607. A covered manufacturing facility uses more than 10,000 pounds of friable asbestos in a diaphragm cell process during the course of a reporting year. During the process, material containing friable asbestos is washed in a treatment unit where it coagulates and is removed by a pressure filter. The filter cake containing asbestos is wetted with ethylene glycol, and the resulting filter cake/ethylene glycol mixture is subsequently landfilled on-site in a closed container. Should the facility report the placement of this asbestos in a landfill as a 'release to land' on the Form R?
EPA interprets 'friable' under EPCRA section 313 '...as being crumbled, pulverized, or reducible to a powder with hand pressure' (53 FR 4519; February 16, 1988). Facilities are required to report releases or other waste management of only the friable form of asbestos. The facility will report zero releases of friable asbestos to land because the ethylene glycol/asbestos mixture is not considered to contain friable asbestos since the asbestos contained therein is wet (i.e., with ethylene glycol). The facility would report the amount of friable asbestos that is treated in Part II, Section 8.6. Note that because ethylene glycol is also a listed toxic chemical, the facility would also need to consider this chemical for threshold determinations and release and other waste management calculations.