Document zdZzyO5qRgymGek9G45QkDvq3
<82672 . ; Federal. Register./ Vol. 5i. No; 119 /. Friday, June .20,. 1986 /. Rules and Regulations
opportunity for its release into the
insulation materials, 9 and during
atmosphere can occur at numerous
disposal operations.
points during mining and milling,
In the construction and demolition
primary and secondary manufacture,
industries, where exposures can far
extended periods of use, construction
exceed 2 f/cc, the reduced PEL will have
end demolition, brake repair, and
a beneficial impact on the workplace
disposal.
environment. Where regulated areas
In urban areas, particularly, airborne and air-tight enclosures are used in
emissions also occur during the normal renovation and demolition operations, .
use and wear of friction materials such the amount of ambient emissions will be
as brake and clutch linings. The final
reduced, Similarly, the use of work
rule is not anticipated to impact directly practice, such as wetting down, or point
on these sources of emissions outside of the workplace. To the extent that '' substitutes may be developed and used in these products as a result of the rule, however, there would be a potential benefit to the environment;
As the level of absestos fibers in the workplace is lowered to meet the PEL, there is a potential for more fibers to be vented outside of that environment, depending on the job performed and control method used. For example, as a result of EPA's National Emissions Standards for Hazardous Air Pollutants (NESHAPS) (49 FR 67:13659-13665, April 5,1984) many industries choose to clean workplace air, thereby removing asbestos fibers, before it is vented to the outside environment. Where baghouses and other gas-cleaning devices are used to capture fibers, the 99.9 percent efficiency rate of these devices will remain unchanged. Because these controls are capable of capturing fibers
as small as 0.5 microns in diameter and even as small as 0.1 microns (but with less efficiency), more fibers would be captured; potentially benefitting the ambient atmosphere.
In manufacturing processes, emissions result primarily from the handling and mixing of dry asbestos fibers and during operations such as blending and mixing, the weaving of asbestos fibers into textiles, and in the sanding, finishing, and culling of hard asbestos products. Emissions from the manufacturing
process can be controlled by using local exhaust ventilations, dust collection and cleaning systems, and enclosures, by ; capturing and filtering devices such as baghouses, electrostatic precipitators and wet.scrubbers, by using wet . ' processes instead of dry when possible, by reducing the amount of asbestos added to products and by properly disposing of the waste materials.
Emissions also occur from extended
source of controls, such as portable capture devices, will reduce ambient air emissions of asbestos fibers. Where respirators alone are used to achieve compliance andprovide worker protection in specific environments, the level of ambient air emissions will remain constant.
In shipbuilding operations in the past,
asbestos materials were used extensively in ceiling tile for overheads, and in fire-resistant sheets for bulkheads and insulation. As of 1978. the Maritime Administration's specification for government-subsidized ships required that nonasbestos materials be used in shipbuilding. As a result, asbestos insulation and cement materials have been replaced by products such as mineral wool and mineral wool cement. Ships built after 1978 are therefore assumed to be free of asbestos.
Although current shipbuilding
operations do not generate exposures to asbestos, exposures are potentially high in ship repair and maintenance of already existing asbestos materials. The nature of this work frequently precludes the use of many engineering controls and extensive work practices. The combined use of work practices, protective clothing, and air-line respirators has been the means of controlling exposures to asbestos emissions. The actual physical configuration of ships also imposes constraints on some tear-out.operations. For example, hatchways are narrow,
space for life-support and power lines is limited, boiler and fire rooms are located in the lowest levels of the ship, hatchways and stairways must hot be blocked, and in general, there is a need for egress in cases of emergency.
As many engineering controls appear to be infeasible in various ship repair operations, a PEL of 0.2 f/cc would not
periods of use of products: during
grinding and fitting operations in replacing and repairing brake linings
9 In 1973, EPA banned the use of 9pray-on Insulation of fireproofing materials containing more ' than 1 percent asbestos by weight. But these, as
and clutch facings: during installation of well as decorative'materials excluded from the ban.
asbestos-cement pipe insulation: during the cutting or sawing of asbestos-cement
sheet, and other construction materials; during demolition, or rip out of spray-on
can and do exist in buildings that are renovated or demolished and, consequently, can pose significant sources of exposures {Exhibit No. 84-414]. Also, the OSHA role would prohibit the spray>on application of asbestos materials in all affected industries.
significantly alter the present level of ambient air emissions of asbestos, or affect the external environment. Worker
protection can be afforded, however, by reducing the exposure levels with the use of air-line or, in some cases, fullmask respirators.'
In the automotive aftermarket, exposures to airborne emissions occur in the remanufacturing and repairing of
brakes and clutches. In the remanufacturing sector, exposures occur during refacing and finishing activities.-
In refacing operations, local controls, including shrouded machine tools with local exhaust systems, can be used to remove abraded material from the work area. In some cases, hoods and upgraded general ventilation systems exist, and overall, local vacuuming is believed to be practiced fairly extensively. In finishing operations, the control methods include the use of local controls, such as shrouds on grinders and the local vacuum collection systems.
In the general repair sector, until recently, it was common practice to use compressed air to remove asbestos fibers and wastes during the cleaning of the brake drums and bell housings prior to repair. This practice has been replaced with the use of compressed airhoses to apply a solvent mist to remove asbestos residue from the brake drums before repair. In other instances, damp wiping is performed, wetting agents are used, and high-efficiency particulate air (HEPA) vacuum systems are employed. Where enclosed vacuum systems and the compressed-air solvent-mist process are employed, exposure levels below the action level can be attained. It is believed that the OSHA recommended spray can/solvent mist process will reduce exposures and emissions even further. These types of controls and work practices would benefit the workplace environment and lessen the
potential for the release of fibers to the external environment.
In sum; the use of local controls, filters, collection devices and wet methods would reduce levels of airborne emissions in the workplace. Further, because of the nature of EPA's . emissions standard (40 FR 199:483012, October 14,1975), many industry . operations already use-engineering controls where feasible to reduce the amount of emissions to the atmosphere. Controls already in place are anticipated to continue to operate effectively in reducing emissions under the rule. As asbestos fibers are removed from the atmosphere by such controls, any fibers collected could be disposed of as solid waste or could comprise
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