contains friable asbes tos materials shall be adequately wetted during the wrecking operation. (3) The fabrication of cement or sili cate board for ventilation hoods; ovens; electrical panels; laboratory furniture; bulkheads, partitions and ceilings for marine construction; and flow control devices for the molten metal Industry. [39 FR 15936, May 3. 1974: 40 FR 48292, (1) Insulating: Molded Insulating ma October 14, '975| terials which are friable and wet-applied <e) Spraying. There shall be no visi Insulating materials which are friable ble emissions to'the outside air from after drying, installed after the effective the spray-on application of materials date of these regulations, shall contain containing more than 1 percent asbes no commercial asbestos. The provisions shall be labeled with a warning label that states: Csoisow Contains Asbestos Avoid Opening or Breaking Container Breatblng Asbestos Is Basardous to Tour Health Alternatively, warning labels specified by Occupational Safety and Health Standards of the Department of Labor, Occupational Safety and Health Admin istration (OSHA) under 29 CFR 1910.93a(g) (2) (11) may be used. (11) Processing of asbestos-containing waste material Into non-frlable forms: (A) All asbestos-containing waste material shall be formed Into non-frlable pellets or other shapes and deposited at waste disposal sites which are operated in accordance with the 'provisions of 3 61.25. (B> There shall be no visible emis sions to the outside air from the collec tion and processing of asbestoscontaining waste material except as specified in paragraph (f> of this section. (4) For the purposes of this para graph (j), the term all asbestos-con taining waste material as applied to tos, on a dry weight basis, used on of this paragraph do not apply to Insu demolition and renovation operations equipment and machinery, except as lating materials which are spray applied; covered by paragraph (d) of this sec provided in paragraph (f) of this sec such materials are regulated under tion Includes only friable asbestos waste tion. Materials sprayed on buildings, { 61.22(e). and control device asbestos waste. structures, structural members, pipes, (j) Waste disposal for manufacturing, (k) Waste disposal for asbestos mills: and conduits shall contain less than 1 fabricating, demolition, renovation and The owner or operator of any source percent asbestos on a dry weight basis. spraying operations: The owner or op covered under the provisions of para [Paragraph (e) revised by 43 FR 26374, June 19,1978) (1) Sources subject to this paragraph are exempt from the requirements of erator of any source covered under the provisions of paragraphs (c), (d), (e>, or (h) of this section shall meet the fol lowing standards: (1) There shall be no visible emissions 3 61.05(a), { 61.07,and! <1.09. to the outside air, except as provided In (2) Any owner or operator who In paragraph (J>(3) of this section, dur tends to spray asbestos materials ing the collection; processing, including graph (a) of this section shall meet the following standard: (l) There shall be no visible emis sions to the outside air. except as pro vided In paragraph (k> (3) of this section, during the collection, processing, pack/ aging, transporting or deposition of any asbestos-containing waste mate which contain more.than 1 percent as Incineration; packaging; transporting; rial which Is generated by such source. bestos on a dry weight basis on equip or deposition of any asbestos-containing (2) All asbestos-containing waste ma ment and machinery shall report such waste material which is generated by terial shall be deposited at waste intention to the Administrator at least such source. disposal sites which are operated In ac 29 days prior to the commencement of (2) All asbestos-containing waste ma cordance with the provisions of 161.25. the spraying operation. Such report terial shall be deposited at waste dis (3) Rather than meet the requirement shall Include the- following Informa posal sites which are operated In accord of paragraph (k) (1) of this section, an tion:<1> Name of owner or operator. ance with the provisions ot 3 61.25. owner or operator may elect to meet (3) Rather than meet the requirement the following requirements in para <il) Address of owner or operator. (Ill) Location of spraying operation, (lv) Procedures to be followed to meet the requirements of this paragraph. (3) The spray-on application of ma terials in which the asbestos fibers are encapsulated with a bituminous or re of paragraph (J) (1) of this section, an owner or operator may elect to use either of the disposal methods specified under (j) (3) (1) and (li) of this section, or an alternative disposal method which has received prior approval by the Ad ministrator: (1) Treatment of asbestos-containing graphs (k>(3> (1) and (11), or use an alternative disposal method which has received prior approval by the Admin istrator: (1) There shall be no visible emissions to the outside air from the transfer of control device asbestos waste to the tailings conveyor, except as provided In sinous binder , during spraying and waste material with water: paragraph It) of this section. Such waste which are not-friable after drying. Is (A) Control device asbestos waste shall shall be subsequently processed either exempted from the requirements of be thoroughly mixed with water Into a as specified In paragraph (k) (3) (li) of paragraphs (e> and (e)(2) of .this sec slurry and other asbestos-containing this section or as specified in paragraph tion. waste material shall be adequately 0X3) of this section. [Paragraphs (2) and (3) revised by 43 FR wetted: There shall be no visible emis (ii) All asbestos-containing waste 26374. June 19, 1978] sions to the outside air from the collec material shall be adequately mixed, with <f> -Rather than meet the no-vlslble- tion, mixing and wetting operations, ex a wetting agent recommended by the emission reanlretneats as specified by cept as provided In paragraph (f) of this manufacturer of the agent to effectively paragraphs (a?, <c>, (d>. (e), (h), (J), section. wet dust and tailings, prior to deposition and (k) of this section, an owner or op (B) After wetting, all asbestos-con at a waste disposal site. Such agent ,v,-n erator,may elect to use the methods spec taining waste material shall be sealed be used as recommended for the partic ified by 3 Sl.23 to dean emissions con Into leak-tight containers while wet, and ular dust by the manufacturer of the taining particulate asbestos mateftSl be such containers shall be deposited at agent. There shall be no discharge of Environment Reporter (Sec. 61.22(k)(3)(ii)] 44 CAPCO JEN 0004-784 ' HAZARDOUS EMISSIONS 121:0469 visible emissions to the outside the vetting operation except as specified 5paragraph(t) of this section. Wetting (5) Rather than meet the requirement of paragraph (1) (I) of this section, an owner, may elect to meet the require installed, used, operated, and maintained. Bypass devices may be used only during upset or emergency conditions and then may be suspended when the ambient ments of this paragraph or may uss an. oniy for so long as It take* to shut down temperature at the waste disposal site to alternative control method for emissions tho operation generating the particulate tea than -9.5*C (ca. 15*F). The ambient from inactive waste disposal sites which asbestos material. .. air temperature shall be determined by has received prior approval by the 9 61.24 Reporting. an appropriate measurement method with an accuracy of 1`C (2*F> and recorded at least at hourly Intervals dim ing the period that the operation of the wetting system Is suspended. Records of such temperature measurements shall be retained at the source for a minimum of two years and made available for Inspec tion by the Administrator. (1) The owner of any Inactive waste disposal site, which was operated by sources covered under } 61.22 (a), (c> or (h) and where asbestos-containing waste material produced by such sources wasi deposited, shall meet the following, standards: (1) There shall be no visible emissions' to the outside air from an Inactive waste disposal site subject to this paragraph, except as provided In paragraph (1) <S> hdhtfrits&ator. Thee asbescos-conUIntng waste material shall be covered with at least 49 centimeters.(ca. 6-inches) of com- jSheted Mb-asbestos-containlng materi!fl, and a cover of vegetation shall be grown and maintained on the area ade quate to prevent exposure of the asbes tos-containing waste material; or '(11) The asbestos-containing waste material shall be covered with at least 69 centimeters (ca. 2 feet) of compacted non-asbestos-contalnlng material and maintained to prevent exposure of the flaeosur(b-1mea11-ssb)btoaeFsss-teoocdrsodnItnautaaisliicntnstiignuvgspe,pwiWrteaHrsse5stEseio5i:nnodoauirsgspeoonsrtapwlehstiirtceohsl .,I11 effectively binds dust and controls wind erosion shall be applied. Such agent shall The owner or operator of any existing source to which this subpart to applicable shall, within 90 days after the effective date, provide the following Information to the administrator: (a) A description of the emission con trol equipment used for each process; (b) If a fabric filter device to used to control emissions, the pressure drop across the fabric filter In inches water gage. (1) If the fabric filter device utilizes a woven fabric, the airflow permeability In ftVmin/ft'; and. If the fabric to synthetlc, indicate whether the fill yam to spun or not spun. (2) If the fabric filter device utilizes a felted fabric, the density In oz/yd*. the minimum thickness In Inches, and the airflow permeability In J't*/mln/ft'. of this section. be used as recommended for the partic (2) Warning signs shall be displayed ular asbestos tailings by the dost sup at all entrances, and along the property pression agent manufacturer.- Other line of the site or along the perimeter of equally effective dust suppression agents the sections of the site where asbestos- may be used upon prior "approval by the containing waste material was deposited, Administrator. For purposes of this para (c) For' souttds subject to { 6l.22(j) and 61-22(fcf: (1) A brief-description of each process hat generates asbestos-containing waste naterlal. at Intervals of 100 m (ca. 330 ft) or less, graph, waste crankcase oil to not con .(2) The average weight of asbestos- except as specified In paragraph (1) (4) sidered a dust suppression agent. containing waste material disposed of, of this section. Signs shall be posted in |40 FR 48292, October 14. 1975| measured In kg/day. such a manner and location that a person may easily read the legend. The warning signs required by this paragraph shall 61.23^ Air-deaning. If'htMteanlng Is elected, as permitted (3) The emission- control methodsused In aQ stages of waste disposal. conform to the requirements of 20" x 14" by ;$6&32(f> and 61.22(d) (4) (lv), tbft (4) The type of disposal site or Incin upright format signs specified In 29 CFR 'requirements of this section must be met. 1610.145(d) (4) and this paragraph. The (40 FR 48292, October 14. 19751 signs shall display the following legend in the lower panel, with letter sizes and (a) Fabric filter collection devices eration site used for ultimate disposal, the name of the site operator, and the game and location of the dlspos-* site. (d) '4tor sources subject to S ( 22(1): styles of a visibility at least equal to those mdat be used, exoept as noted In para (I) A brief description of the site. specified In this paragraph. graphs .(b) and (c). of this section. Suchdevices must be operated at a pressure, 13) The method or methods used to dropof no more than 4Inchee water,gage, comply with the standard, or alternative Asbestos Waste Disposal Site aa measured, across the filter fabric. The prooe^ires to be used. Do Not Create Dust Breathing Asbestos Is Bjoardous toTourEeslth Notation 1" Sans Serif, Gothic or Block airflow permeability, as determined hr; AsyM metnod'D737^6S, must not exceed (e> Such Information shall "accom pany the Information required by i 61.10. 30 ft'/mln/ft' for woven fabrics or 35 ftymin/ft* lor felted fabrics, except that 40 ftymin/ft' for woven and 45 ft*/ mln/lt'.lor felted fabrics to allowed for The information described in this section, shall be reported using the format of Appen* dix A of thu part. ; (40 FR 48292. October 14, 19751 ' filtering air from asbestos ore dryers. 94'* Sane Serif, Gothic or Block Each square yard 6f felted fabric must 14 Point Gothic weigh at least 14 ounces and be at least 6125 Waste disposal sites. Spacing between lines shall be at least equal to the height of the upper of the two lines. (3) The perimeter of the site shall be fenced in a manner adequate to deter access by the general public, except as specified In paragraph (1X4) of this section. (4) Warning signs and fencing are not required where the requirements of, paragraphs (1) (5) (1) or (11) of this sec tion are met, or where a natural barrier adequately deters access by the general public. Upon request and supply of ap propriate Information, the Adminis trator will determine whether a fence or a natural barrier adequately deters ac cess to the general public. one-sixteenth Inch thick throughout.; Synthetic fabrics must not contain fill yam other than that which Is spun. (b) If the use of fabric filters creates a fire or explosion hazard, the adminls-trator may authorize the use of wet col lectors designed to operate with a unit contacting energy of at least 40 inches: water gage pressure. (c) The administrator may authorize the use of filtering equipment other than that described In paragraphs (a) and (b) of this section If the owner or operator demonstrates to the satisfaction of theadministrator that the filtering of par ticulate asbestos material Is equivalent tq_that of the described equipment. (d> All air-cleaning equipment au thorized by this section must be properly . Jfl.<>r4er to be an acceptable site for disposal ..ot asbestos-containing waste giatris&'under 6122 (J) and (k), an activowaste disposal site shall meet the requirements of this section. ,(aT niere Shall be no visible emtoitaM 26 tiie'6utsiao air from any active waste? disposal site where aibsstoe' contetntsg waste material has been deposited, smeefit aa provided. In paragraph (e)' Of this ' section. (b) Warning signs shall be displayed at all entrances, and along the property line of the site or along the perimeter of the sections of the site where asbestoscontaining waste material to deposited, at intervals of 100 m (ca. 330 ft) or less except as specified In paragraph (d> of this section. Signs shallbe posted in such M-4-61 [Se. 6125(b)! PJfflshcd by THE BUREAU OE NATIONAL AFFAIRS. INC. WASHINGTON, D.C 2003-7 1 CAPCO JEN 0004-785 721:0470 FEDERAL REGULATIONS a manner and location that a person may agent- manufacturer-'Other.eq'ualty'ef- easily read the legend. The warning fective dust suppression agShts may be signs required by this paragraph shall used upon priorapproval by the Admln- conform to the requirements of 20"it 14'" "IsWator. For purposes of this paragraph, upright format signs specified In 29 CFR wast* crankcase oil is' not considered a 1910.145(d) (4) and this paragraph. The dustsuppresslon agent. signs shall display tile following legend in the lower panel, with letter sizes and styles of a visibility at least equal to those specified in this paragraph. (40 t'R 48292. October 14. 1975J (Sec. 114 of the Clean Air Act as amended (42 U.S.C. 7414)) LECEND Subpart C--National Emission Standard for Beryllium AssrsTos Waste Dcsfosae Sett 61.30 Applicability. Do Not Create Dust Breathing Asbestos is Hazardous to Your Health The provisions of this subpart are ap plicable to the following stationary sources: Notation 1" Sans Serif, Gothic or Block 11" Sans Serif, Gothic or Block 14 Point Gothic Spacing between lines shall be at least equal to the height of the upper of the two lines. <c) The perimeter of the disposal site shall be fenced in order to adequately deter access to the general public except as specified in paragraph (d) of this section ed) Warning signs and fencing are not required where the requirements of paragraph (e)(1) of this section arc met, or where n natural barrier ade quately deters access to the general public. Upon request and supply of ap propriate information, the Administra tor will determine whether a fence or a natural barrier adequately deters access to the general public. (e) Rather than meet the require ment of paragraph (aj of this section,an owner or operator may elect to meet the requirements of paragraph (e) (1) or (e) (21 of this section, or may use an al ternative control method for emissions from active waste disposal sites which has received prior approval by the Administrator. (1) At the end of each operating day. or at least once every 24-hour period while the site is in continuous operation, the asbestos-containing waste material which was deposited at the site during the operating day or previous 24-hour period shall be covered with at least IS centimeters (ca. 6 inches) of compacted non-asbestos-containing material. (2) At the end'of each operating day. or at least once every- 24-hour period while tire disposal site is In'continuous operation, the asbestos-containing waste (a) Extraction plans, ceramic plants, foundries, Incinerators, and propellant plants which process beryllium ore, beryl lium. beryllium oxide, beryllium alloys, or beryllium-containing waste. (b> Machine shops which process beryllium, beryllium oxides, or any alloy when such alloy contains more than S percent beryllium by weight. 61.31 Definitions. Terms used In this subpart are de fined in the act, in subpart A of this part, or in tills section as follows: (a) "Beryllium" means the element beryllium. Where weights or concentra tions are specified, such weights or con centrations apply to beryllium only, excluding the weight or concentration of any associated elements. (b) "Extraction plant" means a fa cility chemically processing beryllium ore to beryllium metal, alloy, or oxide, or performing any of the intermediate steps in these processes. (c) "Beryllium ore" means any natu rally occurring material mined or gathered for its beryllium content. (d) "Machine shop" means a facility performing cutting, grinding, turning, honing, milling, deburring. lapping, electrochemical machining, etching, or other similar operations. te> "Ceramic plant" means a manu facturing plant producing ceramic items. (f) "Foundry" means a facility en gaged in the melting or casting of beryllium metal or alloy. (g) "Beryllium-containing waste" means material contaminated with beryllium and'or beryllium compounds used or generated during any process or operation performed by a source subject to this subpart. (h> "Incinerator" means any furnace material which was deposited artne site during the operating day or previous 24hour period shall be covered with a res-; inous or petroleum-based dust suppres-. sion agent which effectively Binds dust and controls wind erosion. Such agent shall be used as recommended for the particular dust by the dust suppression used in the process of burning waste for the primary purpose of reducing the volume of the waste by removing com bustible matter. (i> "Propellant" means a fuel and oxi dizer physically or chemically combined which undergoes combustion to provide rocket propulsion. (]) "Beryllium alloy" means any metal to which beryllium has been added In order to Increase Its beryllium content and which contains more than 0.1 per cent beryllium by weight. (k) "Propellant plant" means any facility engaged In the mixing, casting, or machining of propellant. 61.32 Emission standard, (a) Emissions to the atmosphere from stationary sources subject to the provi sions of this subpart shall not exceed 10 grams of beryllium over a 24-hour period, except as provided in paragraph (b) of this section. (b) Rather than meet the require ment of paragraph (a) of this section, an owner or operator may request ap proval from the Administrator to meet an ambient concentration limit on beryl lium in the vicinity of the stationary source of 0.01 pg/m', averaged over a 30-day period. (1) Approval of such requests may be granted by the Administrator provided that: (1) At least 3 years of data Is avail able which in the judgment of the Ad ministrator demonstrates that the fu ture ambient concentrations of beryllium in the vicinity of the stationary source will not exceed 0.01 pg/m', averaged over a 30-day period. Such 3-year period shall be the 3 years ending 30 days before the effective date of this standard. (ii) The owner or operator requests such approval in writing within 30 days after the effective date of this standard. (ill) The owner or operator submits a report to the Administrator within 45 days after the effective date of this standard which report includes the fol lowing information: (a) Description of sampling method including the method and frequency of calibration. (b) Method of sample analysis. (c) Averaging technique for determin ing 30-day average concentrations. (d) Number, identity, and location (address, coordinates, or distance and heading from plant) of sampling sites. (e) Ground elevations and height above ground of sampling inlets. (/) Plant and sampling area plots showing emission points and sampling sites. Topographic features significantly affecting dispersion including plant building heights and locations shsll be Included. ip) Information necessary for esti mating dispersion Including stack height, inside diameter, exit gas temperature, exit velocity or flow rate, and beryllium concentration. th) A description of data and proce dures (methods or models) used to de- Environment RepOffer ISec. 61.32(h)) 46 CAPCO JEN 0004.786