Asbestos Recognition

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Asbestos Recognition Waste HandlingPart 1 of 2

• John Podolinsky
• State of Montana
• Department of Environmental Quality
• Waste Underground Tank Management Bureau
• Asbestos Control Program
• Fall 2008

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What is Asbestos?

• Naturally occurring fibrous minerals.
• Chrysotile, amosite, crocidolite, anthophyllite,
  tremolite, actinolite, others.
• Over 3000 different products were made using
  asbestos fibers.
• Some new products are still made using asbestos
  see EPA Asbestos Ban Phase Out Rule.

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Asbestos Micrograph
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Asbestos Uses and Why

• Asbestos fibers were/are added to construction
  materials and other products to enhance
  properties of insulation, heat and cold
  resistance, fireproofing, sound proofing,
  texturing, condensation control, decoration,
  chemical resistance, friction, tensile strength,
  filler, filtering, etc.

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Asbestos Containing Material (ACM) Defined

• ACM is any material containing more than one
  percent asbestos (gt1) by Polarized Light
  Microscopy techniques.
• Friable ACM contains gt1 asbestos and can be
  crumbled, pulverized, or reduced to powder by
  hand pressure.
• Non-Friable ACM contains gt1 asbestos and cannot
  be crumbled, pulverized, or reduced to powder by
  hand pressure.
• Regulated Asbestos Containing Materials (RACM)
  are friable ACMs and non-friable ACMs that are or
  have become friable, and therefore, regulated by
  definition of RACM in Asbestos Work Practices
  Procedures Manual.

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Examples of Friable ACM

• Pipe insulation, boiler insulation, tank
  insulation, ceiling tiles/panels, fireproofing,
  heater/furnace/duct insulation, duct tape,
  ceiling texture, ceiling materials, wall
  materials, plaster, drywall, texture, attic
  insulation, wall insulation, textured paint, etc.
  
• Most friable ACMs were banned by EPA in the 1970s
  and 1990.

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Pipe Boiler Insulation
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Aircell Pipe Insulation
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Ceiling Tiles/Panels
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Heater/Furnace/Duct Insulation
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Sprayed On Fireproofing
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Plaster
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Wallboard(drywall/tape/mud)
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Vermiculite/Zonolite
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Vermiculite/Zonolite
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Dry Crushing Mill - 1966
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Anthophyllite/Karstolite

• 80-100 asbestos material found as attic
  insulation in Bozeman, Livingston, and Helena.
• Raw material originated from the Gallatin Canyon
  Karst Asbestos Mine.
• Processed at the/former Bozeman Train Depot.
• Mousy-bed/dirty cottage cheese appearance with
  fibers.
• Karstolite ore used as backfill in foundations,
  pipe trenches, culverts, etc.

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Anthophyllite/Karstolite
Anthophyllite/Karstolite
Brown Cellulose (non-asbestos)
Gray Cellulose (non-asbestos)
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Non-Friable ACM Examples

• Packings Gaskets
• Resilient Floor Covering (Floor Tile, Sheet Vinyl
  Floor Covering)
• Asphalt Roofing Products
• Cement Asbestos materials such as water pipe,
  flue pipe, board, siding roofing shingles
• Putty, caulks, mastics, adhesives, grout, caulks,
  concrete, brake and clutch materials, electrical
  insulation, etc.
• Others
• Many non-friable ACMs are not banned

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Flooring MaterialsFloor Tile, Sheet Vinyl, Mastic
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Asphalt Roofing
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Cement Asbestos Board
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Cement Asbestos Pipe
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Asbestos Siding
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Asbestos Exposure/Health Effects

• Fibers can be inhaled and ingested.
• Can cause illnesses such as plural plaques,
  asbestosis, mesothelioma, lung cancer,
  gastrointestinal illness.
• 10-40 year latency period between exposure and
  illness.
• Smoking and Susceptibility.

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Asbestos Inspection

• Prior to building demolition or renovation
  activities, building materials that will be
  impacted are required to be inspected for
  asbestos by a DEQ-accredited asbestos inspector
  on behalf of the building owner or contractor.
• Inspection can serve as a waste characterization
  for transportation and disposal purposes.
• Non ACM examples - wood, glass, metal, fiberglass.

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Asbestos Non-Compliance

• Many building demolition and renovation
  activities fail to comply with asbestos
  inspection requirements and proper asbestos
  abatement procedures.
• Fear that asbestos waste is transported and
  disposed of non-compliantly.
• Fear of asbestos exposures to personnel who
  transport and disposal unknowingly/non-compliantly
  .

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Asbestos Non-Compliancecontinued

• Transporting and disposing of asbestos waste
  without a TD permit or being accredited by DEQ
  are citable offenses.
• OSHA and Department of Labor Industry
  regulations also apply to protect employees from
  asbestos exposure (MT Safety Culture Act).
• Concern about handling non-friable ACM,
  wallboard, and vermiculite waste stuff that
  sometimes falls outside of DEQ asbestos
  regulations.

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What To Do??!!

• If regulated asbestos waste is placed in your
  dumpster??!!
• If regulated asbestos waste comes to your
  gate??!!
• If regulated asbestos waste is dumped at your
  site??!!

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Asbestos Transportation DisposalPart 2 of 2

• John Podolinsky
• State of Montana
• Department of Environmental Quality
• Waste Underground Tank Management Bureau
• Asbestos Control Program
• Fall 2008

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Asbestos Waste Regulations

• Asbestos and Solid Waste Administrative Rules of
  Montana, Title 17, Chapters 74 and 50
• Asbestos Work Practices Procedures Manual,
  section 5.09 A B
• EPA National Emission Standards for Hazardous Air
  Pollutants (NESHAP)
• OSHA and Dept of Labor Industry
• DOT and MDT

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Solid Waste ARM

• Only DEQ-licensed class II IV landfills can
  accept regulated asbestos waste, which are
  defined as Group II wastes.
• Non-friable ACM can be disposed of as
  construction/demolition waste. OSHA/DLI
  regulations apply for employee protection.

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Asbestos ARM

• Asbestos project means the removal,
  encapsulation, enclosure, repair, renovation,
  placement in new construction, demolition of
  asbestos in a building or other structure, or the
  TRANSPORTATION OR DISPOSAL of asbestos-containing
  waste. Does not include less than 3 square or
  linear feet of RACM.
• ARM 17.74.303 Exclusions Homeowner asbestos work
  is exempt from regulations, but asbestos waste
  packaging, transport, and disposal requirements
  apply. The Manual and NESHAP are incorporated by
  reference in the ARM.

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Asbestos Waste Transport and Disposal

• Transport and disposal (TD) of regulated
  asbestos waste (3 or more square or linear feet)
  are regulated by DEQs Asbestos Control Program.
• TD asbestos project permit required
• Accreditation requirements apply to personnel
  conducting TD asbestos project worker or
  contractor/supervisor.

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Asbestos Manual

• Section 5.09 A B of the Manual covers who can
  transport and dispose of asbestos waste, proper
  waste packaging in leak-tight wrappings, lining
  of dumpster, loading/unloading placarding,
  personnel protection, adequate wetness of waste,
  labeling of waste with generator name and
  address, verification of waste quantity,
  temporary waste storage, licensing of disposal
  site, covering of waste, waste shipment record
  (WSR), etc.

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EPA NESHAP

• 40 CFR Part 61, subpart M, Asbestos.
• Governs building demolition and renovation
  activities, inspecting for asbestos, building
  demolition/renovation notification, asbestos
  removal, asbestos waste disposal, and other
  sources of asbestos emissions.
• Applies to facilities on Indian Reservations.
• Active and inactive asbestos waste disposal
  sites.
• WSR, fencing, signage, waste cover, mapping,
  recordkeeping, etc.
• EPA AHERA applies to schools.

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OSHA/Dept of Labor Industry

• 29 CFR 1926.1101, 29 CFR 1910.1001, and others
  regulate asbestos activities.
• Montana Safety Culture Act DLI for public
  employees.
• OSHA and DLI govern employer responsibilities and
  employee safety.

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Department of Transportation

• 49 CFR Parts 172 173
• Proper identification and shipping requirements
• Class 9 Hazardous Substance
• Waste label - NA2590 for white asbestos, NA2212
  for blue or brown asbestos
• Proper packaging, wetness, labeling, WSR, etc.

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Transportation

• Accredited asbestos project worker or
  contractor/supervisor
• Transportation Permit
• Poly lined dumpster
• Asbestos Danger signs posted during
  loading/unloading
• Waste Shipment Record/Manifest
• Proper packaging, labeling, wetness, etc.
• Discrepancies reported to DEQ

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Waste Shipment Record/Manifest
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Disposal

• Accredited asbestos project worker or
  contractor/supervisor
• Disposal Permit
• Waste Shipment Record/Manifest
• Proper packaging, labeling, wetness, etc.
• Asbestos Danger signs posted during
  loading/unloading
• Dispose of in asbestos cell which is fenced,
  mapped, etc.
• Cover waste with 6 of non-asbestos material or
  other options
• Discrepancies reported to DEQ or EPA
• Close inactive waste disposal sites per NESHAP

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Warning Sign

• Posted and easy to read
• Asbestos Waste Disposal Site, Do Not Create
  Dust, Breathing Asbestos is Hazardous to Your
  Health

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Asbestos Signage
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Signage
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Asbestos Waste Concerns

• Care for asbestos waste waste reduction,
  compacting, transfer station actions, etc.
• Concern about handling non-friable ACM,
  wallboard, and vermiculite waste stuff that
  sometimes falls outside of DEQ asbestos
  regulations.
• Salvaging, recycling, or reusing waste that
  contains asbestos.
• Training available.

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References

• DEQ Asbestos Control Program
• [phone] www.Asbestos.mt.gov
• EPA [phone] www.epa.gov
• Department of Labor Industry
• [phone] http//erd.dli.mt.gov
• OSHA [phone] www.osha.gov
• DOT [phone] www.dot.gov
• MDT [phone] www.mdt.mt.gov