2.1.1.1. Asbestos Emissions



Many buildings on the ANL-E site contain large amounts of asbestos-containing materials (ACM) such as thermal system insulation around pipes and tanks, spray-applied surfacing material for fireproofing, floor tile, and asbestos-cement panels. This material is removed as necessary during renovations or maintenance of equipment and facilities. The removal and disposal of this material is governed by the asbestos NESHAP.

The standards for asbestos specify detailed requirements for removal and disposal of certain types of ACM. Until the November 1990 revisions, only friable (easily crushed) ACM was regulated. Now, however, many other types of ACM are regulated, including nonfriable materials that have been, or could be reduced to a crumbly, pulverized or powder state through the process of removal or disposal. This change greatly increases the amount of material regulated by the NESHAP.

The standard describes accepted procedures for removal of ACM, including notification of the IEPA prior to removal of greater than certain amounts, work practices and procedures to be used, and emission control procedures to be used. The use of specially trained individuals for removal of ACM is mandated.

ANL-E maintains an asbestos abatement program designed to assure compliance with these and other regulatory requirements. ACM are removed from the Laboratory by either a specially-trained Waste Management (WM) crew (for "small-scale" short-duration projects as defined by the NESHAP-Asbestos Title 40, Part 61 of the Code of Federal Regulations [40 CFR 61], Subpart M) or by outside contractors specializing in ACM removal work (for large-scale insulation removal projects lasting a day or longer). All removal work is done in strict compliance with both NESHAP and Occupational Safety and Health Administration (OSHA) requirements governing worker safety at ACM removal sites. When ACM is encountered during a renovation or demolition project, it is carefully wetted or otherwise encapsulated and completely removed. The work area is sealed off using disposable glove bags or temporary plastic sheeting barriers, and high-efficiency particulate air (HEPA) filtration equipment is used to control emissions. Air is monitored in the vicinity of such work by ANL-E Industrial Hygiene personnel both during the removal work and after the work is completed, in order to verify that adequate precautions have been taken to prevent the release of significant amounts of asbestos. Personal exposure air samples are collected. Asbestos fiber counts are analyzed using Phase Contrast Microscopy, and selected samples are analyzed by Transmission Electron Microscopy.

Approximately 245 m3 (8,600 ft3) of ACM were removed from ANL-E buildings during 1995. These materials included various structural or facility components such as surfacing materials, thermal system insulation, floor tile and mastic, and transite wallboard. Also included are items that were part of the removal activity and became contaminated with asbestos, such as Tyvek coveralls, gloves, and polyethylene sheets. Asbestos-containing laboratory equipment such as the laboratory furnace, heating coil, and transite tabletop were also removed and included in the annual estimate. The primary types of asbestos identified in these materials were chrysotile and amosite.

Most of the ANL-E asbestos removal activities are small nonscheduled renovation operations as defined by the NESHAP-Asbestos (40 CFR 61, Subpart M). The duration of these projects is usually not more than eight hours, and glovebag removal techniques are normally used. A total of 142 small removal projects were completed and generated 77 m3 (2,700 ft3) of ACM waste. Projects performed by outside contractors accounted for 28 m3 (980 ft3) of the ACM waste from small projects.

The asbestos NESHAP standards require that the IEPA be notified before beginning large asbestos removal projects involving more than 80 m (260 ft) of pipe insulation or 15 m2 (160 ft2) of other materials or 1 m3 (35 ft3) of ACM where the length or area cannot be measured. The Notification of Demolition and Renovation Form must be forwarded to the IEPA within a prescribed time limit. Eight Notification of Demolition and Renovation forms were provided to the IEPA during 1995. Project information is provided in Table 2.1.

The NESHAP requires estimation of the total amount of ACM to be removed during renovation or demolition activities during each upcoming calendar year. If this amount exceeds the regulatory levels given above, the IEPA must be notified. ANL-E made such a notification during December 1995 for activities planned for 1996. It is estimated that no more than 128 m3 (4,500 ft3) of ACM waste will be generated during 1996.

A separate portion of the standard contains requirements for waste disposal sites used for disposal of ACM. The acceptable disposal practice involves placing wetted waste materials into labeled, leakproof plastic bags for disposal in landfills. Off-site shipments are to be accompanied by completed shipping manifests. The principal requirements applicable to landfill disposal of ACM relate to covering the ACM daily with at least six inches of non-asbestos-containing materials and maintenance of disposal records. Asbestos disposal information is provided in Table 2.2.

TABLE 2.1

Asbestos Abatement Projects: IEPA Notification, 1995

Completion Notification Quantity Disposal Quantity
Date (ft) (ft2) Material Building (ft3) Landfill
January 31, 1995 300 188 Chiller and Pipe Insulation 200 300 Communitya
200 NAb Generator Pipe Insulation 202 100 Community
75 2,000 Pipe Insulation and Cooling 203 500 Community
Tower Panels 203 350 Countyc
May 5, 1995 165 600 Pipe Insulation, Floor Tile, and Mastic 202 180 County
May 24, 1995 350 245 Pipe and Tank Insulation 108 473 County
July 14, 1995 650 5,200 Pipe Insulation, Floor Tile, and Mastic 25 585 County
80 NA Air Handling Unit Insulation 223 190 County
NA 360 Exterior Siding 605 80 County
September 15, 1995 340 100 Pipe Insulation 223 125 County
December 6, 1995 NA 840 Floor Tile 362 48 Libertyd
December 23, 1995 NA 20,300 Carpet and Floor Tile Mastic, Spray-on Insulation 213 2,430 County
January 29, 1996e NA 7,760 Floor Tile and Mastic 212 544 Hanfordf

a Community Landfill Company, Morris, Ill.
b NA = not applicable.
c County Environmental Livingston Landfill, Pontiac, Ill.
d Chambers Liberty Landfill, Monticello, Ind.
e Majority of project completed in 1995.
f Disposed of as low-level radioactive waste at Westinghouse Hanford Corporation, Richland, Wash.

TABLE 2.2

Disposal of Asbestos-Containing Materials, 1995


Project Size
Landfill
Quantity (ft3)
Total Quantity (ft3)
Small-Scale County Environmentala 2,069
Chambers Libertyb 521
Pekin Metroc 137 2,727
Large County Environmental 4,461
(IEPA Notification) Communityd 900
Hanforde 544 5,905
Total 8,632

a County Environmental Livingston Landfill, Pontiac, Ill.
b Chambers Liberty Landfill, Monticello, Ind.
c Central Illinois Landfill Service Corporation Peking Metro Landfill, Peking, Ill.
d Community Landfill Company, Morris, Ill.
e Disposed of as low-level radioactive waste at Westinghouse Hanford Corporation, Richland, Wash.




Until closure of the ANL-E landfill in September 1992, asbestos from small-scale projects was disposed of on site in a designated area of the landfill. The IEPA conducted an asbestos disposal inspection on April 28, 1994. Noncompliance with 40 CFR 61.154(g) -- failure to modify deed to reflect the presence of asbestos material -- was cited. On June 17, 1994, the IEPA transmitted a Compliance Inquiry Letter that stated that ANL-E was in apparent noncompliance with 40 CFR 61.154(g) in that it failed to modify its property deed to reflect the fact that the landfill had been used for the disposal of ACM, thus making said disposal part of the public record and subject to discovery during a title search of the property.

DOE is responsible for any required modifications to the property deed and provided a response to IEPA on July 8, 1994, indicating the steps that would be taken to modify the deed. However, the deed was not modified during 1995. DOE must address some issues associated with the ANL-E boundary prior to modifying the property deed.


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