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A NATE OF CALIFORNIA—HEALTH AND WELFARE CY EDMUND G. BROWN JR.,Governor DEPARTMENT OF HEALTH SERVICES 714/744 P STREET SACRAMENTO, CA 45814 (9 16) 324-1807 r=y3 July 19, 1982 JAL r Mr. James N. Siegfried, Manage r j d:A l 1 D',S r LCT Community Environmental Standards Manville Service Corporation Ken-Caryl Ranch Denver, CO 80217 Dear Mr. Siegfried: This is in response to your letter of March 29, 19$2 and the enclosed report describing your asbestos-cement pipe- rejects and process wastes (M-03) generated at your Stockton, California plant. These submitted materials constitute an application for a nonhazardous classification pursuant to Section 66305, Chapter 30, Division 4, Title 22, California Administrative Code. Asbestos-cement pipe is manufactured using a wet process. A pumpable slurry is formed by blending portland cement (50%) with sand and silica flour (35%) and asbestos fiber (15%) in aqueous suspension. These ingredients are formed into a thin wet sheet by filtration and wrapped onto the circumference of a rotating round steel core. The pipe is cured first by air followed by steam in an auto- clave unit. The wastes can be categorized as follows: I . Product rejects - fully cured pipe, pieces, and couplings. The character of these wastes does not differ from actual finished product. 2. Process rejects - nonfriable machine cleanings and pipe rejected prior to autoclaving. Except for shape these kinds of wastes would be very similar to finished product. 3. Wrapping wastes - bags that contained imported asbestos and are likely to retain a light layer of fiber dust on the inner lining. The bags are folded and housed in a plastic wrapper which is then heat-shrunk to encapsulate re- sidual fibers. 4. Basin sediments - inert process ingredients which pass through the filtration septum and the wastewater system. These materials , which are ultimately de- posited as sediments in settling basins, are relatively high in reactive cement and low in fiber content due to preferential interception at the point of filtration. Waste types 1 , 2, and 3 above are not considered hazardous asbestos wastes because they are nonfriable and contain no significant amount of free particulate asbestos fiber. As such, they do not possess the potential of producing airborne, respir- able asbestos fibers. The department considers an asbestos waste to be hazardous only if this potential exists due to friability or particulate form.