Re: Asbestos Contaminated with Rad Materials

[LIPTONW@detroitedison.com]

You wrote: 
 
Can someone clarify just what type and form of asbestos is considered 
hazardous waste? 
 
Asbestos is NOT a hazardous waste, since it is not listed and does not have 
one of the specified characteristics of 40 CFR 261 (the EPA's Resource 
Conservation and Recovery Act (RCRA) regulations).  This is important, since 
it means that radioactively contaminated asbestos is NOT a mixed waste, and
is 
generally accepted at Barnwell.  However, it IS an EPA hazardous air
pollutant 
under 40 CFR 61 (NESHAPS) and 1 pound or more IS a "hazardous substance" 
(Reportable Quantity) under 40 CFR 302 and 49 CFR 172.  There are also 
extensive EPA and OSHA regulations governing asbestos cleanup projects.  It
IS 
also a DOT hazardous material.  There are a few applicable proper shipping 
names (Asbestos, White Asbestos, Blue Asbestos, and Brown Asbestos).  These 
regulations generally only apply to "friable" asbestos, which is generally 
considered to be asbestos in a form where there is the potential to inhale 
asbestos fibers.  There is the caution, however, that abatement projects
often 
turn nonfriable asbestos into friable asbestos.   
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com