FRIABLE ASBESTOS-CONTAINING
MATERIALS:
Due to their high tensile
strength, incombustibility, corrosion and friction resistance and other
properties, such as acoustical and thermal insulation abilities, asbestos
fibers have been incorporated into over thirty-six hundred (3600) commercial
products. Thermal system, fireproofing and acoustical insulation materials have
been used extensively in the construction industry.
Thermal system applications
include steam or hot water pipe coverings and thermal block insulation found on
boilers and hot water tanks. Fireproofing insulation may be found on building
structural beams and decking. Acoustical insulation (soundproofing) commonly
has been applied as a troweled-on plaster in school and office building
stairwells and hallways. Unfortunately, with time and exposure to damaging
forces (e.g., severe weather, chemicals, mechanical forces, etc.), many
asbestos-containing materials may become crumbled, pulverized or reduced to
powder, thereby releasing asbestos fibers, or may deteriorate to the extent
that they may release fibers if disturbed. Since inhalation of asbestos fibers
has been linked to the development of respiratory and other diseases, any
material which is friable, or has a high probability of releasing fibers, must
be handled in accordance with the Asbestos NESHAP.
NON-FRIABLE ASBESTOS-CONTAINING
MATERIALS:
Because of the resilient nature
of asbestos, it is used in materials exposed to a wide variety of stressful
environments. These environments can cause the deterioration of binding
materials and cause non-friable materials to become friable. For example,
asbestos-containing packings and gaskets (Category I
non-friable ACM) used in thermal systems may be found in poor condition as a
result of the heat they have encountered. In petrochemical handling facilities,
which may have miles of transfer pipes and fittings which contain asbestos
gaskets and/or packings, profound degradation of the
ACM may occur due to exposure to organic-based liquids and gases or to
corrosive agents used to chemically clean these lines.
When non-friable ACM is subjected
to intense mechanical forces, such as those encountered during demolition or
renovation, it can be crumbled, pulverized, or reduced to powder, and thereby
release asbestos fibers. When non-friable materials are damaged or are likely
to become damaged during such activities, they must be handled in accordance
with the Asbestos NESHAP.
There are two categories of
non-friable materials: Category I non-friable ACM and Category II non-friable
ACM.
CATEGORY I non-friable ACM
Category I non-friable ACM is any
asbestos-containing packing, gasket, resilient floor covering or asphalt
roofing product which contains more than one percent (1%) asbestos as
determined using polarized light microscopy (PLM) according to the method
specified in Appendix A, Subpart F, 40 CFR Part 763. (Sec. 61.141)
Category I non-friable ACM must
be inspected and tested for friability if it is in poor condition before
demolition to determine whether or not it is subject to the Asbestos NESHAP. If
the ACM is friable, it must be handled in accordance with the NESHAP.
Asbestos-containing packings, gaskets, resilient
floor coverings and asphalt roofing materials must be removed before demolition
only if they are in poor condition and are friable.
The Asbestos NESHAP further
requires that if a facility is demolished by intentional burning, all of the
facility's ACM, including Category I and II non-friable ACM, be considered RACM
and be removed prior to burning (Sec. 61.145(c)(10)). Additionally, if Category
I or Category II non-friable ACM is to be sanded, ground, cut, or abraded, the
material is considered RACM and the owner or operator must abide by the
following (Sec. 61.145(c)(1)):
(i)
Adequately wet the material during the sanding, grinding, cutting or abrading
operations.
(ii) comply
with the requirements of 61.145(c)(3)(i) if wetting
would unavoidably damage equipment or present a safety hazard.
(iii) Handle asbestos material
produced by the sanding, grinding, cutting, or abrading, as asbestos-containing
waste material subject to the waste handling and collection provisions of
Section 61.150.
CATEGORY II non-friable ACM
Category II non-friable ACM is
any material, excluding Category I non-friable ACM, containing more than one
percent (1%) asbestos as determined using polarized light microscopy according
to the methods specified in Appendix A, Subpart F, 40 CFR Part 763 that, when
dry, cannot be crumbled, pulverized, or reduced to powder by hand
pressure. (Sec. 61.141)
Category II non-friable ACMs
(cement siding, transite board shingles, etc.)
subjected to intense weather conditions such as thunderstorms, high winds or
prolonged exposure to high heat and humidity may become "weathered"
to a point where they become friable.
The following table lists
examples and other relevant information about Category I and Category II
non-friable ACM.
TABLE 1. non-friable ASBESTOS
PRODUCTS
From EPA
Guidance entitled "Guidance for Controlling Asbestos- Containing
Materials in Buildings" (Purple Book), appendix A, Page A-1; EPA 560/5-85-024.
Except for the following, Section
61.145(c) of the Asbestos NESHAP requires that each owner or operator of a
demolition or renovation activity involving RACM remove all such material from
a facility being demolished or renovated before any activity begins that would
break up, dislodge, or similarly disturb the material or preclude access to the
material for subsequent removal.
ACM need not be removed
before demolition if it:
(i) Is
a Category I non-friable ACM that is not friable.
(ii) Is on a facility component
that is encased in concrete or other similarly hard material and is adequately
wet whenever exposed during demolition.
(iii)
Was not accessible for testing and therefore was not discovered until after
demolition began and, as a result of the demolition, cannot be safely removed.
If not removed for safety reasons, the exposed RACM and any
asbestos-contaminated debris must be treated as asbestos-containing waste
material and kept adequately wet at at all times
until disposed of.
(iv) Is
a Category II non-friable ACM and the probability is low that the material will
become crumbled, pulverized, or reduced to powder during demolition.
4. INSPECTION PROCEDURES TO
DETERMINE THE POTENTIAL FOR FIBER RELEASE FROM non-friable ASBESTOS-CONTAINING
MATERIALS:
Members of the regulated
community (i.e. abatement contractors, industrial hygienists, building owners
& operators, etc.) should become familiar with these procedures as they are
designed to enhance compliance with the Asbestos NESHAP.
GENERAL INSPECTION PROCEDURES
1. Identify all non-friable suspect ACM and determine whether it is Category I or II.
2. If it is Category I
non-friable RACM:
Is it in "poor
condition?" [Is the binding of the ACM losing its integrity? Is the ACM
peeling, cracking, or crumbling? (Remember, friable ACM may not appear in poor
condition.)]
Is it friable?
- Collect a piece of dry ACM and
seal it in a transparent, reclosable sample bag.
- Apply hand pressure and observe
if the ACM falls apart to the extent that it is crumbled, pulverized, or
reduced to powder. Does it occur suddenly, all at once?
- Send representative samples of
the RACM to an analytical laboratory which is able to test them for the
presence of asbestos according to the methods specified in 40 CFR Part 763
Subpart F, Appendix A.
- Ask the owner/operator if any
ACM or RACM has been sampled and analyzed. If so, determine where the samples
were taken and ask if the methods of demolition/renovation were considered when
assessing the fiber release potential of the material. Will it or has it been
subjected to sanding, grinding, cutting or abrading?
3. If it is Category II
non-friable ACM:
- Has the material been crumbled,
pulverized or reduced to powder or is there a high probability that it will be
crumbled, pulverized or reduced to powder during the demolition/renovation
operations, thus rendering the material friable and subject to the Asbestos
NESHAP?
- If Category II non-friable ACM
has been or will be crumbled, pulverized, or reduced to powder by demolition or
renovation forces, take representative samples and send them to a laboratory to
test for the presence of asbestos according to the method specified in 40 CFR
Part 763, Subpart F, Appendix A.
5. SPECIFIC INSPECTION
PROCEDURES:
CATEGORY I non-friable ACM
Packings and Gaskets
These materials are often very
difficult to find because they are usually placed inside ovens, doors, pipes,
boilers, etc. Often a packing or gasket is discovered during a stripping or
demolition activity. For example, some boilers have an asbestos containing
paraffin wax packing between the steam lines that travel between the mud and
fire boxes. The paraffin binding of the packing may decompose due to the high
temperatures, and render the packing friable. Observe all of the packing and
note areas that are in poor condition. Packings in
poor condition appear dry and discolored, and fibers may be visible.
A representative piece of
asbestos-containing packing material (in good or poor condition) should be
removed with a utility knife and sealed in a transparent, reclosable
bag. Apply hand pressure to the packing in the sample bag to determine if any
portion is crumbled, pulverized or reduced to powder. If the material simply
deforms, but does not crumble or reduces to a powder, then the material is
considered non-friable.
Resilient Floor Covering
There is a wide variety of
resilient floor covering applications that contain asbestos. The most common
are linoleum flooring and vinyl asbestos tile (VAT). VAT is most commonly found
in either a 9"x9" or a 12"x12" square size. The
9"x9" VAT's are normally found in older buildings because they were
manufactured earlier than the 12"x12" VAT's; however, floor tile
sizes and resilient floor covering applications vary greatly since many
buildings have been re-tiled several times.
In order to determine if a
resilient floor covering is in poor condition look for sections or tiles which
are cracked or peeling to the extent that they are crumbled. Floor coverings in
poor condition can often be found near doorways or loading/staging areas where
the floor has sustained a lot of stress and traffic. If the floor covering is
in poor condition, collect a small representative sample and seal it in a
transparent, sample bag. Hand pressure should be applied to determine if the
material can be crumbled, pulverized, or reduced to powder. If it can, the
material is considered friable. Resilient floor covering that will be or has
been sanded, ground or abraded is subject to the Asbestos NESHAP.
Asphalt Roofing Products
Asbestos-containing roofing felts
have been widely used in "built-up" roofs. Built-up roofing was used
on flat surfaces and consists of alternating layers of roofing felt and
asphalt. The roofing felt consists of asbestos paper saturated and coated with
asphalt. Asphalt-asbestos roofing products made from roofing felt coated with
asphalt were reportedly used on residential structures for only a short time
(1971-1974).
To determine if an asphalt
roofing product is covered by the Asbestos NESHAP, examine the RACM to spot any
areas where the material is in poor condition and friable.
If possible, sample areas where
fibers can be seen protruding from the matrix of the asphalt. The sample should
be sealed into a transparent, reclosable sample bag
and hand pressure applied to see if the sample can be crumbled, pulverized, or
reduced to powder.
CATEGORY II non-friable ACM
Asbestos Cement Pipe and Sheet
Products
Asbestos-cement (A-C) pipe has
been widely used for water and sewer mains and occasionally used as electrical
conduits, drainage pipe, and vent pipes. A-C sheet, manufactured in flat or
corrugated panels and shingles (transite board), has
been used primarily for roofing and siding, but also for cooling tower fill
sheets, canal bulkheads, laboratory tables, and electrical switching gear
panels. If these ACM are crumbled, pulverized or reduced to a powder, they are
friable and thus covered by the Asbestos NESHAP. Broken edges of these material typically are friable. The fractured surface
should be rubbed to see if it produces powder.
If Category II non-friable ACM
has not crumbled, been pulverized or reduced to powder and will not become so
during the course of demolition/renovation operations, it is considered
non-friable and therefore is not subject to Asbestos NESHAP. However, if during
the demolition or renovation activity it becomes crumbled, pulverized or
reduced to powder, it is covered by the Asbestos NESHAP.
