EPA Other EPA Regions
Regional Administrator

Asbestos NESHAP
Coordinators

Press Officer

Division Director

Section Chief

Asbestos NESHAP
Coordinator

Delegated
State

Air Pollution Control Emergency Management

Delegated
Local
Air Pollution Control
Agency

Emergency Management
Agency

Buildings
Department

Figure 1. Emergency response structure.



APPENDIX B

FEMA REGIONAL DIRECTORS

35



statutes and regulations, possible sources of information to help locate asbestos in a

community, and special considerations relevant to clean up and disposal. This document will
be most useful for advanced planning for emergency situations, although it will still find use

when a disaster strikes.

31



Appendix C

STATE OFFICIAL RESPONSIBLE
FOR DISASTER OPERATIONS

STATE EMERGENCY DIRECTOR

Mr. William O. Brock

Director, Alabama Emergency
Management Agency

520 South Court Street

Montgomery, Alabama 36130

(205) 834-1375

Mr. Ervin P. Martin
Director, Division of Emergency
Services, Dept. of Military
and Veterans Affairs
3501 E. Bogard Road
Wasilla, Alaska 99687-2689

(907) 376-2337

Mr. Maiava (Oliver) F. Hunkin

Disaster Program Coordinator
Department of Public Safety

American Samoa Government

P.O. Box 1086

Fagatogo, American Samoa 96799

011-684-633-2331

Mr. William D. Lockwood
Director, Arizona Division of
Emergency Services
National Guard Building
5636 East McDowell Road
Phoenix, Arizona 85008

(602) 244-0504

RESPONSIBLE SENIOR
— OFFICIAL _

same

Maj. Gen. John W.Schaeffer
The Adjutant General

Dept. of Military

Veterans Affairs

1800 E. Dimond Boulevard
Suite 3-450

Anchorage, Alaska
99515-2097

(907) 249-1565

Mr. Tuilefano M. Vaela’s
Acting Commissioner of
Public Safety, Depart-
ment of Public Safety
American Samoa Government
P.O. Box 1086
Fagatogo, American Samoa
96799

011-684-633-1111

Maj. Gen. Donald L. Owens
The Adjutant General
National Guard Building
5636 East McDowell Road
Phoenix, Arizona 85008

(602) 273-9710



IV. ASBESTOS NESHAP APPLICABILITY

The applicability of the asbestos NESHAP (40 CFR Part 61, Subpart M) in emergency
situations is discussed here. Whenever asbestos will be damaged or disturbed as part of a
demolition or renovation and a threshold amount (160 square feet, or 260 linear feet, or 35
cubic feet) is exceeded, or whenever a building is demolished, the asbestos NESHAP applies.
There are no provisions that stay the applicability of the NESHAP as a result of disaster,
although there are emergency-related provisions. The relevant sections of the NESHAP
include Definitions (61.141), Standard for Demolition and Renovation (61.145), Standard for
Waste Disposal for Manufacturing, Fabricating, Demolition, Renovations, and Spraying
Operations (61.150), and Active Disposal Sites (61.154).

A. Definitions (61.141)

The only definition that is specifically applicable to emergencies is "emergency
renovation operation." The NESHAP defines the term as follows:

“Emergency renovation operation" means a renovation operation that was not

planned but results from a sudden, unexpected event that, if not immediately

attended to, presents a safety or public health hazard, is necessary to protect

equipment from damage, or is necessary to avoid imposing an unreasonable

financial burden. This term includes operations necessitated by nonroutine failures

of equipment.

The xepair or replacement of an apartment building’s asbestos-insulated boiler that fails
during the winter may be considered an emergency renovation, since to delay repair or
replacement could expose residents of the apartment building to dangerously cold
temperatures. Or, the repair of asbestos-insulated equipment that suddenly fails at a power
plant could result in prolonged power outages and affect many essential services if not

attended to immediately. These are examples of asbestos removal operations that might be

considered emergency renovations. It is usually the responsibility of the building owner or



RHODE
ISLAND

SOUTH
CAROLINA

SOUTH
DAKOTA

TENNESSEE

Mr. Edward A. Cotugno

Executive Director, Rhode Island
Emergency Management Agency

State House

Providence, Rhode Island 02903

(401) 421-7333
FAX (401) 751-0827

Mr. Paul Lunsford

Director, Emergency Preparedness
Division

1429 Senate Street

Columbia, South Carolina 29201

(803) 734-8020

Mr. Gray N. Whitney

Director, Division of Emergency
and Disaster Services

Department of Military Affairs

EOC-State Capitol

Pierre, South Dakota

57501-5060

(605) 773-3231

Mr. Lacy E. Suiter

Director, Tennessee Emergency
Management Agency

3041 Sidco Drive

Nashville, Tennessee 37204

(615) 252-3300

Maj. Gen. Andre Trudeau

The Adjutant General and
Director, Rhode Island
Emergency Management
Agency

Armory of Mounted Commands

1051 North Main Street

Providence, Rhode Island

02904

(401) 277-2100

Maj. Gen. T. Eston Marchant
The Adjutant General
Rembert C. Dennis Building
1000 Assembly Street
Columbia, South Carolina
29201

(803) 748-4200

Maj. Gen. Harold J. Sykora

The Adjutant General

State Director of Civil
Defense

State Capitol

Pierre, South Dakota

57501-5060

(605) 773-5340

Maj. Gen. Carl Wallace

The Adjutant General

3041 Sidco Drive

Nashville, Tennessee 37204

(615) 252-3001


Mr. Donald A. DeVito

Director, State Emergency
Management Office

Division of Military and
Naval Affairs

Public Security Bldg.

State Campus

Albany, New York 12226-5000

(518) 457-2222

Mr. Joseph F. Myers

Director, North Carolina

Division of Emergency
Management

Administration Building

116 West Jones Street

Raleigh, North Carolina 27611

(919) 733-3867

Mr. Ronald D. Affeldt
Director, North Dakota Division

of Emergency Management
P.O. Box 5511
Bismarck, North Dakota
58502-5511

(701) 224-2111

Mr. Felix A. Sasamoto

Disaster Control Officer

Office of the Governor

Commonwealth of the Northem
Mariana Islands

Saipan, Mariana Islands 96950

011-670-322-9529/9572

Maj. Gen. Lawrence P. Flynn

Adjutant General, NYS
Division of Military and
Naval Affairs

330 Old Niskayuna Road

Latham, New York

12110-2224

(518) 786-4502

Mr. Joseph W. Dean

Secretary, Department of
Crime Control and
Public Safety

P.O. Box 27687

Raleigh, North Carolina

27611

(919) 733-2126

Maj. Gen. Alexander
MacDonald

The Adjutant General

P.O. Box 5511

Bismarck, North Dakota

58502-5511

(701) 224-5102

Same



APPENDIX D

REGIONAL ASBESTOS COORDINATORS





MISSISSIPPI

Mr. Thomas Motherway

Director, Division of Emergency
Services

Department of Public Safety

State Capitol, B-5

St. Paul, Minnesota 55155

(612) 296-2233 - FTS 372-7854

Mr. James E. Maher

Director, Emergency Management
Agency

P.O. Box 4501, Fondren Station.

Jackson, Mississippi 39216

(601) 352-9100

Mr. Richard D. Ross

Director, State Emergency.
Management Agency

P.O. Box 116

Jefferson City, Missouri

65102

(314) 751-9571

Mz. F. Guy Youngblood
Administrator, Disaster
and Emergency Services
Division’
Department of Military Affairs
P.O. Box 4789
Helena, Montana 59604-4789

(406) 444-6911

Mr. Richard L. Semm

Assistant Director, Nebraska
Civil Defense Agency

National Guard Center

1300 Military Road

Lincoln, Nebraska 68508

(402) 473-1410

Mr. Paul Tschida

Commissioner, Department
of Public Safety

211 Transportation Bldg.

St. Paul, Minnesota 55155

(612) 296-6642

Same

Maj. Gen. Charles Kiefner
The Adjutant General
1717 Industrial Drive
Jefferson City, Missouri
65101

(314) 751-9710

Maj. Gen. James W. Duffy

The Adjutant General

Department of Military
Affairs

P.O. Box 4789

Helena, Montana 59604

(406) 444-6910

Maj. Gen. Stanley M. Heng

The Adjutant General and

Director, Nebraska Civil
Defense Agency

National Guard Center

1300 Military Road

Lincoln, Nebraska 68508

(402) 473-1100



1. The Problem
In the aftermath of catastrophic events that result in significant structural

damage to buildings, fire and buildings departments personnel typically are called upon to
identify those structures that are in imminent danger of collapse. Recent experience with
Hurricane Hugo and the San Francisco earthquake indicates that these personnel are often not
conscious of the presence of asbestos and the hazard it represents. Nor are they aware that
the NESHAP prescribes minimum work practices that must be followed even in an ordered
demolition resulting from a catastrophic emergency. The first part of the problem then is one
of a lack of awareness of the applicable asbestos regulations on the parts of some local
government personnel. It can be remedied by a conscious effort to inform them of the
NESHAP. The second part of the problem is that local emergency personnel, even if they are

aware of asbestos and the NESHAP, may not be qualified to determine whether asbestos is

present in a structure. Accordingly, an asbestos NESHAP inspector needs to be on the scene.

2. Strategy
As a courtesy, Regional asbestos NESHAP coordinators should contact the

FEMA Regional Directors to explain EPA’s interest in asbestos, the NESHAP requirements
applicable to catastrophes, and EPA’s plan to inform state and local emergency preparedness
agencies of the NESHAP requirements. Copies of the regulation and A Guide to the
Asbestos NESHAP, As Revised November 1990 with the relevant portions highlighted should
be made available to FEMA. Names, addresses, and telephone numbers of FEMA Regional
Directors are given in Appendix B.

Then the Regional asbestos NESHAP coordinators should recommend that the state air
pollution control agencies in their regions contact their counterpart state emergency
preparedness agencies to inform them of the NESHAP requirements. Again, copies of the

18



Appendix B
FEMA REGIONAL DIRECTORS
Region I

Mr. Richard H. Strome
Regional Director
Federal Emergency Management Agency
J.W. McCormack, Post Office and
Court House, Room 442
Boston, Massachusetts 02109

ETS: 223-9540; Commercial: (617) 223-9540; FAX: 223-9519

Region

Mr. Phillip McIntire

Regional Director (Acting)

Federal Emergency Management Agency
26 Federal Plaza, Room 1338

New York, New York 10278

FTS: 649-8208; Commercial: (212) 238-8202; FAX: 238-8245

Region Ti

Mr. Paul Giordano

Regional Director

Federal Emergency Management Agency
Liberty Square Building (Second Floor)
105 S. Seventh Street

Philadelphia, Pennsylvania 19106

FTS: 489-5608; Commercial: (215) 931-5608; FAX: 489-5513

Region IV

Mr. Major P. May

Regional Director

Federal Emergency Management Agency
1371 Peachtree Street, N.E., Suite 700
Atlanta, Georgia 30309

FTS: 230-4200; Commercial: (404) 853-4200; FAX: 230-4230



TABLE OF CONTENTS

INTRODUCTION . 2.0... ce cece eee ene teen ene nnn 1

A. Background ©... 0... cece eee tee eee t tee re tenes 1
B. Purpose 2... eee ee tee teen teen teen tenes 1
RECENT EMERGENCIES 3
A. Gramercy Park 3
B. Hurricane Hugo .. 3
C. San Francisco Earthquake .. 1.1.2... eee ee eee eee eens 4

ASBESTOS NESHAP APPLICABILITY .......-. eee eee eee e eee enes 8
A. Definitions (61.141) veee 8
B. Demolition and Renovation Provisions (61.145) .......-. 0. eee e eens 9
1. Emergency Renovation Operations ......... esse eee eee ee eee 9

2. Government-Ordered Demolitions . . 10

C. Waste Disposal (61.150) ..........5- Ul
D. Active Waste Disposal Sites (61.154) 12
PRE-EMERGENCY PLANNING ...... 0.02 eee eee eee eens 13
A. Emergency Response Organization ..... 6.26 eee eee eee eee eee 13
B. Coordination With Local Emergency and Related Organizations .......:. 13
J. The Problem . 0... 6... cc eee ee eee ene nae 18

2. Strategy 2... eee eee teen eens 18

C. Mapping Asbestos Locations ......-+..- eee e eee e ee ere etter 20
1. Asbestos Milling, Manufacturing, and Fabricating -. 20

2. Asbestos in Facilities .. 0... 6... e ee eee eee eee .. 21

a. Surveys of Buildings for Asbestos ..........+..+- .. 21

b. Schools 2.0... 0. cee eee eee tee eee ete eee 23

c. Local Building Permit Agencies .... 2.6.0.0... eee ee erences 23

d. Notifications .. 2.0.2... 020 ee ee eee «. 25

D. leanup and Disposal .........-.- ee eee eres oe. 25
1. Water Supply ..... 2.0.00. e eee eee eee eee a. 26

2. Chemical Contamination ....... -.+ 26

3. Waste Disposal ........... we. 27

4, Backup Personnel .. 1.2... eee ee ee eee eens 27

5. Laboratory Capabilities ©... 00... ee ee cee eee eee eee 27

6. Emergency Exemptions ........ 6500s eee eee eee eee eee 28



VI. EMERGENCY PERIOD
When a catastrophic emergency occurs, the responsible NESHAP coordinator should
implement those plans developed prior to the emergency. Listed below are some of the more
significant actions to be taken. Specific actions to be taken will, of course, depend on the
nature of the emergency.
+ Contact those agencies listed in the emergency response structure (see Figure 1).
+ Assess the need to issue press release(s).

+ Through contact with building and fire departments, determine magnitude of the
problem, ie., number of damaged structures.

¢ Activate previously established procedures with fire and building departments to be
kept informed of buildings that are ordered to be demolished.

+ Assess need for additional resources, e.g., inspectors, laboratory capabilities, etc. and
take steps, as necessary, to augment existing resources.

¢ Provide guidance to delegated agencies, as appropriate.
¢ — Assess need to allow selected exemptions to the NESHAP requirements.

* Make periodic contacts with agencies listed in the emergency response structure, as
needed.

29



Contact. Telephone number

Other EPA Regional asbestos NESHAP
coordinators

State asbestos NESHAP coordinators

Figure 2. Example emergency telephone list for
Regional asbestos NESHAP coordinator.

15



Another source of information on asbestos milling, manufacturing, and fabricating
facilities is the Toxic Chemical Release Inventory System (TRIS), a computer system
designed by EPA to track the annual emission of toxic chemicals into the environment. TRIS
compiles toxic emissions information submitted by facilities, including asbestos processing
facilities, regulated under the Superfund Amendments and Reauthorization Act (SARA).
TRIS can be accessed by the name of the pollutant and provide a list of the names and
locations of sources in the data base. Facilities are required to report under TRIS if they
release above a certain amount of the toxic pollutant. If the estimated emissions fall below a
certain level, a facility is not required to submit information and will not be picked up by
TRIS. TRIS can be accessed by EPA employees and other Federal, state, and local
government officials on EPA’s National Computer Center (NCC) in Research Triangle Park,
North Carolina. The user must have an NCC user ID and authorization to access the system.
To obtain a user ID, contact TRIS User Support at (202) 475-9419.

2. Asbestos in Facilities

Facility refers to any institutional, commercial, public, industrial, or residential
structure, installation, or building (excluding residential buildings having four or fewer
dwelling units). There are several potential sources of information that may be used to help
locate asbestos-containing structures within a community.

a. Surveys of Buildings for Asbestos

The results of an EPA survey of buildings for the presence of asbestos may

be helpful in identifying asbestos-containing facilities.'” In addition to estimating the number
of buildings that contained asbestos, the survey also looked at the presence of asbestos in
relation to various building characteristics, including height and age of the building. The
findings of the EPA survey represent the situation on a national basis. The presence of

21



Contact

Telephone number

State asbestos NESHAP
coordinator

Other local asbestos NESHAP

coordinators

Local emergency management
agency

Building department
Fire department

Landfill operators

Laboratories

Emergency response organization

Figure 4. Example emergency telephone list for
local asbestos NESHAP coordinator.

17



VII. CONCLUSIONS

Efforts to restore the damaged areas to their predisaster condition often involve removing
or repairing damaged structures. There may be a natural tendency at this stage to overlook
certain hazards, such as asbestos, that are not immediately life threatening. However, such
hazards are serious and may manifest themselves many years from the time of exposure and
should be taken into consideration. Given the health hazards associated with asbestos
exposure, it is reasonable that adequate measures be taken during emergency situations to
minimize exposure to asbestos from the demolition or renovation of buildings. The

applicability of the asbestos NESHAP is not altered as the result of a disaster. With a few

exceptions for emergency renovations and government-ordered demolitions, all of the

NESHAP requirements are applicable in emergency situations.

One of the key factors in effectively dealing with asbestos in emergency situations is
communications. Communications are needed between the asbestos NESHAP coordinator and
the other emergency response agencies and related agencies. The first step is for the
Regional asbestos NESHAP coordinator to discuss this matter with Regional FEMA personnel
and assure them of EPA’s desire to cooperate with FEMA and other emergency response
agencies. The next step is for the Regional EPA offices to inform their respective state
NESHAP enforcement agencies of the need to coordinate efforts. The delegated state
NESHAP agency should then contact the state emergency preparedness office to discuss the
need to consider asbestos in emergency situations. Finally, the same communications should
occur at the local level.

This guidance document is intended to assist asbestos NESHAP coordinators in dealing
with asbestos during catastrophic emergency situations. It provides suggestions for
coordinating with other local and state emergency-related agencies, information on applicable

30



D. Active Waste Disposal Sites (61.154)

There are no special provisions or exemptions from the NESHAP for any
asbestos-containing waste material that is subject to the asbestos NESHAP.

Asbestos-containing waste from emergency renovations, government-ordered demolitions, or

from any source covered by the NESHAP must be disposed of in compliance with all the

provisions of 61.154.





Buildings destroyed by Hugo were considered to be demolished by natural
causes and notification requirements were waived. Removal contractors
were not required for the cleanup; however, wetting and proper disposal of
asbestos-containing material were required.

Remaining, uncontaminated building debris was disposed of in accordance
with solid waste regulations.

Open burning was permitted in the disaster area to clear it of trees and
wood products without using landfills.

Partially destroyed buildings could be demolished without notifications
after asbestos materials were removed by abatement contractors.

A problem that emerged in South Carolina was that of unscrupulous contractors preying
on unsuspecting home owners by telling them that they were subject to $25,000 a day in fines
unless their roofs were repaired by licensed asbestos contractors, when, in fact, SCDHEC
regulations did not apply to private residences unless the homeowner selected a licensed
asbestos contractor. A one-page Guidelines for Homeowners with Damaged Asbestos
Roofing was issued by SCDHEC to outline requirements for homeowners.

Emergency preparedness representatives, presumably unaware of the presence of
asbestos, complicated asbestos NESHAP enforcement by instructing people to go ahead and
knock down damaged buildings.

C. San Francisco Earthquake

On October 17, 1989, an earthquake registering 7.1 on the Richter scale shook San
Francisco. According to the Region 9 asbestos NESHAP coordinator, many demolition
contractors thought the NESHAP regulations did not apply following the earthquake and
many buildings were demolished without regard to asbestos. At a minimum, the NESHAP

coordinator feels that wetting should be employed and the debris disposed of properly.

Based on the Region 9 experience, the NESHAP coordinator suggested the following to

prepare for emergencies:



3. Waste Disposal
Where a large number of asbestos-contaminated facilities are damaged and need
to be demolished without prior removal of the asbestos, a large amount of
asbestos-contaminated waste will be generated. The existing capacity of the landfills that are
available to accept asbestos waste may be inadequate. Another problem may arise if the
landfill is not accessible as a result of the disaster. Under these conditions, altemative
disposal sites would be needed. In some cases, it may be possible to arrange with another
local landfill to accept the waste, or it may be necessary to transport the waste to more distant
sites. Alternative sites should be identified in advance, if possible. To the extent possible,
uncontaminated demolition waste should be segregated from the asbestos-contaminated debris
to reduce the volume that has to be disposed of in accordance with the NESHAP. NESHAP
coordinators should establish emergency contacts for landfills and agree on emergency
procedures in advance for accepting and handling asbestos-containing waste.
4. Bi Personnel
It may be necessary to have additional enforcement personnel available to
oversee asbestos cleanup and disposal operations, since decisions may have to be made at the
same time at numerous locations regarding appropriate actions to take. Cleanup operations
that go on around the clock may require inspections after normal working hours to make sure
work is being done properly. Additional NESHAP inspectors may be available from other
NESHAP delegated local agencies, the state, the Region, or from other states.
5. Laboratory Capabilities
Large numbers of bulk samples may require quick analysis before NESHAP
enforcement personnel can make decisions on appropriate actions to take. Arrangements
should be made for additional laboratory support to handle a potentially large number of

27



Table 1. New York City Survey Results -- Percentage
of Buildings Containing Asbestos and Average
Amount of Asbestos Per Building

Average Amount of
Percent of Asbestos per
Buildings Building with
Building Category with Asbestos Asbestos (sq. ft.)

Tall office buildings 84 64,341
Educational structures 83 3,233
Hotels 78 3,802
Walk-up apartments 74 457
Hospitals 72 6,929
Elevator apartments 72 4,832
Churches 71 919
One and two family 68 167
Outdoor recreation 64 969
Short office buildings 64 2,109
Stores 62 363
Factories 61 1,759
Theaters 57 4,438
Govt. /transportation 43 8,282
Warehouses/lofts 40 2,393
Garages/gas stations 17 419

Source: City of New York Department of Environmental
Protection. Final Report. Assessment of the Public’s
Risk of Exposure to In-Place Asbestos. New York, New
York. December 1, 1988.



GUIDELINES FOR CATASTROPHIC EMERGENCY SITUATIONS
INVOLVING ASBESTOS
I INTRODUCTION
A. Background
In 1989, the Califomia earthquake and Hurricane Hugo resulted in the destruction of
or damage to numerous buildings, many of which contained asbestos. Badly damaged or
destroyed structures had to be demolished quickly to reduce the threat of injuries from the
damaged structures and to aid in restoring the affected areas. In the same year, a steam pipe
explosion in Gramercy Park, NY spread asbestos over a wide area with the potential to
expose a large number of people to asbestos.

These recent natural and man-made disasters and others that have damaged or destroyed
structures containing asbestos have served to focus attention on the need to consider asbestos
along with other emergency response activities. Understandably, the emphasis in an
emergency or disaster situation is on efforts to mitigate the immediate threats to public health
and safety and to retum the stricken area to its former condition as quickly as possible. Also,
the organizations that typically respond to emergency or disaster situations, such as fire
departments and emergency management agencies, do not deal with asbestos as part of their
normal duties. As a result, there may be a tendency to overlook potential public health
threats like asbestos, which do not pose an immediate, life-threatening hazard.

B. Purpose

These guidelines are intended to assist Regional, state, and local agencies in

managing potential asbestos hazards resulting from a catastrophic accident or disaster. The

guidelines may be used as a reference for advanced planning or, once the emergency presents



VI. EMERGENCY PERIOD

Vil. CONCLUSIONS

Asbestos NESHAP Checklist for Catastrophic Emergency Situations

FEMA Regional Directors

State Official Responsible for Disaster Operations

Regional Asbestos Coordinators . 2.2.2... ee eee eet 54



V. PRE-EMERGENCY PLANNING

In advance of a catastrophic emergency, Regional, state and local NESHAP coordinators
should take certain steps to ensure that potential asbestos hazards can be adequately managed
and asbestos exposures minimized. The following sections identify activities that, if
performed prior to an emergency, should help to ensure an adequate response in the event of
a catastrophic emergency.

A. Emergency Response Organization
Each Regional office should prepare a flow chart for their Region (similar to

Figure 1) with the names and telephone numbers of contact persons and backups. Copies of
the completed flow chart should be provided to neighboring Regions.

An organizational flow chart showing in parallel the levels of government engaged in
enforcing the asbestos NESHAP and responding to catastrophic emergencies is given in
Figure 1. Normal channels for the flow of information, requests for assistance, etc. are shown
as solid lines connecting the government agencies, while channels that need to be established
in order to plan for and respond to asbestos encountered in forced demolitions resulting from
emergencies are shown as dashed lines. Example emergency telephone lists for Regional,
state, and local asbestos NESHAP coordinators are presented in Figures 2, 3, and 4. The lists
are presented for illustrative purposes only; they are not intended to be comprehensive. The
telephone lists needed by a NESHAP coordinator will depend on several factors including, for
example, the extent to which NESHAP authority has been delegated.

B. Coordination With Local Emergency and Related Organizations

The responsible NESHAP coordinators should establish contact with responsible

emergency agencies and inform them of the NESHAP requirements.

13



Il. RECENT EMERGENCIES

Three emergencies occurred in 1989 that focused EPA’s attention on the handling of
asbestos. One was a technological failure--a Consolidated Edison steam pipe explosion at
Gramercy Park in N.Y. City; the other two were natural phenomena--Hurricane Hugo and the
San Francisco earthquake. These emergencies are reviewed here for lessons that may help
plan for and deal with similar problems in the future.

A. Gramercy Park

On August 19, 1989, an underground Consolidated Edison steam pipe exploded in

Gramercy Park in New York City, discharging 400°F steam, asbestos and mud into the air
and onto and into nearby buildings. The explosion killed three people, injured m4, and forced
the evacuation of 200 residents. Two-hundred pounds of asbestos from pipe insulation were ,
released with the explosion. The cleanup and decontamination of the contaminated structures
required several months. The asbestos-contaminated waste was collected and transported to
the Meadowfill Landfill, Clarksburg, West Virginia for disposal. The cleanup was supervised
by the New York City Department of Environmental Protection, with oversight by EPA. This
cleanup effort was not regulated under the asbestos NESHAP, because it was neither a
demolition nor a renovation.

B. Hurricane Hugo

In September 1989, Hurricane Hugo made a landfall on the South Carolina coast at

Charleston destroying many buildings, damaging many others, and creating vast amounts of
debris, some of it contaminated by asbestos. The City of Charleston was declared a disaster
area and the South Carolina Department of Health and Environmental Control (SCDHEC) was
asked to assist with the cleanup of debris. To deal with a problem of such great magnitude,

SCDHEC adopted the following procedures:



regulation and Guide should be provided. The state emergency preparedness agency should

be asked to inform local emergency preparedness agencies that they will be contacted by their
local air pollution control agency, as appropriate. The state air pollution control agency
should then contact local air pollution control agencies and recommend that they contact the
appropriate local emergency preparedness agencies. Names, addresses, and telephone
numbers of state officials responsible for disaster operations are given in Appendix C.

By working through the local emergency preparedness agency, the local air pollution
control agency can reach fire and building department personnel and share the message with
them. The asbestos NESHAP coordinator should discuss with heads of fire and building
departments their procedures for identifying buildings that need to be demolished and develop
procedures whereby the NESHAP agency can be kept apprised of the location of buildings
that are ordered demolished during emergency situations. ,

Many state and local emergency preparedness agencies utilize emergency operations
centers to coordinate emergency response and relief activities in times of disaster. These
operations centers frequently have communications systems designed to remain intact during
disasters when normal systems, such as telephone lines, may be inoperative. In their contacts
with state and local emergency preparedness agencies, NESHAP coordinators should discuss
the possibility of having access to these systems if their normal communication links are
disrupted in an emergency.

At the local level, plans can be prepared that provide for making asbestos NESHAP
inspectors available to assist in evaluating asbestos problems in buildings following disasters.
State and Regional NESHAP enforcement agencies should plan to respond by providing
additional inspectors if requested and public information services. A checklist is provided in
Appendix A summarizing suggested lines of communications along with other planning aids.

19



United States . Air And Radiation EPA 340/I-92-010
Environmental Protection (EN-341W) February 1992
gency

SEPA Guidelines For Catastrophic
Emergency Situations
Involving Asbestos



GEORGIA

Mr. Joseph P. Yeldell
Director, Office of Emergency
Preparedness

2000 14th Street, NW, Eighth FL.

Washington, DC 20009
(202) 727-6161

Mr. Gordon L. Guthrie

Director, Division of Emergency
Management

2740 Centerview Drive

Tallahassee, Florida 32399

(904) 487-4918

Mr. Billy J. Clack

Executive Director, Georgia
Emergency Management Agency
P.O. Box 18055

Atlanta, Georgia 30316-0055

(404) 624-7000

Mr. Jose T. Terlaje

Director, Civil Defense/Guam
Emergency Services Office
Territory of Guam

P.O. Box 2877

Agana, Guam 96910

011-671-477-9841

Mr. Roy C. Price, Sr.

Vice Director of Civil Defense
Department of Defense

3949 Diamond Head Road
Honolulu, Hawaii 96816

(808) 734-2161

Mr. Tom Pelham

Secretary, Department of
Community Affairs

2740 Crestview Drive

Tallahassee, Florida 32399

(904) 488-8466

*Maj. Gen. Joseph W. Griffin

The Adjutant General and
Director, Georgia Emergency
Management Agency

P.O. Box 18055

Atlanta, Georgia 30316-0055

(404) 624-6000

Same

*Maj. Gen. Alexis T. Lum

The Adjutant General of the

National Guard and Director
of Civil Defense

Department of Defense
3949 Diamond Head Road
Honolulu, Hawaii 96816

(808) 734-2195



I. OTHER APPLICABLE STATUTES

In addition to the asbestos NESHAP, there are other Federal statutes that provide
planning information and/or cleanup authority applicable to catastrophic emergencies
involving asbestos. They include the Asbestos Hazard Emergency Response Act (AHERA);
the Emergency Planning and Community Right-to-Know Act (EPCRA); the Comprehensive

Environmental Response, Compensation, and Liability Act of 1980 (CERCLA); and the

Occupational Safety and Health Act (OSHA).

A. AHERA
Regulations promulgated under the authority of AHERA require the preparation of
management plans for asbestos in school buildings (40 CFR 763.93). Plans must be prepared
by an accredited management planner and include:

¢ The name and address of each school building and whether it contains
friable asbestos.

A blueprint, diagram or written description that identifies the location and
approximate square or linear feet of asbestos.

Thus, a data base on asbestos in school buildings already exists in the administrative offices
of school systems in many communities. This data base is potentially useful either for
emergency response planning or for identifying asbestos-containing structures following the
occurrence of a catastrophic emergency.
B. EPCRA

Since asbestos is not listed as an extremely hazardous substance, emergency plans
developed under EPCRA do not address asbestos. However, the Act also requires routine
toxic chemical release reporting and friable asbestos is a reportable emission (40 CFR
372.65). Information collected in this way is entered into a computer file known as the Toxic
Release Inventory System (TRIS) which can be accessed to identify asbestos sources in SIC

6



+ Create an emergency phone list

¢ Coordinate with nearby Regions

¢ Tie into existing emergency communication plans

« Set up an emergency protocol for buildings and fire departments
+ Set up emergency protocols with delegated agencies

* Prepare and pre-position press releases regarding NESHAP and asbestos
risks

* Contact the Federal Emergency Management Agency (FEMA) regarding
asbestos risks and NESHAP

¢ Contact state emergency planners

¢ Set up an informal network of volunteer inspectors.

The NESHAP coordinator also noted that there was a shortage of inspectors available to

determine whether asbestos was present in the damaged buildings and that obtaining

additional help was a problem.



Appendix D

REGIONAL ASBESTOS COORDINATORS

Regional Asbestos Coordinator.

US EPA, Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3835

Regional Asbestos Coordinator
US EPA, Region 2
Woodbridge Avenue

Edison, NJ_ 08837

(201) 321-6671

Regional Asbestos Coordinator
US EPA, Region 3

841 Chestnut Street
Philadelphia, PA 19107

(215) 597-3160

Regional Asbestos Coordinator
US EPA, Region 4

345 Courtland Street

Atlanta, GA 30365

(404) 347-5014

Regional Asbestos Coordinator
US EPA, Region 5

230 South Dearborn Street
Chicago, IL 60604

(312) 353-6003

#U.S. Government Printing Office :

55

Regional Asbestos Coordinator
US EPA, Region 6

Allied Bank Tower

1445 Ross Avenue

Suite 1200

Dallas, TX 75720

(214) 655-7244

Regional Asbestos Coordinator
US EPA, Region 7

726 Minnesota Avenue

Kansas City, KS 66101

(913) 551-7381

Regional Asbestos Coordinator
US EPA, Region 8

One Denver Place

999 18th Street

Suite 500

Denver, CO 80202-2405
(303) 293-1442

Regional Asbestos Coordinator
US EPA, Region 9

75 Hawthorne Street

San Francisco, CA 94105
(415) 556-5406

Regional Asbestos Coordinator
US EPA, Region 10

1200 6th Avenue

Seattle, WA 98101

(206) 442-4762

1992 - 312-014/40056



Region IX

Mr. William M. Medigovich

Regional Director

Federal Emergency Management Agency
Building 105

Presidio of San Francisco

San Francisco, California 94129

FTS: 469-7100; Commercial: (415) 923-7100; FAX: 469-7157

Region X

Mr. Raymond C. Williams

Regional Director (Acting)

Federal Emergency Management Agency
Federal Regional Center

130 228th Street, S.W.

Bothell, Washington 98021-9796

FTS: 390-4604; Commercial: (206) 487-4604: FAX: 390-4707

Source: Directory of Governors, State Officials and Adjutants General Responsible for

Disaster Operations and Emergency Planning, FEMA-9. Washington, D.C.: Federal
Emergency Management Agency, July 1990.



list of considerations is not intended to be complete since any number of complications could
arise.
1. Water Supply
Water supplies may be disrupted during disasters making it difficult to wet

asbestos during the demolition or abatement of asbestos-containing structures. This is likely

to be more of a problem where relatively large quantities of water are needed, for example,

when a building is being demolished upon a government order and the asbestos cannot be
removed prior to demolition. Large quantities of water will be needed to keep the debris wet
during demolition and during the loading for transport to a disposal site. However, during an
emergency, adequate water may not be readily available. If possible, such demolitions should
be delayed until the water supply can be restored or until an altemate supply can be obtained.

2. Chemical Contamination

Where accidents or emergencies involve industrial facilities, there is the

possibility that any asbestos that is involved may be contaminated with process chemicals. In
some instances, the chemicals may be hazardous. Where asbestos is contaminated with toxic
chemicals, other regulations may also apply to their handling and disposal. For hazardous
chemicals regulated under RCRA, for example, the disposal site requirements are more
stringent than those for asbestos. In some instances, it may not be advisable to apply water to
the contaminated asbestos waste. Usually the emergency response teams that deal with
accidents involving hazardous chemicals will know the best procedures for handling those
chemicals. Coordination with emergency response teams in these situations should help

ensure that the hazards associated with asbestos are adequately addressed.



IDAHO

ILLINOIS

INDIANA

IOWA

KANSAS

Mr. Darrell G. Waller

Coordinator, Bureau of
Disaster Services

Military Division

650 West State Street

Boise, Idaho 83720

(208) 334-3460

Mr. John Plunk, Acting Director
Illinois Emergency Services

and Disaster Agency
110 East Adams Street
Springfield, Hlinois 62706

(217) 782-6818 - FTS 372-7851

Mr. Jerome Hauer, Director

Indiana State Emergency
Management Agency

State Office Building, Room 315

100 North Senate Avenue

Indianapolis, Indiana 46204

(317) 232-3830 - FTS 372-7852

Ms. Ellen Gordon

Administrator, Disaster Services
Division

Hoover State Office Bldg.

Level A, Room 29

Des Moines, Iowa 50319

(515) 272-5211

Vacant
Deputy Director, Division
of Emergency Preparedness
P.O. Box C-300
Topeka, Kansas 66601

(913) 233-9253 X 301

43

Maj. Gen. Darrell V.
Manning

The Adjutant General

Military Division

P.O. Box 45

Boise, Idaho 83707

(208) 385-5242

Same

Same

Maj. Gen. Warren G. Lawson

The Adjutant General and
Executive Director

Department of Public
Defense

Camp Dodge

7700 N.W. Beaver Drive

Johnston, Iowa 50131-1902

(515) 278-9211

Maj. Gen. Phillip B. Finley
The Adjutant General and
Director, Division of
Emergency Services

P.O. Box C-300

Topeka, Kansas 66601

(913) 233-7560 X 101



of approved building plans is usually kept by building permit agencies. Where a copy of the
specifications is also kept by the permitting agency, it could be used to help identify buildings
that contain asbestos.
d. Notifications
A number of large industrial facilities, such as petroleum refineries and

chemical plants, contain large amounts of asbestos in the form of thermal insulation. Many
of these facilities remove asbestos as part of nonscheduled renovation operations in addition
to scheduled renovations and demolitions. Nonscheduled renovations are typically
maintenance-related or repair-related renovations for which the exact date of occurrence
cannot be predicted, but based on previous experience, are likely to occur. Because the dates
of these renovations cannot be predicted, facilities where these operations occur often submit
annual, semiannual, or quarterly notices to EPA or its delegated authority describing how
these nonscheduled renovations will be handled to control asbestos emissions. Notices of
nonscheduled renovations and scheduled renovations and demolitions received from large
industrial facilities identify where asbestos is to be found and in what amounts.

D. Cleanup and Disposal

The responsible NESHAP coordinator should identify critical activities and

resources and develop contingency plans for augmenting or replacing them in an emergency.

Operations to clean up and dispose of asbestos during emergencies may be hampered by
unusual conditions resulting from the disaster. Often during disaster-related emergencies, the
normal provider/supplier relationships are disrupted so that business as usual is difficult, if not
impossible. Identified below are some circumstances that could complicate cleanup and

disposal operations and some suggested approaches to planning for such contingencies. The

25



itself, to help ensure that, to the extent feasible and compatible with other emergency
measures, all appropriate steps are taken to safely handle and dispose of all asbestos, while
avoiding unnecessary exposures to asbestos. The guidelines provide information that may be
helpful to EPA Regional offices and delegated NESHAP agencies that must respond to
emergencies involving asbestos.

The guidelines review the experiences of EPA Regional and state enforcement agencies
in dealing with asbestos during recent emergencies. Information is included on statutes and
regulations that may be applicable in emergency situations, including the emergency
provisions of the asbestos NESHAP. Lines of communication within EPA and between EPA
and emergency management agencies are discussed. A list of contacts responsible at the state
level for emergency and disaster activities is provided, as is a protocol for coordinating
asbestos NESHAP activities with local fire and building departments. Information is provided

to help identify potential sources of asbestos releases, and factors are identified that should be

considered in planning for the cleanup and disposal of asbestos.



Contact Telephone number

Regional asbestos NESHAP
coordinator

Asbestos NESHAP
coordinators of adjacent
states

Local asbestos NESHAP
coordinators

Local air pollution control
agencies

State emergency management
agency

Landfill operators

Laboratories

Emergency response
organizations

Figure 3. Example emergency telephone list for
state asbestos NESHAP coordinator.



WYOMING

Source:

Mr. Edwin S. Usui Maj. Gen. Charles Wing
Coordinator, Wyoming Disaster The Adjutant General

and Civil Defense Division P.O. Box 1709
P.O. Box 1709 Cheyenne, Wyoming 82003

Cheyenne, Wyoming 82003
(307) 772-6233
(307) 777-7566

Directory of Govemors, State Officials and Adjutants General Responsible for Disaster
Operations and Emergency Planning, FEMA-9. Washington, DC: Federal Emergency
Management Agency, July 1990.

33



APPENDIX A

ASBESTOS NESHAP CHECKLIST FOR
CATASTROPHIC EMERGENCY SITUATIONS

33



Appendix A
ASBESTOS NESHAP CHECKLIST FOR
CATASTROPHIC EMERGENCY SITUATIONS

. Regional Coordination Activities

Regional FEMA

Other regional NESHAP coordinators

Delegated state NESHAP agencies
. State Coordination Activities

State emergency preparedness agencies
Delegated local NESHAP agencies

. Local Coordination Activities
Local emergency preparedness agencies
Local building departments
Local fire departments

. Link with Emergency Communication System

. Emergency Telephone List

Alternate Water Supplies

Coordination with Emergency Response Agency for Hazardous Chemical Contamination

. Alternate Waste Disposal Sites
. Additional Asbestos Inspectors
. Laboratory Support

. Press Releases



OHIO

OKLAHOMA

OREGON

Mr. Dale W. Shipley

Deputy Director, Ohio
Emergency Management
Agency

2825 West Granville Road

Columbus, Ohio 43235-2712

(614) 889-7155
FTS 372-7855

Mr. Woodrow Goins
Director, Oklahoma Civil
Defense Agency
P.O. Box 53365 .
Oklahoma City, Oklahoma 73152

(405) 521-2481

Ms. Myra T. Lee
Administrator, Emergency
Management Division

Executive Department
603 Chemeketa Street, NE
Salem, Oregon 97310

(503) 378-4124

PENNSYLVANIA

PUERTO
RICO

Mr. Joseph LaFleur
Director, Pennsylvania

Emergency Management Agency
Transportation and Safety
Building, B-151
Harrisburg, Pennsylvania 17120

(717) 783-8150
Mr. Heriberto Acevedo
Director, State Civil
Defense Agency
P.O. Box 5127
San Juan, Puerto Rico 00906

(809) 724-0124

49

Adjutant General’s
Department

Ohio Emergency Management
Agency

2825 West Granville Road

Columbus, Ohio 43235-2712

Attn: Dale W. Shipley

(614) 889-7150

Same

Mr. Fred Miller, Director
Executive Department
15 Cottage Street, NE
Salem, Oregon 97310

(503) 378-3104

Lt. Gov. Mark S. Singel

Chairman, Pennsylvania
Emergency Management
Council

State Capitol

Harrisburg, Pennsylvania

17120

(717) 787-3300

Same



asbestos in buildings may vary from these national averages from one part of the country to
another for various reasons, such as climate and age of cities.

Overall, the survey found that 20 percent of all buildings contained asbestos-containing
friable material, either in the form of sprayed- or trowelled-on asbestos, asbestos ceiling tile,
asbestos pipe and boiler insulation, or a combination of two or all three types. Pipe and
boiler insulation was more common (found in 16 percent of the buildings) than sprayed- or
trowelled-on asbestos (found in 5 percent of the buildings). Asbestos ceiling tile was rarely
found. Pipe and boiler insulation was generally limited to machine rooms, while sprayed- or
trowelled-on material was usually found exposed to areas of public use rather than behind
drop ceilings or otherwise concealed.

Relative to the age of buildings, the study found that in buildings built prior to 1960,
most of the asbestos was found as boiler and pipe insulation; after 1960, most of the friable
asbestos was sprayed or trowelled onto ceilings and steel beams, a practice which continued
until 1973 when most sprayed-on uses of asbestos were banned by EPA. Decorative
sprayed-on asbestos was banned in 1978.

The study also found that taller buildings are more likely to have asbestos-containing
friable material. Of the 19 high-rise buildings (8 or more floors) surveyed, all contained
asbestos pipe and boiler wrap and 41 percent contained sprayed- or trowelled-on asbestos
material.

As stated above, the EPA survey results represent national averages of asbestos-
containing buildings. The results may be significantly different in different parts of the
country. For example, in a survey of buildings in New York City for the presence of

asbestos, the results varied significantly from the national averages presented in the EPA

study.’ Overall, 68 percent of buildings in New York City have some form of asbestos. The

22



Mr. Addison E. Slayton, Jr.
State Coordinator

Office of Emergency Services
310 Turner Road

Richmond, Virginia 23225

(804) 674-2497

Mr. William S. Harvey
Director, Virgin Island
Territorial

" -VITEMA

WASHINGTON

‘WISCONSIN

#3-4 King Street
Christiansted, US VI 00820

(809) 774-2244

Ms. Kate Heimbach

Assistant Director,

Division of Emergency Management
Dept. of Community Development
4220 East Martin Way, PT-11
Olympia, Washington 98504-8611

(206) 753-5255

Mr. Bill R. Joplin

Acting Director, West Virginia
Office of Emergency Services
State Capitol Complex, EB 80
Charleston, West Virginia 25305

(304) 348-5380

BG Richard I. Braund, USNG Ret.)

Administrator, Division of
Emergency Government

Department of Administration

4802 Sheboygan Avenue, Rm. 99A

Madison, Wisconsin 53707

(606) 266-3232 - FTS 372-7856

Col. Robert Suthard
Secretary, Department of
Public Safety

Ninth Street Office Bldg.
Sixth Floor

Richmond, Virginia
23225-6491

(804) 786-5351

Maj. Gen. Charles Hood

The Adjutant General

Virgin Islands Territorial
Emergency Management Agency
Foreign Arrivals Bldg.
Alexander Hamilton Airport

St. Croix, US 00850

(809) 772-7443

Mr. Chuck Clarke

Director, Department of

Community Development
State of Washington

Ninth & Columbia Building,

MS/GH-51

Olympia, Washington

98504-4151

(206) 753-5625

Same

BG Jerald D. Slack

The Adjutant General
Wisconsin National Guard
3020 Wright Street
Madison, Wisconsin 53708

(608) 241-6312





ARKANSAS

CALIFORNIA

COLORADO

CONNECTICUT

DELAWARE

Mr. James Lee Witt

Director, Office of Emergency
Services

P.O. Box 758

Conway, Arkansas 72032

(501) 329-5601, Ext. 201

(501) 374-1201 (Little Rock)

Mr. Donald R. Irwin
Director, Office of Emergency
Services, State of Califomia
2800 Meadowview Road

Sacramento, Califomia
95832-1499

(916) 427-4201

Mr. Richard E. Hatten

Director, Disaster Emergency
Services

EOC, Camp George West

Golden, Colorado 80401

(303) 273-1624

Mr. Frank Mancusco

State Director, Office of
Emergency Management

360 Broad Street

Hartford, Connecticut 06105

(203) 566-3180/4338
FAX (203) 247-0664

Mr. James W. Hoffman

Director, Division of Emergency
Planning and Operations

P.O. Box 527

Delaware City, Delaware 19706

(302) 834-4531

41

Same

Same

Mr. David J. Thomas

Executive Director

Colorado Department of
Public Safety

700 Kipling Street

Suite 3000

Lakewood, Colorado

80215-5865

(303) 239-4398

Same

Mr. Patrick W. Murray

Secretary of Public Safety

Department of Public Safety

Highway Administration
Building

Dover, Delaware 19901

(302) 736-4321



APPENDIX C

STATE OFFICIAL RESPONSIBLE FOR

DISASTER OPERATIONS

39



operator to demonstrate that the renovation was an emergency. The implications for an
emergency renovation in the context of the NESHAP requirements are discussed below.

B. Demolition and Renovation Provisions (61.145)

The demolition and renovation provisions of the NESHAP contain specific
requirements that may apply in certain emergency situations and include the provisions for
emergency renovation operations and government-ordered demolitions.

1. Emergency Renovation Operations

In order for a renovation to be considered an emergency renovation operation
and be subject to the NESHAP, it must satisfy the definitional requirements of an emergency
renovation operation and it must also meet the applicability requirements of Section 61.145
(a)(4)(iv). Section 61.145 (a)(4)(iv) specifies that for an emergency renovation to be subject
to the notification and control provisions of the NESHAP, the combined amount of regulated
asbestos-containing material (RACM) that is to be stripped or removed as a result of the
emergency, must equal or exceed 260 linear feet of asbestos on pipes or 160 square feet on
other facility components, or 35 cubic feet if the asbestos material is already off the facility
component and the length or area could not be determined previously.

Notifications for emergency renovation operations that are subject to the NESHAP must
be given as early as possible before the renovation begins, but no later than the next working
day following the day the emergency renovation begins (61.145 (b)(3)(iii)). As for all
notices, they must be in writing and may be delivered by U.S. Postal Service, commercial
delivery service, or hand delivery. The NESHAP does not permit notification by telephone or
telephone facsimile (fax) machines. The information contained in the notice for an

emergency renovation is the same as that required for all notices, except that the following

additional information is also required:



TEXAS

TRUST
TERRITORY
OF THE
PACIFIC

VERMONT

Mr. Robert A. Lansford

State Coordinator, Division of
Emergency Management

Texas Department of Public
Safety

Box 4087, N. Austin Station

Austin, Texas 78773

(512) 465-2000 x 2138

Mr. Charles Jordan
Chief, Office of Planning

and Statistics
Office of the High Commissioner
Trust Territory Headquarters
Saipan, Mariana Islands 96950

011-670-322-9333

Mrs. Lorayne Frank

Director, Division of

Comprehensive Emergency
Management

Department of Public Safety

1543 Sunnyside Avenue

Salt Lake City, Utah 84105-0136

(801) 533-5271

Mr. George Lowe

Director, State of Vermont

Department of Public Safety

Division of Emergency Management
Waterbury State Complex

103 S. Main Street

Waterbury, Vermont 05676

(802) 244-8721
FAX (802) 244-8655

51

Mr. Joe E. Milner

Director, Texas Department of
Public Safety and Division
of Emergency Management

Box 4087, N. Austin Station

Austin, Texas 78773

(512) 465-2000 x 370

Same

Mr. D. Douglas Bodiero

Commissioner, Department
of Public Safety

4501 South 2700 West

Salt Lake City, Utah 84119

(801) 965-4463

Mr. Charles E. Bristow

Commissioner, Department of
Public Safety

103 S. Main Street

Waterbury, Vermont 05676

(802) 244-8718





representative who ordered the demolition, the date the order was issued, and the date on
which the demolition is ordered to begin.

As specified in the applicability provisions of 61.145 (a)(3), government-ordered
demolitions are exempt from all but the following emission control procedures:

* The requirement to strip or place in leak-tight wrapping all asbestos covered or
coated facility components that were removed in sections or units (61.145 (c)(4)).

+ The requirements for large facility components to be removed where the asbestos
will not be disturbed (61.145 (c)(5)).

* The requirements for RACM that has been stripped or removed (61.145 (c)(6)).
* The requirements during periods of freezing temperatures (61.145 (c)(7)).

* The requirement for a person trained in the provisions of the NESHAP to be on site
(61.145 (c)(8)).

* The requirement that all goverment-ordered demolitions adequately wet the portion
of the facility that contains RACM during the wrecking operation (61.145 (c)(9)).

C. Waste Disposal (61.150)

For facilities that have been demolished in response to government orders, Section
61.150 (a)(3) requires that the resulting asbestos-containing waste be adequately wetted at all
times after demolition and kept wet during the handling and loading for transport to a
disposal site. Such waste may be transported and disposed of in bulk. All the rest of the
waste disposal provisions in section 61.150 apply, including the requirements to dispose of
the waste as soon as practical at an appropriate site, to properly mark vehicles used to
transport the waste, to maintain waste shipment records, to provide a copy of the waste
shipment record to the disposal site, and to report any waste for which a copy of the waste
shipment record signed by the disposal site owner or operator is not received from the

disposal site within the prescribed amount of time.

11



Guidelines for Catastrophic Emergency Situations
Involving Asbestos

U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460

September 1991



REFERENCES

U.S. Environmental Protection Agency. Asbestos in Buildings: A National Survey of
Asbestos-Containing Friable Materials. EPA 560/5-84-006. Washington, DC. June
1984. 260 p.

U.S. Environmental Protection Agency. Additional Analysis of EPA’s 1984 Asbestos
Survey Data. EPA 560/5-88-010. Washington, DC. September 1988. 87 p.

New York City Department of Environmental Protection. Assessment of the Public’s
Risk of Exposure to In-place Asbestos. New York, NY. December 1, 1988.



C. Mapping Asbestos Locations
State and local NESHAP coordinators should, to the extent feasible, determine the
presence and location of asbestos-containing facilities before a catastrophic emergency occurs.
During an emergency, knowing which structures in the community contain asbestos and
which do not could save time, reduce the risk associated with entering unsafe structures, and
avoid the unnecessary cost of treating the building as though it contained asbestos when in
fact it did not. Even at the facility level, knowing what equipment, for example, is insulated
with asbestos could be useful in responding to an accident involving that equipment. Sources
of location information are discussed below and are separated into those for asbestos milling,
manufacturing, and fabricating; and demolition and renovation.
1. Asbestos Milling, Manufacturing, and Fabricating
The most obvious source of information on the location of asbestos mills,
manufacturers, and fabricators is EPA’s own compliance inspection records for these sources.
Where enforcement of the NESHAP has been delegated, the responsible state or local
government should have in its files the names and locations of these sources.

Additional information on asbestos sources may be available from agencies responsible

for enforcement of occupational safety and health regulations. OSHA enforcement agencies

will have information on many of the same sources covered by asbestos air pollution
regulations. Typically, however, OSHA rules cover a much wider range of sources than those
covered by the asbestos NESHAP. Many of these additional sources may not be of as great a
concem because they frequently include sources that handle small amounts of asbestos or
asbestos-containing products, such as automobile brake servicing shops and the field

fabrication of asbestos products for construction.





LOUISIANA.

Mr. James H. "Mike" Molloy
Executive Director, Kentucky
Disaster and Emergency Services
Boone Center, Parkside Drive
Frankfort, Kentucky 40601

(502) 564-8680

Mr. Robert Warren, Director
Office of Emergency Preparedness
Department of Public Safety

P.O. Box 66536, Audubon Station
Baton Rouge, Louisiana 70896

(504) 342-5470

Mr. David D. Brown
Director, Maine Emergency

Management Agency
State Office Bldg., Station 72
Augusta, Maine 04333

(207) 289-4080
FTS: 289-4080

Mr. Phil Kabua

Disaster Control Officer,
Republic of the Marshall
Islands

Majuro, Marshall Islands 96960

93-011-692-9-3234

Brig. Gen. Michael W.
Davidson

The Adjutant General and

State Director of Disaster
and Emergency Services

Boone National Guard Center

Frankfort, Kentucky 40601

Attn: James H. Molloy

(502) 564-8558

Col. (Ret.) Marlin A.
Flores
Deputy Secretary

Department of Public Safety
P.O. Box 66614

Baton Rouge, Louisiana
70896

(504) 925-6117

Gen. Emest Park

The Adjutant General and
Commissioner, Department
of Defense and Veterans
Services

Maine National Guard

Camp Keyes

Augusta, Maine 04333

(207) 626-4225

Mr. Phil Kabua

Republic of the Marshall
Islands

Majuro, Marshall Islands

96960



samples. In addition, consideration should be given to arranging for overnight analysis of
bulk samples. This would allow for the results from the analysis of samples collected one
day to be available to enforcement personnel at the beginning of the next day.

6. Emergency Exemptions

Although the NESHAP contains provisions for emergency renovations and

ordered demolitions, the nature of the emergency may require some flexibility in enforcing
the NESHAP. For example, the NESHAP requires a written notice beforehand, but in no
case later than the following working day, for ordered demolitions. It is conceivable that,
under catastrophic emergency conditions, normal mail delivery services and transportation
systems would be so disrupted as to make it impossible to deliver a written notice in the time
period specified by the NESHAP. The responsible NESHAP coordinator should be aware
that situations may arise that make strict application of the NESHAP difficult, if not

impossible. While it is not possible to know in advance all the scenarios that may require

flexibility in applying the NESHAP, it would be advisable to discuss predictable problems

with agency management as well as with other NESHAP enforcement agencies at the

appropriate Regional, state, or local level.



Region V

Mr. Arlyn F. Brower

Regional Director

Federal Emergency Management Agency
175 W. Jackson Boulevard (Fourth Floor)
Chicago, Illinois 60604

FTS: 363-5501; Commercial: (312) 408-5501; FAX: 363-5521

Region VI

Mr. Bradley M. Harris

Regional Director

Federal Emergency Management Agency
Federal Regional Center

800 N. Loop 288, Room 206

Denton, Texas 76201-3698

FTS: 749-9104; Commercial: (817) 898-9104; FAX: 749-9290

Region VIL

Mr. S. Richard Mellinger

Regional Director

Federal Emergency Management Agency
Old Federal Office Building

911 Walnut Street, Rom 200

Kansas City, Missouri 64106

FTS: 759-7061; Commercial: (816) 283-7061; FAX: 759-7504
Region VII

Dr. Marian L. Olson

Regional Director

Federal Emergency Management Agency

Denver Federal Center, Building 710

Box 25267
Denver, Colorado 80225-0267

FTS: 322-4812; Commercial: (303) 235-4815; FAX: 322-4976

37



New York City survey showed that tall office buildings most frequently contained asbestos
and also contained the greatest amount of asbestos. Table 1 presents a summary of the
survey results regarding the percent of buildings with asbestos and the amount of asbestos per
building.

b. Schools

Information on asbestos in schools is available at the local level as well as

at the state level. Under AHERA, schools are required to inspect their facilities for the
presence of asbestos, document the location of the asbestos and keep this information on site
as well as forward a copy to the responsible state agency. In some states, the state
department of education will retain copies of this information, while in other states, the state
agency responsible for asbestos programs is the designated state agency responsible under
AHERA. Each school must also keep a copy of the inspection results in its files. The
Regional Asbestos Coordinators for each region can provide information on state contacts for
information on asbestos in schools. A list of the addresses and telephone numbers for the
Regional Asbestos Coordinators is given in Appendix D.

c. Local Building Permit Agencies

In most communities, a building permit is required prior to any new

construction. As part of the application for a building permit, the building plans are reviewed
by the permitting agency to determine that the structure is designed and will be constructed in
accordance with applicable building codes. Building plans usually specify that a particular
code or standard will be met which, for example, relates to a certain fire rating. The
specifications which accompany the building plans state what materials are to be used to meet
the code specified in the plans. If asbestos was recommended for a certain application in
order to meet the relevant codes, the specifications would contain that information. A copy

23



codes 20 through 39. TRIS would seem to be a useful database for either emergency
response planning or identifying facilities where friable asbestos might be expected following
an emergency.

C. CERCLA

Hazardous air pollutants regulated under the Clean Air Act (CAA) are also
regulated as hazardous substances under CERCLA. CERCLA provides the authority and
funds for emergency government response to hazardous substance releases into the
environment, including the ambient air and allows the federal government to recover the costs
of responding to and cleaning up hazardous substance releases.

Emissions of reportable quantities (RQs) of listed substances must be reported to the
National Response Center in Washington. The RQ for asbestos is 1 lb. (0.454 kg) of pure
asbestos (40 CFR 302.4).

As noted earlier, the Gramercy Park response was conducted under New York City law
and was not regulated under the asbestos NESHAP. A federal response could have been
carried out under CERCLA, however, if that had been needed.

D. OSHA

The OSHA rules on asbestos (29 CFR 1910.1001 and 29 CFR 1926) are applicable
in catastrophic emergencies. OSHA rules specify a permissible exposure limit for asbestos,
respiratory protection, work practices, and engineering controls for worker protection. There

are no exemptions for emergencies in the Act.



MARYLAND

Mr. David A. McMillion

Director, Maryland Emergency
Management Agency

Two Sudbrook Lane, East

Pikesville, Maryland 21208

(301) 486-4422
FTS 486-4422

MASSACHUSETTS

MICHIGAN

MICRONESIA

Mr. Robert J. Boulay
Director, Massachusetts Civil
Defense Agency and Office of

Emergency Preparedness
400 Worcester Road
Framingham, Massachusetts
01701

(508) 820-2000

Dave Charney

State Director

Emergency Management Division
Michigan State Police

300 S. Washington Square,
Suite 300

Lansing, Michigan 48913

(517) 373-6271 - FTS 372-7853

Mr. Ehson D. Johnson
Director, Disaster Control
Officer
The Federated States
of Micronesia 96941

(011) 691-9228

Brig. Gen. John Barshay

Maryland Military
Department

National Guard

Sth Regiment Armory

29th Division Street

Baltimore, Maryland 21201

(301) 764-4004

Mr. Charles V. Barry

Secretary, Department of
Public Safety

One Ashburton Place,
Room 2133

Boston, Massachusetts

02108

(617) 727-7775

Col. R. T. Davis

Acting Director, Department
of State Police and State
Division of Emergency
Services

714 S. Harrison Road

East Lansing, Michigan

48823

(517) 337-6157

Same



NEVADA

NEW
HAMPSHIRE

NEW JERSEY

NEW MEXICO

Mr. Robert R. King

Director, Nevada Division
of Emergency Services

Military Department

2525 S. Carson Street,

Capitol Complex

Carson City, Nevada 89710

(702) 885-4240

Colonel George Iverson
Director, Governor’s Office

of Emergency Management
State Office Park South
107 Pleasant Street
Concord, New Hampshire 03301

(603) 271-2231
FAX (603) 225-7341

Maj. Joseph J. Craparotta

Deputy State Director

Office of Emergency Management
New Jersey State Police

P.O. Box 7068

West Trenton, New Jersey 08628

(609) 882-2000

Mr. Thomas H. Johnson

Director, Technical and
Emergency Support Division

Department of Public Safety

4491 Cerrillos Road

P.O. Box 1628

Santa Fe, New Mexico 87504

(505) 827-3375

47

Maj. Gen. Robert Dwyer
The Adjutant General
Military Department

2525 S. Carson Street,
Capitol Complex

Carson City, Nevada 89710

(702) 887-7302

Same

Justin J. Dintino

Superintendent of State
Police

P.O. Box 7068

‘West Trenton, New Jersey

08628

(609) 882-2000

Col. Robert Kemble

Secretary, Office of the
Secretary

Department of Public Safety

4491 Cerrillos Road

P.O. Box 1628

Santa Fe, New Mexico 87504

(S05) 827-3370



The date and the hour that the emergency occurred,

A description of the sudden, unexpected event, and

An explanation of how the event caused an unsafe condition, or would cause

equipment damage or an unreasonable financial burden (61.145 (b)(4)(xv)).

Emergency renovation operations are subject to the emission control procedures of

section 61.145 (c). These procedures include removal of asbestos from the facility before any
activity that would disturb or break up the asbestos, wetting the asbestos during stripping,
keeping the asbestos that has been removed or stripped wet until collected or contained for
disposal, and having an individual on-site who is trained in the provisions of the NESHAP.
There are no exemptions from emission control procedures for emergency renovation
operations.

2. Government-Ordered Demolitions

The NESHAP exempts certain types of demolitions from some of the

notification and emission control requirements. The applicability provisions in section 61.145

(a)(3) state that a facility that is being demolished as a result of a government order that is

issued because the facility is structurally unsound and in danger of imminent collapse, is
exempt from the following:
* Notification requirement to provide 10 working days advance notice. Notice for
such demolitions must be provided as early as possible before demolition and not

later than the following working day.

Notification requirement to include the scheduled starting and completion dates of
* asbestos removal.

All other notification requirements apply. In addition, the notice for government-ordered

demolitions must include the name, title, and authority of the State or local government