United States
           Environmental Protection
           'Agency
Offici of Pesticide^
and Toxic Substances
Washington, DC 20460
EPA 560/5-85-024
June 1985
           Toxic Substances
           Guidance for Controlling
           Asbestos-Containing
           Materials in Buildings
jo not remove. This document
Should be retained in the EPA
legion 5 Library Collection.

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GUIDANCE FOR CONTROLLING ASBESTOS-CONTAINING
                 MATERIALS IN  BUILDINGS

                        1985 EDITION
                     Exposure Evaluation Division
                      Office of Toxic Substances
                 Office of Pesticides and Toxic Substances
                  U.S. Environmental Protection Agency
                       Washington, D.C. 20460
                     U.S. Environmental Prelection Agency
                     Region 5, Library (PL-12J)
                     77 West Jackson Boufevacd, 12th Floor
                     Chicago, it 60604-3590

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                           NOTE TO SCHOOL DISTRICTS
The regulations at 40 CFR §763.114(a)(5) require that schools with asbestos-containing material
retain one copy of "Asbestos-Containing Materials in School Buildings: A Guidance Document"
Parts 1 and 2, also known as the orange books, in the school's administrative office (EPA No.
C00090).

This book, "Guidance for Controlling Asbestos-Containing Materials in Buildings" (the purple
book), may be kept in lieu of the document "Asbestos-Containing Material in School Buildings:
A Guidance Document," Parts 1 and 2 (orange books), to satisfy the  requirement at 40 CFR
§763.114(a)(5). Please note that schools must continue to retain copies of the "Guide for Reduc-
ing Asbestos  Exposure" found at 40 CFR §763.111(b), which is also  required by 40 CFR
§763.114(a)(5).

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                                  TABLE OF CONTENTS
                                                                                  Page
ACKNOWLEDGEMENTS	 vii
SUMMARY OF GUIDANCE	 S-1
CHAPTER 1— BACKGROUND ON EXPOSURE TO ASBESTOS INSIDE BUILDINGS	 1-1
     1.1   Asbestos-Containing Materials in Buildings	 1-1
     1.2  Levels of Airborne Asbestos in Buildings and Other Settings	 1-2
     1.3  Diseases Associated with Exposure to Asbestos	 1-2
     1.4  Federal Regulations Regarding Asbestos in Buildings	 1-5
CHAPTER 2 — DETERMINING IF ASBESTOS-CONTAINING MATERIAL (ACM) IS
              PRESENT IN BUILDINGS  	 2-1
     2.1   Planning the Survey	 2-1
         2.1.1  Assembling the Survey Team 	 2-1
         2.1.2 Obtaining Cooperation	 2-4
     2.2  Conducting the Survey	 2-4
         2.2.1 General Survey Elements	 2-4
         2.2.2 Procedures for Sprayed- or Troweled-on Surfacing Materials	 2-4
         2.2.3 Procedures for Pipe and Boiler Insulation	 2-6
         2.2.4 Procedures for Other ACM 	 2-8
CHAPTER 3— ESTABLISHING A SPECIAL OPERATIONS AND MAINTENANCE (O&M) PROGRAM 3-1
     3.1   The Purpose of a Special O&M Program	 3-1
     3.2  Who Should Participate	 3-1
     3.3  Program Elements 	 3-1
         3.3.1  Special Practices for Sprayed- and Troweled-on Surfacing Materials	 3-2
         3.3.2 Special Practices for Pipe and Boiler Insulation 	    3-3
         3.3.3  Special Practices for Other ACM	3-6
CHAPTER 4 — ASBESTOS CONTROL BEYOND SPECIAL OPERATIONS AND
              MAINTENANCE	 4-1
     4.1   Assessment Information	 4-2
         4.1.1  Potential Fiber Release	 4-2
         4.1.2 Air Monitoring	 4-3
     4.2  The Assessment Process	 4-6
         4.2.1  Sprayed- and Troweled-on  Surfacing Materials  	 4-6
         4.2.2 Pipe and Boiler Insulation	 4-10
         4.2.3 Other Types of ACM	 4-12
     4.3   Further Considerations  in  Selecting a Schedule  for Abatement	 4-12
                                           in

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                                  TABLE OF CONTENTS
                                       (Continued)
                                                                                   Page
CHAPTER 5 — ABATEMENT METHODS: CHARACTERISTICS AND RECOMMENDED
              WORK PRACTICES	 5-1
    5.1   Abatement Methods for Sprayed- or Troweled-on Surfacing Material  	 5-1
         5.1.1   Removal, Disposal, and Replacement	 5-3
         5.1.2  Enclosure	 5-6
         5.1.3  Encapsulation with Sealants	 5-8
    5.2  Abatement Methods for Pipe and Boiler Insulation  	 5-8
    5.3  Abatement Methods for Other Types of ACM	 5-10
CHAPTER 6 — CONDUCTING ABATEMENT PROJECTS	 6-1
    6.1   Who Should Do the Abatement Work	6-1
    6.2  Selecting a Contractor	 6-2
    6.3  Managing the Work  	 6-3
    6.4  Releasing the Contractor	 6-4
         6.4.1   Visual Inspection	 6-4
         6.4.2  Air Testing	 6-4
         6.4.3  Quality Assurance   	 6-8
REFERENCES	 R-1
                                  LIST OF APPENDICES
Appendix A.   Asbestos-Containing Materials Found in Buildings	A-1
Appendix B.   Common Units Used in Measuring Airborne Asbestos Concentrations 	 B-1
Appendix C.   USEPA National Emission Standards for Hazardous Air Pollutants
             (NESHAPS) Asbestos Regulations 	 C-1
Appendix D.   Addresses of  EPA NESHAPS Contacts and Regional
             Asbestos Coordinators	 D-1
Appendix E.   Phone Numbers for Obtaining Information and EPA Publications	 E-1
Appendix F.   Occupational  Health and Safety (OSHA) Asbestos Regulations	F-1
Appendix G.   Specifications for Sampling Materials and Selecting a
             Qualified Laboratory to Analyze for Asbestos	 G-1
Appendix H.   Definition and Description of Factors for Assessing the
             Need for Corrective Action	 H-1
Appendix I.   Example Building Inspection Form	 1-1
                                            IV

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                                    TABLE OF CONTENTS
                                         (Continued)
                                                                                       Page
Appendix J.   Recommended Specifications and Operating Procedures for the
             Use of Negative Pressure Systems for Asbestos Abatement	J-1
Appendix K.  Checklist for Determining Contractor Qualifications	  K-1
Appendix L.   Guide Specifications for Abatement Projects	  L-1
Appendix M.  Detailed Specifications for Sampling and Analyzing Airborne Asbestos	  M-1
Appendix N.  Glossary  	  N-1

                                      LIST OF TABLES
Table   1.    Factors for Assessing  Potential Fiber Release	  4-3
Table   2.    Assessment Table for  Surfacing Materials	  4-7
Table   3.    Comparison of Asbestos Abatement Methods for Surfacing Materials	  4-8
Table   4.    Assessment Table for  Pipe and Boiler Insulation	  4-11
Table   5.    Comparison of Methods for Measuring Airborne Asbestos	  6-6

                                      LIST OF FIGURES
Figure  1.    Examples of Asbestos-Containing Materials Found  in  Buildings	  1-3
Figure  2.    Comparison of Measured Airborne Asbestos Concentrations in
             Three Settings	  1-4
Figure  3.    Composition of the ACM Survey Team	  2-3
Figure  4.    Initial  Steps in an ACM Survey	  2-5
Figure  5.    Survey Procedures for Sprayed- or Troweled-on Surfacing Material   	  2-7
Figure  6.    Survey Procedures for Pipe and Boiler Insulation	  2-9
Figure  7.    Example Assessment  Characteristics of  Asbestos Containing Materials	  4-4
Figure  8.    An Example of the Effect of a Change in Building Use  	  4-5
Figure  9.    Asbestos-Containing Material Located Above a Suspended Ceiling	     5-2
Figure 10.    Construction of Containment  Barriers	  5-4
Figure 11.    An Asbestos Removal  Project	5-5
Figure 12.    An Asbestos Enclosure Project	  5-7
Figure 13.    An Asbestos Encapsulation Project	  5-9
Figure 14.    Custom Containment Bags for Repairing or Removing Pipe Insulation	  5-10
Figure G-1.    Sampler/Container	  G-1
Figure J-1.    Sketch of HEPA-Filtered Exhaust Unit 	  J-2
Figure J-2.    Examples of Negative  Pressure Systems	  J-6

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                                    ACKNOWLEDGEMENTS


Many individuals contributed their time and effort to this revision of "Guidance for Controlling Friable
Asbestos-Containing Materials in Buildings" (EPA 560/5-83-002), commonly referred to as the "Blue Book."
Their assistance is gratefully acknowledged. The primary authors were Dale Keyes  of Environmental
Sciences, Bertram Price of National Economic Research Associates, Inc., and Jean Chesson of Battelle
Memorial Institute. They prepared the initial draft and revised it to reflect a series of detailed reviews. Joan
Blake (Office of Toxic Substances, Exposure Evaluation Division), with the support of Cindy Stroup  and
Joseph Breen, served as Task Manager and directed the report preparation process. The material presented
here reflects two years of experience with the original Blue Book and incorporates the comments and sug-
gestions of local school officials, health and environmental scientists, architects,  engineers, and staff at
EPA Headquarters and in the Regional Offices. This document was developed and refined through a series
of meetings with three groups—a working group consisting of EPA staff from the Office of Toxic Substances
(OTS); a larger review group consisting of the OTS working group, EPA staff from  the Office of Research
and  Development (ORD), and Regional Asbestos Coordinators from EPA Regional Offices; and a peer
review group consisting of school officials and technical specialists who are not EPA employees.

The OTS working group provided thorough and timely criticism, suggestions, and assistance in formulating
the presentation of more complex issues.  The working group members were:

    Joan  Blake, Exposure Evaluation Division

    Joseph Breen, Exposure Evaluation Division

    Elizabeth Dutrow, Exposure Evaluation Division

    Dave Mayer, Asbestos Action Program

    Cindy Stroup,  Exposure Evaluation  Division


The  larger EPA review group met early in the process to  discuss the revision and to decide which areas
needed to be emphasized. In addition  to persons listed  above, the group consisted of:

    Carol Bass, Office of Toxic  Substances/Exposure Evaluation  Division

    Michael Beard, Office of Research and Development/Environmental Monitoring Systems Laboratory

    Wolfgang Brandner, EPA Region VII

    William Cain, Office  of Research and  Development/Water Engineering Research  Laboratory

    Mark Hague, Office of the Comptroller/Budget Division

    Paul  Heffernan, EPA Region I

    Jim Littell,  EPA Region  IV

    Amy  Moll,  Office of Toxic Substances/Economics and Technology Division

    Tony  Restaino, EPA Region V

    John  Rigby, Office of Toxic Substances/Chemical Control Division
                                              VII

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    Sims Roy, Office of Air Quality Planning and Standards/Emission Standards Engineering Division

    Steve Schanamann, Office of Pesticides and Toxic Substances/Asbestos Action Program

    Lorie Roeser, Office of Pesticides and Toxic Substances/Office of Compliance Monitoring

    Roger Wilmoth, Office of Research and  Development/Water Engineering Research Laboratory



The members of this group were also active participants in the three-day peer review meeting. We thank
all of them for their  contributions. The Regional Asbestos Coordinators deserve special recognition. Their
insights and suggestions based on experience gained in  the field were invaluable.

The peer review group  members were:

    Steven  Biegel,  National Institute of Building Sciences, Washington, DC

    William Brown, Asbestos Coordinator of  Baltimore City, Baltimore,  Maryland

    Judith Hunt, Broward County Florida Schools, Oakland Park, Florida

    Art Langer,  Mt. Sinai School of Medicine, City University of New York, New York,  New York

    Hal  Levin, University of California, Berkeley, Santa Cruz, California

    Ernest Lory, Naval Civil Engineering Laboratory, Port  Hueneme, California

    Marshall Marcus, Marcus Associates, Hopewell, Virginia

    Chris T.  Matthews, Naval Facility Engineering Command,  Alexandria,  Virginia

    William Nicholson, Mt. Sinai School of Medicine, City University of New  York, New York, New York

    James Parker,  General Services Administration, Washington, DC

    Bernard Rafferty, School District of Philadelphia, Pennsylvania

    John Rodousakis, Veterans Administration, Washington, DC

    Don Ryan,  House Appropriations  Committee, Washington, DC

    Robert Sawyer, M.D., Guilford, Connecticut

    George Smart, George M.  Smart  Architects,  Inc.,  Raleigh, North Carolina

    James Trombley,  Hoskins-Western-Sonderagger, Inc.,  Lincoln, Nebraska

    Kenneth M. Wallingford, National  Institute for Occupational Safety  and Health, Cincinnati, Ohio
Their active participation in the peer review meeting, the speed with which they reviewed all drafts, and
their commitment and dedication to the task of disseminating information and guidance for the control
of exposure to airborne asbestos are greatly appreciated.
                                              VIII

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Other contributors participated at various stages in the report preparation. In particular, we wish to thank
Project Officer Joseph Carra (Office of Toxic Substances, Exposure Evaluation Division), and Susan Vogt
(Office of Pesticides and Toxic Substances, Asbestos Action Program).

Terri Stiteler of Battelle deserves special recognition for organizing the review meetings and directing the
preparation and distribution of drafts. Karen Krasner managed the document through its many revisions
and Sharon Congdon assisted in the  production of the final version. We also thank other support staff
at EPA and at Battelle for contributing to the successful completion of the project.
                                               IX

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                                   SUMMARY OF GUIDANCE
INTRODUCTION

Airborne asbestos contamination in buildings is a significant environmental problem. Various diseases have
been linked with industrial exposure to airborne asbestos, and the extensive use of asbestos products in
buildings has raised concerns about exposure to asbestos in nonindustrial settings. Surveys conducted
by the Environmental Protection Agency (EPA) estimate that asbestos containing materials can be found
in approximately 31,000 schools and 733,000 other public and commercial buildings in this country.

The presence of asbestos in a building does not mean that the health of building occupants is necessarily
endangered. As long as asbestos-containing material (ACM) remains in good condition and is not disturb-
ed, exposure is unlikely. When building maintenance, repair, renovation or other activities disturb ACM,
or if it is damaged, asbestos fibers are released creating a potential hazard to building occupants. Although
not required to do so by federal law, the prudent building owner will take steps to limit building occupants'
exposure to airborne asbestos. In  1983 EPA prepared and distributed "Guidance  for Controlling Friable
Asbestos-Containing Materials in Buildings" (USEPA 1983a). Since this guidance was published, EPA has
gathered additional information and has gained valuable experience through its continuing Asbestos-in-
Buildings Program. The guidance document has been substantially revised to incorporate this new infor-
mation and to reflect the  comments and suggestions of building owners and other readers. EPA offers
building owners guidance to understand the technical issues, determine if asbestos is present in a building,
plan a control program, and  choose the course of further action if necessary.

This summary is divided into  two parts. The first is an introduction to the problem of asbestos in buildings
and summarizes the material that  is presented  in Chapter 1. The second part of the summary provides
a concise outline of the remainder of the report.  It lists the major steps needed to determine whether asbestos
is present in a building (Chapter 2), establish a special operations and maintenance (O&M) program (Chapter
3), assess the need for further action (Chapters 4 and 5), and  carry out an abatement project (Chapter
6).  It is  intended as a checklist for the building owner.
ACM IN BUILDINGS

ACM in buildings is found in three forms: (1) sprayed or troweled on ceilings and walls (surfacing material);
(2) in insulation around hot or cold pipes, ducts, boilers, and tanks (pipe and boiler insulation); and (3)
in a variety of other products such as ceiling and floor tiles and wall boards (miscellaneous materials).
In general, ACM in the first two categories is of greatest concern, especially if it is friable. (Friable material
can be crumbled, pulverized, or reduced to powder by hand pressure.)

Testing for ACM is required in primary and secondary schools only. (Regulations are specified in "The
Friable Asbestos-Containing Materials in Schools; Identification and Notification Rule.") At present, no parallel
rule applies to other public or commercial buildings.  Further, no Federal regulations require abatement
actions (repair or  removal, enclosure, encapsulation).

The OSHA (Occupational Safety and Health Administration) regulations specifying work practices and the
EPA rules governing the handling and disposal of asbestos apply to abatement actions. State regulations
on these issues vary and may  be more stringent than federal requirements.


ASBESTOS CONTROL ACTIVITIES

The following pages outline the steps that a building owner should take to control asbestos. Each step
is described in more detail in the  body of the report.
                                              S-1

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Survey to See if Asbestos is Present

    •  Appoint an asbestos program manager and assemble a survey team.

    •  Check building records for evidence of asbestos- containing surfacing materials, pipe and boiler
      insulation, or miscellaneous ACM.

    •  Locate  and document all ACM identified in building records.

    •  Inspect the building for friable materials on walls or ceilings. Inspection means touching walls
      and ceilings.

    •  Inspect the building for insulation on pipes and boilers. Inspection means looking at pipes and
      boilers.

    •  Be persistent. Friable materials may be hidden behind dropped ceilings or partitions.

    •  Collect samples of friable ceiling and wall materials following EPA procedures.

    •  Collect samples of pipe and boiler wrap if the insulation is exposed. Otherwise, assume the
      insulation contains asbestos.

    •  Send samples to a qualified laboratory for analysis by polarized light microscopy (PLM). If the
      samples show  more than one percent asbestos, the building contains ACM.

    •  Document all findings.


Establish a Special Operations and Maintenance (O&M) Program

    •  Obtain  cooperation of building maintenance and custodial managers.

    •  Educate building occupants and employees about ACM.

    •  Train custodial and maintenance workers in special cleaning techniques and  maintenance
      precautions.

    •  Clean the building thoroughly using wet cleaning and HEPA-vacuum techniques.

    •  Repeat the cleaning monthly (near surfacing materials) or semi-annually (near wrapped
      insulation).

    •  Take special precautions before starting maintenance and construction work.

    •  Inspect ACM at least twice a year for evidence of damage or deterioration.

    •  Continue the O&M program until all ACM is removed.


Assess the ACM to Determine the Need for Further Action

    •  Assess the likelihood of fiber release from the ACM by evaluating its current condition and the
      potential for future disturbance, damage or erosion.

    •  Determine:
                                             S-2

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      —  The need for further action.

      —  When it should be done.

      —  What abatement method should be used.


Conduct Abatement Actions if Needed

    •  Hire an abatement contractor or, if in-house capabilities are available, use building staff.

    •  To select a contractor:

      —  Write precise contract specifications.

      —  Check references.

      —  Conduct interviews.

      —  Review insurance coverage.

      —  Select the "best" contractor, not necessarily the lowest bidder.

    •  To Manage the work:

      —  Inspect the work site at least four times a day to insure compliance with all prescribed work
          practices  and worker protection measures. These include:

          *  Construction of a containment barrier around the entire work area, or the use of contain-
            ment bags for wrapped insulation.

          *  Use of coveralls and respirators by the workers.

          *  Provision of worker change and decontamination facilities.

      —  Stop abatement work immediately if any condition of the worksite appears to be hazardous.

      —  Release the contractor only after:

          *  The work site has been thoroughly cleaned at least twice.

          *  The work site passes a visual test for abatement completion and cleanliness.

          *  The work site passes a test for airborne  asbestos.
                                              S-3

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         CHAPTER 1. BACKGROUND ON EXPOSURE TO ASBESTOS INSIDE BUILDINGS

Construction materials containing asbestos have been used extensively in schools and other buildings.
The concern about exposure to asbestos in these buildings is based on evidence linking various respiratory
diseases with occupational exposure in the shipbuilding, mining,  milling, and fabricating industries. The
presence of asbestos in a building does not mean that the health of building occupants is endangered.
If asbestos-containing material (ACM) remains in good condition and is unlikely to be disturbed, exposure
will be negligible. However, when ACM is damaged or disturbed — for example, by maintenance or repairs
conducted without proper controls — asbestos fibers are released. These fibers can create a  potential
hazard for building occupants.

This chapter describes ACM found in buildings and the  potential health risks to occupants of buildings
where ACM is present. Also, federal regulations addressing asbestos in buildings are briefly summarized.
SUMMARY

    ACM in Buildings: Three forms of asbestos are typically found in buildings: (1) sprayed- ortroweled-
    on surfacing materials; (2) insulation on pipes, boilers, and ducts; and (3) miscellaneous forms,
    such as wallboard, ceiling tiles, and floor tiles. EPA surveys estimate that 31,000 schools and 733,000
    public and commercial buildings contain friable (easily crumbled) ACM. Friable ACM and ACM
    disturbed during maintenance, repair or renovation are of greatest concern from an exposure
    perspective.

    Levels of Airborne  Asbestos in Buildings and Other Settings: Prevalent levels of airborne
    asbestos inside buildings with ACM may be 10 to 100 times higher than outdoor levels. However,
    these indoor levels are typically 10,000 to 100,000 times lower than levels in asbestos industry
    workplaces where asbestos-related diseases have been well-documented.

    Asbestos-Related Disease: Most people with asbestos-related diseases (asbestosis, lung cancer,
    and mesothelioma) were exposed to high levels of asbestos while working in asbestos industries
    prior to 1972. Extrapolation of the relationship between exposure level and disease indicates that
    only a small proportion of people exposed to low levels of asbestos will develop asbestos-related
    diseases. Smokers, children, and young adults are at somewhat greater risk.

    Federal  Regulations Regarding Asbestos in Buildings: Current regulations (1) restrict the use
    of most asbestos products in new buildings, (2) specify work practices for removal of ACM from
    buildings, and (3) require the identification of  asbestos in schools. There are no exposure stan-
    dards for nonindustrial settings, and no regulations requiring corrective actions in buildings with
    ACM.
1.1   Asbestos-Containing Materials in Buildings

Asbestos may be found in cement products, acoustical plaster, fireproofing textiles, wallboard, ceiling tiles,
vinyl floor tiles, thermal insulation, and other materials.1 EPA surveys estimate that 31,000 schools and
733,000 federal and commercial buildings have ACM in one form or another (USEPA 1984a, 1984b). ACM
has been grouped into three categories: (1) sprayed- or troweled-on materials on ceilings, walls, and other
surfaces; (2) insulation on pipes, boilers, tanks, ducts, and other equipment; and (3) other miscellaneous
products. (Examples of ACM are shown in Figure 1.) Material in the first two categories can be friable,
that is, it can be crumbled,  pulverized, or reduced to powder by  hand pressure. Most ACM in the third
category is nonfriable.
  Descriptions of these and other types of products containing asbestos appear in Appendix A.
                                              1-1

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Friable materials are more likely than nonfriable materials to release fibers when disturbed or damaged.
Although nonfriable ACM is of less immediate concern, it should not be ignored. Fibers will be released
if nonfriable material is cut, drilled, sanded, or broken  during building repairs or renovation.


1.2  Levels of Airborne Asbestos in Buildings and Other Settings

Levels of airborne asbestos in the asbestos industry workplace are substantially higher than levels found
outdoors or in buildings with ACM. Figure 2 shows levels measured in the three settings: asbestos insula-
tion plants before the 1972 Occupational Safety and Health Administration (OSHA) exposure standards,
schools with ACM, and outdoor urban areas.2 The  range of values in each category reflects differences
in location, source of asbestos, and variability in asbestos measurements. Concentrations may exceed the
upper limits of these ranges for short periods if, for example, manufacturing equipment malfunctions, in-
sulating material is pierced with a sharp  object, or asbestos-coated surfaces are disturbed by the impact
of  a ball or similar object.

Figure 2 shows that prevalent concentrations of airborne asbestos in a sample of school buildings were
approximately 10 to 100 times higher than outdoors. At the same time, asbestos levels in the schools were
10,000 to 100,000 times lower than pre-1972 levels  in asbestos insulation workplaces.3


1.3  Diseases Associated with Exposure to Asbestos

Much of what is known about asbestos-related diseases comes from studying workers in the various asbestos
industries. Exposure to levels of airborne  asbestos typical of the asbestos workplace prior to 1972 has been
linked with a debilitating lung disease called asbestosis; a rare cancer of the chest and abdominal lining
called mesothelioma; and cancers of the lung, esophagus, stomach, colon, and other organs. In 1972 federal
exposure standards were imposed.

The relationship between exposure level and health risk is complex. The potential for disease appears
to be related to the physical and chemical characteristics of asbestos fibers as well as to the concentration
of  fibers in the air. Data on asbestos workers indicate that the risks of asbestosis,  lung cancer, and
mesothelioma decrease in direct proportion to a decrease in total asbestos dose. Because there is no direct
information on health risks from exposure to asbestos in buildings with ACM, the risks are estimated by
extrapolation from studies of asbestos industry workers  (Nicholson 1984, NRC  1984, The Royal Commis-
sion of Ontario  1984). The estimates indicate that only a small proportion of people exposed to  low levels
of  asbestos will develop asbestos-related diseases. However, combining smoking with occupational ex-
posure to asbestos increases the lung cancer rate  above the rate due to either smoking or asbestos ex-
posure alone. Also, asbestos exposure in children is of special concern: since they have a greater remain-
ing lifespan than adults, their lifetime risk of developing mesothelioma is greater. Avoiding unnecessary
exposure to  asbestos is prudent.
 2 For comparison, all data are expressed in nanograms per cubic meter (ng/m3) units. Concentrations of asbestos
  fibers in the air are measured in terms of either the number of fibers per unit volume (typically, fibers per cubic
  centimeter) or the mass per unit volume (typically, ng/m3). A nanogram is one-billionth of a gram. See Appendix
  B for a simple explanation of measurement units used for airborne asbestos concentrations.
 3 The data in Figure 2 should be interpreted with caution. Estimated concentrations in asbestos workplaces are bas-
  ed on measurements of airborne fibers using the method specified by OSHA (phase contrast microscopy), while
  the levels in schools and outdoors were measured by a different method (transmission electron microscopy). Com-
  parisons of measurements obtained by the two methods are based on certain assumptions (see footnote to Figure
  2). Measurement of airborne asbestos fibers is a complex subject and is discussed in more detail in Section 4.1.2.
                                               1-2

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                                                                   rr
                                                                           ?>x
                                                "       -        '*"     ^
   Friable, fluffy sprayed-on material
Friable, cementitious sprayed-on or troweled

material (acoustical plaster)
Nonfriable wallboard with friable sprayed-on

material behind
                                                                    Pipe lagging
        Figure 1. Examples of asbestos-containing materials found in buildings.
                                           1-3

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    Figure 2.  Comparison of measured airborne asbestos concentrations in three settings.*
Asbestos insulation
workplaces before 1970
(NIOSH 1972)
                                            r_~jr_~_~
School buildings
(USEPA 1983b, Chesson
et al. 1985 a,b)

Outdoor ambient air
(USEPA 1983b, Chesson
et al. 1985 a,b)
                                                  I
                                       I
I
J_
I
J
01        10        10        100      1,000     10,000

                              Nanograms per cubic meter
                                                                             100,000   1,000,000  10,000,000
         -Range-
       25%
         Percentiles
  *Levels in asbestos workplaces were derived from measurements using phase contrast microscopy (PCM) while
   levels in school buildings and outdoors were measured using electron microscopy (EM) PCM and EM
   measurements are not directly comparable PCM measures all fibers whereas EM can distinguish between
   asbestos and nonasbestos fibers. In addition, EM has a better capability than PCM for detecting small fibers. In
   order to translate the workplace PCM measurements (expressed as fiber counts) into values of asbestos mass
   (nanograms) that are approximately comparable to EM measurements, 30 fibers were assumed to equal one
   nanogram  This value is an average obtained from many comparisons of PCM and EM measurements taken at
   the same location (industrial settings) and time. Values for individual samples range from about 10 fibers per
   nanogram of asbestos to well over 100 fibers per nanogram, depending on the average size of fibers and the
   relative number of asbestos and nonasbestos fibers in the air (Versar 1 980 and William Nicholson, personal
   communication, 1982).
                                                 1-4

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1.4  Federal Regulations Regarding Asbestos in Buildings

Both EPA and OSHA have published regulations to reduce asbestos exposure. EPA regulations focus on:
(1) application and removal of ACM in new or remodeled buildings, and (2) identification of friable asbestos
in schools. EPA also regulates the industrial emission of asbestos fibers and the disposal of asbestos waste.
OSHA addresses worker protection in the workplace.

The first EPA regulations were issued in 1973 under the National Emission Standards for Hazardous Air
Pollutants (NESHAPS), as authorized by the Clean Air Act. The first regulations were directed largely  at
the asbestos industries, but also partially banned spray-applied ACM in new buildings, and established
procedures for handling ACM during demolition. The regulations were revised in 1975 and  1978 to cover
building renovations, the use of all types of insulating ACM in new buildings, and asbestos emissions from
ACM waste disposal.4

Of particular interest to owners of buildings with ACM are the following regulations:

   •  When a building is demolished — or more than 260 linear ft. of asbestos pipe insulation or 160
      sq. ft. of asbestos surfacing material are removed during renovation — advance notice must be
      filed  with the EPA regional office and/or the state, giving:

      — name  and  address of the building owner or manager;
      — description and location of the building;
      — scheduled  starting and completion dates of ACM removal;
      — description of the planned removal methods; and
      — name, address, and location of disposal site.

   •  ACM can be removed only with wet removal techniques (see Section 5.1). Dry removal is allowed
      only  under special conditions and only with written EPA approval.

   •  No visible emissions of dust are allowed during removal, transportation, and disposal  of ACM. (The
      wet removal techniques described in Section 5.1 are designed to satisfy this requirement.)

The entire text of the NESHAPS regulations appears in Appendix C.  Before beginning any ACM removal
or building demolition, the building owner should review the NESHAPS requirements in detail. More infor-
mation can be obtained from the regional NESHAPS contact. Addresses and telephone numbers of the
contacts are found in Appendix D.

The second set of EPA regulations is in the "Friable Asbestos-Containing Materials in Schools; Identifica-
tion and Notification Rule," (40 CFR Part 763)5 promulgated under the Toxic Substances Control Act. Known
as the Asbestos-in-Schools rule, it requires all primary and secondary schools, both public and private, to:

   •  inspect, sample, and analyze friable  materials for asbestos;

   •  document all findings; and

   •  inform all school employees and the school's parent-teacher organization (or parents, if there is no
      organized  group) of the location of friable ACM,  and provide each custodial worker with a copy  of
      the EPA publication, "A Guide for Reducing Asbestos Exposure," as published in the FEDERAL
      REGISTER (40 CFR Part 763).
 "The complete set of regulations was repromulgated on April 5, 1984.
 5 The deadline for compliance with the Rule was June 28, 1983. A copy of the Rule is available from EPA. See
  Appendix E.
                                             1-5

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The OSHA regulations were first issued in 1972 and modified in 1976. They specify airborne exposure stan-
dards for asbestos workers, engineering and administrative controls, workplace practices, and medical
surveillance and worker protection requirements. In 1982, OSHA announced its intention to tighten the
exposure standards. (See the "Calendar of Federal  Regulations," published in the FEDERAL REGISTER
[47 FR 1807].)6 The OSHA regulations apply to all workplace activities involving asbestos, including removal
of ACM from buildings. Future OSHA regulations may include separate exposure standards for ACM removal
operations. The complete text of the OSHA regulations appears in  Appendix F.

OSHA's worker exposure standards are inappropriate for nonindustrial settings. First, the standards were
set to protect workers only against asbestosis, which does not occur at  the lower exposure levels typical
of buildings with ACM. Second, the measurement technique that determines OSHA compliance does not
distinguish between asbestos  and nonasbestos fibers and does not measure the small asbestos fibers
typically found in  buildings with ACM.

The measurement problem is  not a major shortcoming in industrial settings where most airborne fibers
are expected to be  asbestos.  However, only a few fibers in building air are asbestos, and the OSHA
measurements may be misleading. (Other limitations of the OSHA technique further confound the measure-
ment of airborne asbestos in buildings. See Section 4.1.2 for a more detailed discussion of measuring air-
borne asbestos.)
 6 As of July 1, 1976, the OSHA standards were set at 2 fibers per cubic centimeter averaged over 8 hours and a
  ceiling level not to exceed 10 fibers per cubic centimeter "at any time." OSHA is now evaluating the effect of lower-
  ing the 8-hour standard to either 0.5 or 0.2 fibers per cubic centimeter in order to protect workers against cancer,
  as published in the FEDERAL REGISTER (47 FR 1807).
                                              1-6

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              CHAPTER 2. DETERMINING IF ASBESTOS-CONTAINING MATERIAL
                              (ACM) IS PRESENT IN BUILDINGS


To determine if ACM is present in a building, examine construction records and conduct a thorough in-
spection of building materials. If asbestos is not present, no further action is required. If asbestos is found,
however, a control program should be initiated. In either case, workers and other building occupants will
be concerned. The building owner must be prepared to explain the purpose of the survey, its results, and
plans for controlling ACM if it  is present.


SUMMARY

    Planning the Survey: A plan for conducting the ACM survey should include assembling the survey
    team and gaining cooperation of building management. The plan should also include a public in-
    formation program.

    Conducting the Survey: The survey consists of checking building records and inspecting the
    building for evidence of ACM. Specific procedures differ for the three types of ACM, and may in-
    clude sampling and analysis of suspect materials.

2.1   Planning the Survey

The survey has four components:

    •  Reviewing building records for references to asbestos used  in construction or repairs;

    •  Inspecting materials throughout the building to identify those that may contain asbestos;

    •  Sampling suspect materials for laboratory confirmation that asbestos is present; and

    •  Mapping the locations of all confirmed or suspected ACM.

Thorough  planning is essential because:

    •  The survey must provide accurate  and reliable information;

    •  Questions from building occupants or the public about the survey and about asbestos in general
      must be answered quickly and responsively;

    •  Complete, accurate, unambiguous documentation of the survey and all test results is critical; and

    •  If ACM is  found,  the building owner must be prepared to initiate special operations and
      maintenance (O&M) practices  immediately, and to develop other controls to minimize health
      risks (see Chapter 3).

The importance of a well-planned public communications program cannot be over- emphasized. Asbestos
is an exceptionally emotional issue. A building owner must clearly understand the purpose of the survey
in order to anticipate and address the concerns of building occupants and the public.


2.1.1  Assembling the Survey Team

Owners are ultimately responsible for asbestos-related problems in their buildings. The owner should ap-
point an asbestos program manager to direct all asbestos-related activities. The asbestos program manager
                                             2-1

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must be able to identify and assess the expertise of the diverse personnel required for an effective team.
The asbestos program manager should communicate directly with the building owner. In addition, if ACM
is present, the asbestos program manager will oversee the development of the asbestos control program,
and provide information to the public. The  manager needs to become familiar with the use of ACM in
buildings, the potential for building contamination by airborne asbestos, the health risks to building oc-
cupants, and options for controlling ACM. The manager needs a general understanding of all the issues
in order to review technical tasks and judge whether they are being performed properly. If the building
owner has no experienced person on his staff,  he should consider hiring a qualified consultant.

The program manager's responsibilities include:

   • Implementing a training program for the ACM survey if the survey is to be conducted in-house;

   • Selecting a technical advisor to conduct the ACM survey if an outside consultant is  needed;

   • Selecting a laboratory to analyze samples of material from the building;

   • Designing a system to document all information about asbestos in the building; and

   • Developing a communications package for discussions with building occupants and others.

If ACM is found, the asbestos program manager should also be prepared to initiate special operations
and maintenance (O&M) practices (see Chapter 3), assess the need for other control measures (see Chapters
4 and 5), and oversee abatement projects if additional corrective action is necessary (see Chapter 6). The
duties and responsibilities of the  manager continue until all ACM is removed from the building.

An asbestos survey team should be assembled under the direction of the asbestos program manager. Figure
3 illustrates the organization of the team. The building architect, the facilities (or physical plant) manager,
and the head of building maintenance are obvious choices due to their knowledge of building records and
facilities. Maintenance and engineering staffs may also be team members since they likely will conduct
the survey. If an  outside technical advisor is hired to conduct the survey,  he or she would be a member
of the team. Other team members acting primarily as special advisors would include an attorney and a
risk manager (i.e., a person responsible for  insurance).

As indicated by Figure 3, the asbestos program manager should seek advice from the EPA Regional Asbestos
Coordinator (RAC). (Addresses and telephone numbers for the 10 RACs are listed in Appendix D.) The
RAC has information on ACM surveys, technical advisors, consultants, laboratories for analyzing samples
of building materials, training programs, and abatement contractors.

The asbestos program manager should attend one of the asbestos control training courses offered by univer-
sities and private organizations. Currently, EPA-sponsored programs are offered in conjunction with Georgia
Institute of Technology, Kansas University and Tufts University. The RAC is the best source of further infor-
mation regarding these programs  and others which may be available in each Region.

If a technical advisor will be hired to conduct the survey, the asbestos program manager should require
evidence of experience and/or training. Examine references, especially those provided by other building
owners. Be sure the advisor has a reputation for being thorough. Most survey errors involve overlooking
building areas where there could be ACM. Asbestos control advisors include specially trained engineers,
architects, and industrial hygienists.

If ACM is found, the technical advisor may assist with the continuation of the control program. In that case,
the advisor should also have experience  in developing a special O&M program, assessing the need for
additional corrective action, and monitoring abatement projects. Additional information on selecting technical
advisors is provided in Chapters 3 and 4.
                                              2-2

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2.1.2   Obtaining Cooperation

An ACM survey will be successful only if everyone in building management cooperates. Most importantly,
the building owner must be convinced that exposure to asbestos is potentially a serious problem, and that
a careful survey for ACM is needed. The asbestos program manager and the building owner must have
a close working relationship.

Beyond this, cooperation must be obtained from building maintenance, operations, and planning person-
nel. A survey for ACM can disrupt normal building activities. Occupants will be concerned and curious.
The survey team must be prepared to discuss the purpose of the survey in a way that is realistic, yet does
not cause undue anxiety. Questions requiring a lengthy response should be referred to the program manager.


2.2  Conducting the Survey

The survey involves a review of building records and  an inspection  of the building for friable materials.
The inspection is the more important component of the survey since building records are often incomplete
and unreliable. Whenever the presence of asbestos is in  doubt, prudence is recommended: treat the material
as if it  contains asbestos.
2.2.1   General Survey Elements

Figure 4 illustrates the survey steps. Begin by reviewing building records to see if ACM was specified at
any stage. Although building records are often unreliable, they are a useful starting point. Check the original
plans, shop drawings, remodeling records, and work change orders. Appendix A is a list of the most com-
mon uses and types of ACM in buildings since 1960. If any of these items appears in the records, assume
that asbestos is in the building. Identify ACM mentioned in building records by type: (1) troweled- or sprayed-
on surfacing  material, (2) pipe and boiler insulation, or  (3) other miscellaneous ACM.

Next, inspect the building for ACM identified in the building records. Determine if the materials are friable
and record the findings. They may be sampled and analyzed to confirm the presence of asbestos. Thoroughly
inspect all areas of the building for friable materials and sample them. The specific procedures for inspec-
tion and sampling vary depending on which of the three types of material  are involved. The sampler of
building materials should wear a respirator to prevent inhalation of fibers. (See Section 5.1 for information
on respirators.)


2.2.2   Procedures  for Sprayed-  or Troweled-on Surfacing  Materials

Surfacing materials can be friable or nonfriable. Friable forms are either very fibrous and fluffy (sometimes
like cotton candy) or granular and cementitious (review Figure 1). Since friable materials are more likely
than nonfriable materials to release fibers when disturbed, the first priority is to identify those friable sur-
facing  materials that contain asbestos. As shown in Figure 5,  the first step  is to locate ACM specified in
building records and determine its friability. Then, identify all friable surfacing materials in the building
and take samples to be analyzed for asbestos.


2.2.2.1  Surfacing  Materials Identified as ACM in Building Records

Begin by locating any acoustical plaster or other surfacing materials that, according to building records,
contain asbestos. Rub these materials to see if they crumble or produce a light powder. If so, consider
them friable.  (When disturbing material that may contain asbestos,  the inspector should wear protective
equipment.) Either assume that these materials contain asbestos, or sample and analyze them, as discussed
below.  Record the location and degree of friability.


                                              2-4

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                                                         <3-


                                                         I
                                                         O)
2-5

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2.2.2.2   Other Surfacing Materials That May Contain Asbestos

Conduct a thorough building inspection for friable materials on walls, ceilings, beams, ducts, and any other
surface. Rub the material to see  if it is  friable.  Following Figure 5, group any friable  material into
"homogeneous" areas for further study.1 A homogeneous area contains friable material that seems by tex-
ture and color to be uniform. If materials appearing uniform were installed at different times, designate
the two materials as distinct homogeneous areas.

Once homogeneous areas of friable materials have been delineated and recorded on floor  plans, collect
samples of the materials and send them to a qualified laboratory. Sampling and analysis should be con-
ducted according to the following guidelines:2

   •  Appoint a coordinator to oversee the entire sampling and analysis operation and quality assurance
      program. The asbestos program manager or technical expert may  assume this role.

   •  Choose a qualified laboratory to analyze the samples (see Appendix G.2). The approved method
      of bulk sample analysis for asbestos is polarized light microscopy. In certain cases,  X-ray dif-
      fraction may be required to confirm the  presence of asbestos.

   •  Collect at least three core samples  of material in each homogeneous sampling area. Select
      sampling locations that are representative of the homogeneous area. (Either select  locations
      evenly distributed throughout the area or choose the locations by a  random selection method
      such as the one described in USEPA 1980a. It is important that three samples not be collected
      in the same location.) Remember that everyone taking samples should wear a respirator.

   •  Collect at least 1  quality control (QC) sample per building or 1 QC sample per 20  samples,
      whichever is larger.  A QC  sample is taken from  the area abutting a  regular sample.  (The two
      samples are referred to as "side-by-side samples.") The QC sample should be analyzed at a
      second laboratory to confirm the results of  the primary laboratory.

   •  Label all samples with an  identifying code and keep a code log. To  avoid bias, the laboratory
      analyst should not know the origin of the samples.

   •  Asbestos is present if the  material  analyzed is more than one percent asbestos by weight.

Record the results of the sampling and analysis program and save the records indefinitely. If no asbestos
is found in these materials, no further action is necessary for this category of ACM. If asbestos is present,
then  an asbestos control program should  be developed as described in Chapters 3 and 4.


2.2.3  Procedures for Pipe and Boiler Insulation

Asbestos-containing insulation is found on  equipment containing hot air or  liquid — pipes, boilers, tanks,
and sometimes ducts. These insulation materials  may be a chalky  mixture of magnesia and asbestos,
preformed fibrous asbestos wrapping, asbestos fiber felt, corrugated paper, or insulating cement. In most
cases, the  insulating material is covered with a protective jacket of cloth, tape, paper,  metal, or cement.3
  1 The Asbestos-in-Schools rule allows schools to skip the sampling and analysis steps by assuming that any friable
   materials found in the building contain asbestos. The location of all friable materials must be documented and all
   affected parties must be notified whether asbestos is assumed to be present or confirmed by laboratory analysis.
   Nonfriable materials are not addressed by the Asbestos-in-Schools rule.
  2 Specific procedures for sampling and analyzing friable materials in schools were presented in the Asbestos-in-
   Schools rule. These procedures are consistent with the guidelines presented here.
  3 ACM sprayed on ducts should be considered surfacing  material.
                                              2-6

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                                                 Locate ACM
                                             Specified in Building
                                                  Records
Document*
Asbestos
Materials
 Friable?
                                                                                                 Document
                                              Inspect Building for
                                               Friable Materials
                       Is Asbestos
                       Present any
                         where?
                                                           Identify Homogeneous
                                                             Areas and Sample
                                                             Send Samples to
                                                           Laboratory for Analysis
                                                                  by PLM
                     Initiate Special
                     O&M Program
                  Is
               Asbestos
              Present any-
                where?
Document
               Figure 5.   Survey procedures for sprayed- or troweled-on surfacing material.
     *These materials can be sampled and analyzed to confirm that they do contain asbestos, and that a
     special O&M program is needed.
                                                    2-7

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Boiler insulation may consist of thermal bricks (refractory) or asbestos insulating blankets, and is usually
covered with finishing cement. Occasionally, asbestos millboard is used as a stiff outside covering on
removable boiler insulation.

Figure 6 outlines how to inspect pipe and boiler insulation. Start in the boiler room and follow air and water
distribution systems throughout the building. Building plans should indicate the location of pipes and ducts.

If the insulation is in good condition, leave it undisturbed. Sampling is  not recommended in this case: in-
stead, assume that the insulation contains asbestos. An EPA nationwide survey of federal, residential, and
commercial buildings revealed that approximately 16 percent (20 percent of those constructed before 1970)
contained asbestos pipe or boiler insulation. An exception to this rule is yellow or pink wrapped insulation.
The color is usually a clear indication of fibrous glass rather than asbestos material. Even here, however,
pipe elbows and joints will likely contain asbestos.

Sample the insulation materials from the damaged or exposed ends or other parts. Procedures for sampl-
ing and analyzing insulation materials are similar to those for surfacing materials:

    •  Identify homogeneous areas (i.e., sections of insulation that appear uniform in color and texture).

    •  Take samples for each homogeneous area  where the  insulation is damaged  or exposed.
      Remember, all persons taking samples should wear a respirator.

    •  Submit samples to a qualified laboratory for analysis  (see Appendix G).

As indicated in Figure 6, the presence (assumed or confirmed) or absence (confirmed) of asbestos should
be documented in permanent records. If asbestos is present, an asbestos control program should be im-
plemented as described in Chapters 3 and 4. If the presence of asbestos has been assumed, sampling
and analysis may be useful for confirmation before any additional corrective action is taken.
2.2.4  Procedures for Other ACM

Most ACM in this category (e.g., wallboard, ceiling tile, floor tile) is hard and nonfriable, and sampling would
damage it and release fibers needlessly. Information on asbestos in these materials comes mainly from
building records or building personnel. Document the presence and location of these materials in perma-
nent records, and proceed with an asbestos control program as described in Chapter 3.
                                              2-8

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Inspect Building
for Pipe & Boiler
   Insulation
     Is the
   Insulation
   Exposed?
   Assume  It
Contains Asbestos
                                                                             Document
    Sample
    Exposed
     Areas
Send Samples to
  a Laboratory
  for Analysis
                                              Document
     Initiate
  Special O&M
     Program
                Figure 6.  Survey procedures for pipe and boiler insulation.
                                           2-9

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 CHAPTER 3. ESTABLISHING A SPECIAL OPERATIONS AND MAINTENANCE (O&M) PROGRAM
If ACM is found in a building, a special O&M program should be implemented as soon as possible. An
O&M program is recommended for each type of ACM: surfacing material, pipe and boiler insulation, and
miscellaneous materials. Although many of the procedures are the same, certain steps vary according
to the type of ACM.
SUMMARY

    Purpose of a Special O&M Program: The program is designed to (1) clean up asbestos fibers
    previously released, (2) prevent future release by minimizing ACM disturbance or damage, and
    (3) monitor the condition of ACM. The program should continue until all ACM is removed or the
    building is  demolished.


    Who Should Participate: The asbestos program manager, the manager of building maintenance,
    and the supervisor of the custodial staff are key participants in the  O&M program.


    Program Elements: The program should alert workers and building occupants to the location of
    ACM, train custodial and maintenance personnel in proper cleaning and maintenance, implement
    initial and periodic cleaning using special methods (for surfacing  materials and pipe and boiler
    insulation only), establish a process that assures ACM is not disturbed during building repairs and
    renovations, and periodically re-inspect areas  with ACM.


3.1  The Purpose of a Special O&M Program

The discovery of ACM in buildings raises two concerns: (1) how to clean up asbestos fibers previously
released, and (2) how to avoid ACM disturbance or damage. The special O&M program  addresses both
of these issues, with procedures tailored to each of the three types of ACM.


3.2  Who Should Participate

The asbestos program manager develops and implements the special O&M program. He or she may serve
as coordinator or delegate that responsibility to the facilities manager or other appropriate employee.

The manager of building maintenance and the custodial staff supervisor are the other key participants.
Both must support the program and must generate the same sense of commitment in their staff. A special
O&M program will increase cleaning and maintenance work; staff dedication is necessary for an effective
program.

Trained building inspectors also participate in all special O&M programs. These inspectors may be the
ones who made the initial inspection for ACM. They may or may not be members of the in-house custodial
or maintenance staff. In the O&M program, they will be inspecting the condition and other characteristics
of the ACM as described in Section  4.1.
3.3   Program Elements

Several aspects of a special O&M program are the same for all three types of ACM. For clarity and com-
pleteness, these steps are repeated in the description of each program.
                                            3-1

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3.3.1  Special Practices for Sprayed- and Troweled-on Surfacing Materials

ACM that is sprayed or troweled on ceilings and walls is often the main source of airborne asbestos fibers
in the building. Areas covered by ACM tend to be large. If the material is friable, fibers are slowly released
as the material ages.

To reduce the level of released fibers and to guard against disturbing or damaging the ACM, the following
measures should  be  taken:


  Documentation, Education, and Training

  The O&M program coordinator should:

    • Record the exact location of ACM on building documents (plans, specifications, and drawings).

    • Inform all building occupants and maintenance and custodial workers about the location of ACM
      and caution them against disturbing or damaging the ACM (e.g., by hanging plants or mobiles
      from the ceiling, or pushing furniture against walls). Be sure to give this information to new oc-
      cupants and employees.

    • Require all maintenance and custodial personnel to wear a half-face  respirator with disposable
      cartridge filters or a more substantial respirator (see Section 5.1) during the initial cleaning and
      whenever they come in contact with ACM.

    • Train custodial workers to clean properly and maintenance workers to handle ACM safely. (As
      noted in Chapter 2, EPA is sponsoring three pilot training programs.  Contact the RAC for infor-
      mation on these and other  training programs.)


  Initial Cleaning

  Custodial staff should:

    • Steam-clean all carpets throughout the building or vacuum  them with a High Efficiency Par-
      ticulate Air (HEPA)-filtered vacuum cleaner, but never with a conventional vacuum cleaner. Spray
      vacuum cleaner bags with water before removal and discard in sealed plastic bags according
      to EPA regulations for removal and disposal of asbestos (see Section 5.1 and USEPA 1985a).
      Discard vacuum  filters in a similar manner.

    • HEPA-vacuum all curtains and books. Discard vacuum bags and filters in sealed plastic bags
      according to EPA regulations for disposal of asbestos waste.

    • Mop all noncarpeted floors with wet mops. Wipe all shelves and other horizontal surfaces with
      damp cloths. Use a mist spray bottle to keep cloths damp. Discard cloths and mopheads in sealed
      plastic bags according to EPA regulations for disposal of asbestos waste.


  Monthly  Cleaning

  Custodial staff should:

    • Spray with water  any debris found near surfacing ACM and place the debris in  plastic bags
      using a dust pan. Rinse the pan with water in a utility sink. Report presence of debris immediately
      to the O&M program coordinator.
                                             3-2

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    •  HEPA-vacuum all carpets.

    •  Wet-mop all other floors and wipe all other horizontal surfaces with damp cloths.

    •  Dispose of all  debris, filters, mopheads, and cloths in plastic bags according to EPA regulations
      for disposal of asbestos waste.


  Building Maintenance

  The special O&M  program coordinator should:

    •  Ensure that recommended procedures and safety precautions will be followed before authoriz-
      ing construction and maintenance work involving surfacing ACM (see Section 5.1).  Specifically,
      containment barriers should be erected around the work area and workers should wear coveralls
      as well as respirators.

  Maintenance staff should:

    •  Clear all construction, renovation, maintenance, or equipment repair work with the O&M pro-
      gram coordinator in advance.

    •  Avoid patching or repairing any damaged surfacing ACM until the ACM has been assessed by
      the  asbestos  program manager.

    •  Mist filters in  a central air ventilation system with water from a spray bottle as the filters are
      removed. Place the filters in plastic bags and dispose of them according to EPA  regulations.


  Periodic Inspection

  Building  inspectors should:

    •  Inspect all ACM materials for damage or deterioration at least twice a year and report findings
      to the O&M program coordinator. (See Chapter 4 for detailed information on assessing ACM.)

    •  Investigate the source of debris found by the custodial staff.

  Custodial and  maintenance staff should:

    •  Inform the O&M program coordinator when damage to ACM is observed or when debris is cleaned
      up.

An illustrated EPA pamphlet, "Asbestos in Buildings—Guidance for Service and Maintenance Personnel"
(USEPA 1985a), may be especially useful in publicizing and initiating the special O&M program. Contact
the  RAC or call the EPA toll-free line for copies of the pamphlet (see Appendix E for telephone numbers).

The special O&M program should continue until all surfacing ACM is removed. Overtime, the special O&M
program may need to be  altered if the ACM is enclosed or encapsulated  (refer to Section 5.1).


3.3.2  Special Practices for Pipe and Boiler Insulation

Asbestos-containing pipe  and boiler insulation typically is a less significant source of airborne asbestos
fibers than surfacing  ACM. Unless damaged, protective jackets around such insulation prevent fiber release.
                                              3-3

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Thus, the special O&M program for pipe and boiler insulation focuses on alerting workers to its location,
inspecting the protective jacket (and pipe joints or elbows) for damage, and taking precautions prior to
building construction activities. The program also includes repair and selected special cleaning practices.


  Documentation, Education, and Training

  The O&M program coordinator should:

    • Record the exact location of asbestos-containing insulation on building  documents (plans,
      specifications, and drawings).

    • Inform maintenance and custodial workers about the location of asbestos-containing insulation,
      and caution them about disturbing it.

    • Post signs reading,  "Caution — Asbestos," on boilers, tanks, pipes, and ducts with asbestos-
      containing insulation.

    • Require all maintenance and custodial  personnel to wear at least a half-face respirator with
      disposable HEPA cartridge filters (see Section  5.1) during initial cleaning and whenever they
      come in contact with asbestos-containing insulation.

    • Train custodial workers to clean properly and maintenance workers to handle ACM safely. (As
      noted in Chapter 2, EPA is sponsoring three pilot training programs. Contact the RAC for more
      information on these and other programs.)


  Initial Cleaning


  Custodial  staff should:

    • Clean carpets in rooms containing  heating, cooling, air-handling, and similar equipment that
      has asbestos-containing insulation. Use a HEPA-filtered vacuum cleaner or steam cleaner. Discard
      filters in sealed plastic bags according to EPA regulations for removal and disposal of asbestos.

    • Wet-mop all other floors in rooms with asbestos-containing insulation. Wipe all shelves and other
      horizontal surfaces with damp cloths. Use a mist spray bottle to keep cloths damp. Discard cloths
      and mopheads in sealed plastic  bags according to  EPA regulations for removal and disposal
      of asbestos.

    • HEPA-vacuum all curtains in rooms with asbestos-containing insulation, and discard  vacuum
      filters in sealed plastic bags according to EPA regulations for removal and disposal of asbestos.
  Semiannual Cleaning

  Custodial staff should:

    • Spray with water any debris found near asbestos-containing insulation, and place the debris
      in a plastic bag using a dustpan.  Clean the pan with water in a utility sink. Report presence
      of debris immediately to the O&M program coordinator.

    • HEPA-vacuum all carpets in rooms with asbestos-containing  insulation.
                                              3-4

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    • Wet-mop all other floors and dust all other horizontal surfaces with damp cloths in rooms with
      asbestos-containing insulation.

    • Seal all debris, vacuum bags, vacuum filters, cloths, and mopheads in plastic bags for disposal
      according to EPA regulations for asbestos waste.
  Maintenance

  The special O&M program coordinator should:

    •  Ensure that recommended procedures and safety precautions will be followed before authoriz-
       ing construction and maintenance work involving pipe and boiler insulation (see Section 5.2).
       Specifically, containment barriers or bags should be positioned around the work area and workers
       should wear coveralls and respirators. Insulation damaged during construction and maintenance
       activities should be repaired with non-asbestos mastic, new protective jackets, and/or replace-
       ment insulation.

    •  Authorize repair of minor insulation damage with non-asbestos mastic, new protective jackets,
       and/or non-asbestos insulation following recommended repair techniques and precautions (see
       Section 5.2).

    •  Authorize large-scale abatement only after a complete assessment of the asbestos-containing
       insulation (see  Section 5.2).


  The maintenance staff should:

    •  Clear all construction, renovation, maintenance,  or equipment repair work with the O&M pro-
       gram coordinator  in advance.


    •  Avoid patching and repair work on insulation until the ACM has been assessed by the asbestos
       program manager.


  Periodic Inspection

  Building  inspectors  should:

    •  Inspect all  insulation for damage or deterioration at least twice a year and report findings to
      the O&M program coordinator. (See  Chapter 4 for detailed information on  assessing ACM.)

    •  Investigate  the  source of debris found by the custodial staff.

  Custodial and maintenance staff should:

    •  Inform the O&M program coordinator when damage to the insulation is observed or when debris
      is cleaned  up.

The illustrated EPA pamphlet, "Asbestos in Buildings—Guidance for Service and Maintenance Person-
nel" (USEPA 1985a), may be useful for the special O&M program for pipe and boiler insulation. The O&M
program should continue until all asbestos-containing  insulation (including materials on  pipe joints and
elbows) is removed  and  replaced with another type of  insulation.
                                              3-5

-------
3.3.3  Special Practices for Other ACM

Most ACM that is neither surfacing material nor pipe and boiler insulation is hard and nonfriable. This type
of ACM releases fibers only when manipulated (e.g., cut, drilled, sawed) or damaged. The special O&M
program is designed to alert workers to the location of ACM, and to avoid its disturbance or damage.


  Documentation, Education, and Training

  The O&M program coordinator should:

    •  Record the exact location of these types of ACM on building documents (plans, specifications,
      and drawings).

    •  Inform maintenance and custodial workers about the location of ACM and caution them about
      disturbance or damage.

    •  Train maintenance workers to handle ACM safely. (As noted in Chapter 2, EPA is sponsoring
      three pilot training programs. Contact the RAC for information on these and other programs.)
  Maintenance

  The O&M program coordinator should:

    •  Ensure that recommended procedures and safety precautions will be followed before authoriz-
      ing construction or maintenance work involving ACM. Specifically, containment barriers should
      be erected  around the construction and  maintenance  work area  and workers should wear
      coveralls as well as respirators. All tools should be equipped with HEPA-filtered vacuum devices.

  The maintenance staff should:

    •  Clear all construction, renovation, maintenance, or equipment repair work with the O&M pro-
      gram coordinator in advance.

    •  Avoid removing, sanding, or stripping floor tiles containing asbestos. If tiles are removed, do
      not sand asbestos backing material remaining on the floor.


  Periodic Inspection

  Building inspectors should:

    •  Inspect all ACM for damage or deterioration at least twice a year, and report findings to the O&M
      program coordinator.

  Custodial and maintenance staff should:

    •  Report any ACM damage to the O&M program coordinator.

The special O&M  program for miscellaneous ACM should continue until all  ACM is removed.
                                             3-6

-------
   CHAPTER 4. ASBESTOS CONTROL BEYOND SPECIAL OPERATIONS AND MAINTENANCE
If a building contains ACM, implementing a special O&M program will remove asbestos fibers and limit
further fiber release. Once the program is operational, the need for additional asbestos control or abate-
ment should be considered. Three questions need to be answered:

    •  Is abatement necessary?

    •  When should abatement be done?

    •  What abatement method should be used?

In some situations, assessing the need for abatement is a straightforward process. Badly damaged ACM
in public areas should be removed immediately. ACM in good condition with virtually no chance of being
disturbed except under controlled conditions (e.g., during scheduled repairs) requires no additional action,
at least not immediately. (An example of the latter is tightly bound, undamaged ACM insulation wrapped
around heating or water pipes.) Deciding how to control ACM is  complicated; assessment  requires
simultaneous consideration of the type and condition of the material, timing  and alternative abatement
methods, as well as constraints that are specific to individual buildings.

This chapter contains an approach to assessing the need for abatement, determining its timing, and choosing
an abatement method. Factors used in the decision-making process are introduced and  discussed. The
three types of ACM — surface material, pipe and boiler insulation and miscellaneous products — are treated
separately. Constraints that affect  individual owners or buildings are also discussed.


SUMMARY

    Assessment Information:

    •  The likelihood of fiber release from ACM is based on evaluating its current condition  and the
      potential for future disturbance, damage, or erosion.

    •  Air monitoring alone should not be used for assessment.


    The Assessment Process:

    The likelihood of fiber release from ACM determines the need for and timing of additional action.
    The nature and location of the material determines the abatement  method.


   • Surfacing Materials


     Need:     Surfacing material in good condition and with a low potential for future disturbance,
               damage, or erosion may need no further action.

     Timing:   ACM in poor condition should be dealt with first. If ACM  is in good condition but has
               a high potential for future fiber release, abatement can  be scheduled with building
               renovation or maintenance.

     Method:  Removing the ACM is the only permanent solution. Enclosure and encapsulation are
               temporary solutions to be implemented in special circumstances.
                                            4-1

-------
    • Pipe and Boiler Insulation

      Need:    If the insulation is intact,  no further action is needed.

      Timing:   Damaged insulation should be repaired or replaced as soon as possible.

      Method:  Removal is appropriate where the insulation is extensively damaged or deteriorated.
                Repair is appropriate where the insulation has minor  damage.

    • Other Types of ACM

      A special O&M program is usually all that is needed.


    Further  Considerations in Selecting an Abatement Schedule:

    • If an abatement project is not urgent, it will be less costly if combined with building repair, renova-
      tion, or expansion, or with scheduled  maintenance to equipment and building systems.

    • Other factors that may  influence the timing of abatement include:

      —  The pattern of normal  building operations;
      —  The building owner's legal liability;
      —  Pressures from building occupants and the public; and
      —  Expected useful life of the building.


4.1   Assessment Information

The need for asbestos control beyond a special O&M program depends  on the likelihood of fiber release
from ACM. The possibility of fiber release should be assessed by evaluating the material's condition, physical
characteristics, and location. Another approach is to measure the current levels of asbestos in the air. As
explained  below, however, assessment by air monitoring alone is not recommended because it reflects
conditions only at the time of sampling. In addition, air monitoring is technically difficult and expensive.


4.1.1  Potential Fiber Release

Factors for assessing fiber release potential are listed in Table 1.  (Figures 7 and 8 illustrate some of these
factors.) The first set of factors focuses on the current condition of  ACM. If water or physical damage,
deterioration, or delamination of the material  is evident, then fiber release has occurred, is occurring, or
is likely  to occur. The appearance of the material and the presence of  broken or crumbled  material on
horizontal  surfaces indicate fiber release.

Factors under the second heading in Table 1  reflect potential fiber release due to disturbance or erosion.
Visible, highly accessible materials in areas frequently used or needing periodic maintenance are most
vulnerable to physical damage. Also in this category are materials subject to vibration from mechanical
equipment, sound, or athletic activities — for example, materials near a gymnasium or band room, or in
buildings near an airport or highway. ACM  in an air plenum or near a forced airstream (e.g., air from  a
heating  vent) is likely to  suffer surface erosion. In addition, fibers  released into an  airstream may be
transported to other parts of the building, possibly exposing more people.  Any planned changes in building
use should also be  considered when assessing potential fiber release.
                                              4-2

-------
                     Table 1. Factors for Assessing Potential Fiber Release
                               (See Appendix H for more detail.)
Current Condition of ACM

    • Evidence of deterioration or delamination from the underlying surface (substrate)

    • Evidence of physical damage (e.g., presence of debris)

    • Evidence of water damage

Potential for Future Disturbance, Damage, or Erosion of ACM

    • Proximity to air plenum or direct airstream

    • Visibility, accessibility (to  building occupants and maintenance personnel), and degree of ac-
      tivity (air movement, vibration, movement of building occupants)

    • Change in  building  use
The factors in Table 1 are fully described in Appendix H. The descriptions should assist the evaluator in
assessing ACM at individual sites.

A simple "present" or "absent," "high" or "low" rating should be used for each factor. More elaborate
rating schemes have been tried. For example, factors have been assigned numerical scores and, using
mathematical formulas, the scores have been combined into indices to reflect potential exposure.1 These
"exposure indices" have met with mixed success. In tests, several indices showed wide variation from one
rater to the next and often did not indicate current, elevated airborne asbestos levels (e.g., USEPA 1983b).
Assigning numerical ratings to assessment factors and combining them into a single score cannot be recom-
mended. However, the factors are useful when they are scored with a simple, nonnumerical rating scheme.


4.1.2  Air Monitoring

Another way to assess asbestos fiber release is to measure asbestos fibers in the air. This approach is
appealing because it quantitatively measures airborne asbestos contamination. However, it measures on-
ly current conditions and provides no information about fiber release potential and future air levels. Moreover,
implementing an effective monitoring program to measure current  levels of airborne asbestos is difficult
and can be expensive.

One  proposed method for measuring airborne asbestos in buildings was developed by the National In-
stitute for Occupational Safety and  Health (NIOSH) in connection with the OSHA asbestos exposure stan-
dard for workplace settings. This method uses phase contrast microscopy (PCM), which may be effective
for industrial measurements where most airborne fibers are asbestos, but is less useful in settings with
much lower asbestos levels. PCM is  not sensitive to fibers with diameters less than 0.2 micrometers.2 In
addition, the NIOSH method excludes fibers shorter than 5 micrometers and does not distinguish between
 1 See, for example, Lory 1980, Pinchin 1982, and USEPA 1979.
 2 A micrometer is one-millionth of a meter. See Appendix B for a simple discussion of measurement units used to
  describe and measure asbestos fibers.
                                              4-3

-------
          Water damage
Physical damage to ceiling material from a flagpole
Airstream erosion from a heating vent
    High activity level near friable asbestos
                     Figure 7. Example assessment characteristics of
                               asbestos-containing materials.
                                            4-4

-------
           Ceiling of a gymnasium in an elementary school
           (no basketball marks)
     Ceiling of a gymnasium in a high school showing evidence of
     damage from basketballs thrown by students
Figure 8.  An example of the effect of a change in building use.
                              4-5

-------
asbestos and non-asbestos fibers. Many airborne fibers in buildings with ACM are likely to be thinner and
shorter than these limits (Chatfield 1983 and NRC 1984), and are likely to include fibers from carpets, clothing,
hair, paper, books, and many other sources. As a result, PCM analyses of air inside these buildings could
be seriously misleading.

Other methods measure both small and large fibers and distinguish asbestos from non-asbestos materials.
Those methods count fibers by electron microscopy, and confirm that the fibers are asbestos with chemical
and crystallographic analyses. The analytical transmission electron microscope (TEM) 3 is the most sen-
sitive and asbestos-specific instrument. EPA has used TEM in experiments to establish baseline asbestos
levels indoors and outdoors. However, obtaining enough samples to estimate prevalent airborne levels is
difficult in occupied buildings. In addition, TEM analysis is expensive (ranging from $200 to $600 per sam-
ple) and few laboratories are qualified to perform  it. These limitations, combined with the inability of air
monitoring to provide information on future conditions, restrict its usefulness for assessment. EPA, therefore,
does not recommend it as a primary assessment tool at this time. (Air monitoring does have a role, however,
in determining when  an abatement project is complete. See Section 6.4.)
4.2  The Assessment Process

The assessment factors discussed above are used to decide if additional asbestos control is needed and,
if so, when and what method. Although the process is similar for each of the three types of ACM, the details
are specific to each type and are discussed separately below.


4.2.1  Sprayed- and Troweled-on Surfacing Materials


4.2.1.1  Need

Use the factors described in 4.1.1 to determine the current condition of the ACM and the potential for future
disturbance, damage, or erosion. Table 2 shows how these two considerations influence the decision regar-
ding action beyond a special O&M program. Surfacing material in good condition may need no further
action if potential for future disturbance, damage, or erosion is low. The material must be inspected regularly
(see Section 3.3.1) to assure that it remains in good condition. Further action is needed if the material is
damaged or in poor condition, or if there is high potential for future  disturbance or erosion.


4.2.1.2  Timing

When further action is necessary, its timing must be carefully considered. A well-planned  and executed
abatement program is needed to ensure that the abatement activity itself does  not create a hazard. If the
ACM is currently in good condition, but the potential for future fiber release is high, scheduling of asbestos
abatement can take advantage of other building plans. For example, renovation work, which requires precau-
tions to control fiber release, provides an opportunity to remove, encapsulate, or enclose ACM. There are
no set rules to determine the timing of  asbestos abatement, since circumstances vary from building to
building. Table 2 provides a guide.

As one moves through the table from left to right (from good to poor condition) and from  top to bottom
(from low to high potential for disturbance, damage, or erosion), the need for immediate action increases.
Material in poor condition should be dealt with first. Materials that are in better condition  or have a low
potential for disturbance or erosion have a lower priority.
 3 A provisional method for TEM measurement of asbestos has been developed by EPA (USEPA 1977).
                                              4-6

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4.2.1.3  Method

The choice of abatement method is determined mainly by the condition of the ACM. Surfacing materials
can be removed, encapsulated with sealant, or enclosed within an airtight structure. The three methods
are summarized in Table 3 and described in more detail in Section 5.1. Worker protection and the construc-
tion of sealed containment barriers around the work site are required for all three methods.

Removal has the widest applicability. It also is the only truly permanent solution, since no building contain-
ing asbestos can be demolished without first removing the ACM. If ACM has only minor, isolated damage,
removal of selected areas may be sufficient.

Enclosure and encapsulation have limited application. Enclosure is restricted to situations where ACM can
be isolated in small localized areas. Encapsulation can be used only for acoustical plaster in  good condi-
tion. In addition, the special O&M program must be continued and the enclosed or encapsulated materials
reinspected periodically (at least monthly) until the ACM is removed or the building is demolished. Encap-
sulation may make eventual removal more difficult and costly,  since encapsulated ACM may have to be
removed in dry form.

Initial  cost of removal may be  higher than for other abatement methods.  However,  removal may be  less
expensive over the long term, since the continued presence of ACM requires special O&M practices, periodic
reinspection, and repairs.  Enclosure and encapsulation are options only when the ACM is in  good condi-
tion. These are primarily temporary measures to reduce the potential for future disturbance or erosion  until
the ACM is eventually removed.


4.2.2   Pipe and Boiler Insulation
4.2.2.1  Need

Pipe and boiler insulation typically presents a more localized fiber release problem than surfacing material.
The insulated pipes, boilers, ducts, and other equipment are frequently confined to equipment rooms or
placed within walls or behind ceilings. Even accessible insulation is localized to the piece of insulated equip-
ment. Thus, the potential for disturbance, damage, or erosion is lower than for surfacing material; frequent
inspection can spot any new disturbance and the damage can be repaired quickly. The condition of the
ACM determines the need for further action (see Table 4). If the insulation is  intact, no further action is
needed.
4.2.2.2   Timing

Damaged insulation should be repaired or replaced as soon as possible.  Major renovation, such as in-
stallation of a new boiler, is a good time to consider replacing pipe and boiler insulation with non-asbestos
material. This will eliminate the need for a continuing special O&M program.
4.2.2.3   Method

Removal is appropriate where the insulation is extensively damaged or deteriorated. It involves cutting
and stripping the insulation from pipes (or other equipment) and substituting non-asbestos material. Plaster
around elbows, valves, and flanges should also be replaced with non-asbestos materials. Removal of pipe
and boiler insulation requires many of the same precautions and worker protection measures for removal
of surfacing materials.
                                             4-10

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                                            4-11

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Repair is appropriate where the insulation has minor damage. Repair involves patching the damaged in-
sulation or covering it with a new jacket. A more complete description of insulation removal and repair
appears in Section 5.2.


4.2.3   Other Types of ACM

A special O&M program is usually all that is needed for other types of ACM, since most ACM in this category
is hard and nonfriable and should not readily release asbestos fibers. The only time abatement (primarily
removal) should be considered is when it becomes necessary as part of building renovation or maintenance.
The procedures in Section 5.3. should  then be followed.
4.3  Further Considerations in Selecting a Schedule for Abatement

Significant cost savings may be realized by coordinating asbestos abatement with other building activities.
For example, when a commercial tenant moves, the space will be temporarily unoccupied and the new
tenant may request changes such as moving walls and doors, installing dropped ceilings, or building rooms
for specialized equipment. ACM will be disturbed by the renovation work, necessitating precautions to control
fiber release. This investment in worker protection and site containment creates an opportunity to enclose,
encapsulate, or remove ACM. On the other hand, when ACM needs immediate action, abatement may
be a cost-effective time to improve building systems — for example, by upgrading electrical systems, repairing
vents and ducts, or installing low-energy lights.

Other considerations in scheduling asbestos abatement include the pattern of normal building operations,
the long-term legal liability of the building owner, pressures brought by concerned parties, and the expected
useful life of the building.

    • The pattern of normal building operations. Extensive abatement activities will disrupt building
      operations. When possible, abatement should coincide with vacations or other periods of low
      activity.

    • The long-term legal liability of the building owner. Some owners choose to remove all ACM as
      quickly as possible to reduce their liability. However, liability may actually  increase if removal
      is  performed by untrained or  inexperienced  contractors or without  proper precautions.

    • Pressures brought by workers, building occupants, and other affected parties. Building occupants
      and the public may have legitimate concerns about possible health risks. However, fear of
      asbestos often motivates them to call for action before the problem has been properly assess-
      ed. The public information program developed with the building survey should  include descrip-
      tions of the assessment, its results, and a justification of the decision. This is especially impor-
      tant if abatement is  not carried out immediately or if no further action will be taken.

    • Expected useful life of the building. The comparative costs of removal versus a continuing special
      O&M  program will depend on the expected  life of the building.
                                              4-12

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CHAPTER 5. ABATEMENT METHODS: CHARACTERISTICS AND RECOMMENDED WORK PRACTICES
This chapter provides more detailed information on the advantages, disadvantages, applicability, and relative
costs of alternative abatement methods. Information is also given on recommended work practices for worker
protection, work site containment, and project surveillance. This information is provided to help building
owners determine which method is most appropriate for their situation and what the abatement effort will
involve. It is not intended as an  instruction manual for  abatement.


5.1  Abatement Methods for Sprayed- or Troweled-on Surfacing Material

Each abatement method (removal, enclosure or encapsulation) is a separate and distinct alternative. They
share,  however, several features. The first is the need to conduct a more detailed inspection of both the
ACM to be treated and the underlying surface. Each separate, homogeneous area of ACM, usually a single
room, hallway, or central space, should be  reinspected.  (Remember that seemingly homogeneous areas
can be composed of different materials and thus require separate inspections.) It is especially important
to inspect for hidden material above a suspended ceiling with lay-in panels (see Figure 9). A second round
of material sampling in selected areas may help to confirm the presence of asbestos and better delineate
areas needing further corrective action.

The following information should be collected on each  area with  ACM:

    •  size of the  area, since this affects the cost of abatement;

    •  type of ceiling construction if the ceiling is coated (for example, concrete joist and  beam, con-
      crete waffle slab, steel beam or bar joist, suspended metal lath, suspended lay-in panels, tile,
      metal, corrugated steel), since different construction types present different control problems;

    •  ceiling height, which may determine the practicality of enclosing the material;

    •  type of wall (for example, smooth or rough concrete, block or brick, plasterboard), which may
      indicate whether an encapsulant is  needed if material  is removed;

    •  average thickness of ACM (and variation in thickness),  since encapsulants should not be ap-
      plied to thick material.

A form for collecting the necessary information was developed  by EPA's Region VII Office and is included
in Appendix I for illustrative purposes.

The second common feature of the three abatement methods is the need for worker protection during abate-
ment activities.  Worker protection entails not only proper training and specified  work practices, but also
protective equipment (special coveralls and  respirators) for the workers. The OSHA standards specify three
different respirators depending on the expected concentration of fibers in the work area: (1) a full- or half-
face mask with either a single-use or replaceable filter,  (2) a full-face mask with replaceable filter and a
pump to  assist  breathing, and (3) a full-face mask with a self-contained  or remote air supply.

NIOSH now recommends that the first type of respirator with a single-use filter not be used, because these
filters  have not  been tested for effectiveness specifically against asbestos  fibers and because they are
difficult to seal properly around the face.1 Supplied air (type "C") units offer the most protection. Respirators
 1 A letter setting forth NIOSH's concerns about these respirators was sent to respirator manufacturers on August
  25,1980. A copy of this letter appeared in the December 1980 issue of the Journal of the American Industrial Hygiene
  Association. An industrial hygienist or other appropriately trained professional should assist workers in fitting any
  type of respirators.
                                              5-1

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Figure 9. Asbestos-containing material located above
               a suspended ceiling.
                       5-2

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are required for removal of ACM and are highly recommended for other abatement methods, since enclosure
and encapsulation may also elevate fiber levels.

The third common feature is proper work area containment. Containment typically means construction
of barriers with 6 mil polyethylene plastic sheets joined with folded seams, and with sealing tape at the
seams and boundaries. Some contractors have had problems attaching plastic sheets to walls. Thinner
sheets or a better attachment system (for example, stapling and taping sheets to furring strips fastened
to walls) may be required. (Figure 10 shows the construction of a typical containment system. Note that
respirators should be worn if the ACM will be disturbed during construction.) Air locks and worker decon-
tamination facilities with showers are recommended, as well as negative air pressure systems, described
in Section 5.1.1 below.2 All return air vents should be sealed to prevent asbestos contamination of the air-
handling system. Without such containment measures, increased exposure for building occupants is like-
ly. Once abatement begins, everyone not  participating  in the project should be kept out of the area.

The fourth common feature is the need for a rigorous postabatement cleanup. This includes wet-mopping
or HEPA-vacuuming all horizontal and vertical surfaces in the work area. (Wet mopheads and cloths should
be discarded in sealed plastic bags and treated as asbestos-contaminated  waste.) Cleaning of surfaces
outside the work area  is highly recommended. Two cleanings—the second  after at least 24 hours when
suspended fibers  have settled—will  provide better assurance of fiber reduction than  a  single cleaning.
(Section 6.4 contains additional  information on cleaning and inspecting the work site.)


5.1.1  Removal, Disposal,  and Replacement

Figure 11  is a photograph  of a typical  removal project. When  removing ACM, observe the following
requirements:

    •  The material must first be treated with a solution of water and a wetting agent to  reduce fiber
      release. Some types of amosite-containing materials will not absorb either water or water com-
      bined with the wetting agent suggested by EPA (50% polyoxyethylene ester and 50% polyox-
      yethylene ether). Other wetting agents should be tested on the material for absorption. If the
      material will not absorb the wetting agent, undertake a dry removal using Type C respiratory
      protection. EPA must approve  all dry removal operations. Get in touch with the NESHAPS con-
      tact in your region (see Appendix D).

    •  Friable ACM must be disposed of in "leak-tight containers," typically  6 mil polyethylene bags.
      Bags can be placed in 55-gallon drums for additional protection. Bags or drums must be label-
      ed, as specified by NESHAPS (see Appendix C) or OSHA (see Appendix F).

    •  OSHA procedures for worker protection and decontamination, as well as for measurement of
      airborne asbestos, must be strictly followed (see Appendix  F). While not required by law, EPA
      procedures for work area containment should also be followed to assure safe  removal.


Research on asbestos removal plus EPA's experience with removal activities in schools  since 1979 have
pointed up several other important issues:

    •  A tear in the containment barrier is a significant exposure hazard for building occupants and
      should be repaired immediately. The use of negative pressure systems together with HEPA filtra-
      tion (that is, low speed exhaust fans with HEPA filters) to move air from within  the work area
 2 OSHA decontamination requirements specify worker change rooms as a minimum provision for asbestos removal
  projects. If negative air systems are used, "air locks" should not be airtight. That is, make-up air should pass through
  the air lock. See Appendix J for additional information.
                                             5-3

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Figure 10. Construction of containment barriers.
                    5-4

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Figure 11. An asbestos removal project.
                 5-5

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      to outside the building will provide added protection in case of an accident. Appendix J sum-
      marizes specifications for negative air systems.

    • When containment barriers are dismantled after ACM removal, the sealing tape used to attach
      the plastic sheets to walls and ceilings frequently removes paint. It is prudent to include the
      cost of repainting all walls (and ceilings, if appropriate) in estimates of asbestos removal costs.

    • Asbestos waste is sometimes spilled both in and  outside the work area. Containers full of wet
      material are very heavy and hard to transport. These containers must be sealed and  handled
      carefully. Workers should continue to wear protective equipment during these operations. Also,
      disposal sites may be scarce. Some states require a disposal permit before removal begins.

    • Amended water (water and wetting  agents) from spray  operations may  leak  through the
      polyethylene sheets and damage floors, especially tile and wood. Sealed double plastic sheets
      should protect the  floors.


When removal and disposal operations are finished, evaluate the need for a sealant on the exposed sur-
face. (The need to reinsulate or resoundproof with asbestos-free materials should be decided before removal
begins.) Sealants generally are necessary where the underlying surfaces are porous (for example,  con-
crete blocks or slabs), since a few fibers usually remain after removal.

Cost of asbestos removal varies widely by region and by job. Where the underlying surface must be sealed
and the ACM replaced, those costs must  be added to  removal costs.
5.1.2  Enclosure

Enclosure involves construction of airtight walls and ceilings around the ACM. Figure 12 shows a typical
enclosure. These recommendations for constructing enclosures should be followed:

    •  To reduce fiber release, drills used during installation should be equipped with HEPA-filtered
      vacuums.

    •  Underlying structures must be  able to support new walls and ceilings.

    •  New construction material  should be impact-resistant and assembled to be airtight.3 Gypsum
      panels taped at the seams, tongue-and-groove boards, and boards with spline joints all qualify.
      Suspended ceilings with lay-in  panels are not acceptable. Joints between walls and ceilings
      should be caulked.

    •  If lights are recessed into ACM, they must be removed carefully to minimize fiber release. Lights
      should be reinstalled beneath the new ceiling.

    •  Relocation of plumbing lines and computer  cables may be  necessary.

    •  Building records must note the presence of asbestos behind  the enclosure to prevent acciden-
      tal fiber release during remodeling or building demolition. (The presence of ACM should  have
      been documented as part  of the special O&M program.) Signs should be posted, noting that
      ACM is behind the enclosure.
  3 No enclosure will be totally airtight. The practices recommended here are designed to greatly reduce air movement
   across the enclosure boundary.
                                              5-6

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Before enclosure
After enclosure
             Figure 12.  An asbestos enclosure project.
                                5-7

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5.1.3  Encapsulation with Sealants

Encapsulation refers to the spraying of ACM with a sealant. The sealant should bind together the asbestos
fibers and other material components and offer some resistance to damage from impact. Figure 13 shows
an asbestos encapsulation project.

Encapsulation should be used only on granular, cementitious material—commonly known as  acoustical
plaster. A sealant should penetrate the ACM and adhere to the substrate (or form a tough skin over the
material), withstand moderate impact, be flexible and flame-retardant, resist deterioration over time, and
be non-toxic. EPA evaluated over 100 sealants, using five criteria: impact resistance, flame spread, smoke
generation, toxic gas release during  combustion, and adhesive/cohesive strength (USEPA 1981). The
American Society of Testing and Materials (ASTM) also is developing laboratory testing criteria for sealants.
Additional information on the EPA sealant study can be obtained from EPA's Office of Toxic  Substances,
TSCA Assistance Office (see Appendix E for phone numbers).

Although the EPA study can help  building  owners choose a sealant, its effectiveness on the particular
ACM should still be tested on-site over several days. (ASTM is developing criteria and procedures for such
on-site tests.) Do not encapsulate  material  that is delaminated or deteriorated, or that shows extensive
damage. If delaminated, the material will be pulled down by the additional weight; if deteriorated, the ACM
may be blown off by sealant application; if extensively damaged, the material  may be repeatedly abused
and the sealant will not hold up. The condition of the sealant on previously encapsulated materials also
should be inspected. Reapplication of sealant may be necessary.

Latex paint has been used as a sealant for granular,  cementitious materials.  Select a brand with a high
vehicle content (at least 60 percent by weight) and at least 25 percent by weight vehicle resin.4 For encap-
sulating ACM, apply paint considerably thicker than recommended  for painting. Coverage should be no
more than 100 sq.  ft. per gallon, and should create a continuous, unbroken  coating.

Apply sealants with airless spray equipment.5 One recommended method is to apply a light (mist) coat,
then a full coat applied at a 90 degree angle to the direction of the first. If latex paint is used, the full coat
can also be applied by roller before  the mist coat dries.

Record the type of sealant used and the nature of the material and substrate encapsulated. This informa-
tion is needed to avoid unintentional  release of fibers during later remodeling or demolition.


5.2  Abatement Methods for  Pipe  and Boiler  Insulation

Abatement  methods  for ACM used to insulate pipes, boilers, ducts, tanks, and related equipment are
somewhat different from methods  for asbestos sprayed or troweled on surfaces. When damage to pipe
or boiler covering is  limited, repair is the recommended abatement approach.  Non-asbestos plastering
can restore open joints, wrapped or plastered areas that are damaged, and areas around valves and flanges.
Encapsulants can also be used as a temporary measure.  Do not use duct tape; it becomes brittle after
exposure to high temperatures.

Where large portions of pipe and boiler insulation must be removed, erect containment barriers and employ
the full range of worker protections (see Section 5.1). Containment bags may be used instead of construc-
ting containment barriers around the work area. These bags are available commercially. As shown in Figure
14, the bags are positioned around the pipe insulation to be  removed,  and sealed to the pipe with tape.
 4 Paint constituents appear on the label of the can.
 5 The use of respirators is recommended for applying any sealant. Solvent-based (as compared to water-based) sealants
   may require the use of a supplied air (Type C) respirator due to hazards from the solvents.
                                              5-8

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Figure 13. An asbestos encapsulation project.
                     5-9

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Armholes and an inside pouch for tools let the worker remove insulation without exposure to asbestos
fibers. A sealed side port also can be constructed to allow access for wetting the asbestos and evacuating
the bag with a HEPA-filtered vacuum.6 Workers who use containment bags should still wear respirators
in  case a bag leaks.

To remove individual pipe sections or an entire pipe network, a small section (about 6 inches wide) of in-
sulation should be removed. The pipe then can be cut into manageable lengths with a saw or torch. Ex-
posed ends of the insulating material should be sealed with plastic and tape. If the remaining insulation
is not in good condition, the entire pipe should be wrapped in 6 mil plastic. Disposal of insulation material
must follow EPA procedures discussed earlier for ACM disposal (Sections 1.4 and 5.1). More information
on pipe and pipe insulation  removal will be provided in a future  technical bulletin.
                Figure 14.  Custom containment bags for repairing or removing
                                       pipe insulation.
5.3.  Abatement Methods for Other Types of ACM

Additional corrective action generally is not needed for other types of ACM. The special O&M program
should continue until  building renovation or maintenance requires ACM removal. The ACM should then
be removed following  the guidelines for surfacing materials (i.e., worker protection and work area contain-
ment).  Removed ACM should  be wrapped in 6  mil plastic sheets or placed in plastic bags, labeled as
asbestos waste, and  transported to a solid waste site.  Unless these materials are friable, OSHA and
NESHAPS regulations covering removal operations do not apply.
 6 Seals can be checked with a flashlight and smoke from a smoke tube.
                                             5-10

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                      CHAPTER 6. CONDUCTING ABATEMENT PROJECTS
Because efforts to treat ACM may be hazardous to abatement workers and building occupants, careful
planning and diligent implementation of the project are essential. Removal, enclosure, or encapsulation
of surfacing materials and removal or repair of pipe and boiler insulation may cause large-scale fiber release
if proper procedures are not followed. As a result, asbestos levels in the building may increase rather than
decrease.

For this reason, key elements of the abatement project include comprehensive and precise contract specifica-
tions, workers specially trained in asbestos abatement, rigorously applied worker protection and site con-
tainment measures, and the regular monitoring of the work site. When abatement activity is complete, the
entire work site should be thoroughly cleaned. The contractor should be released only after the work  site
has passed visual inspection and a test for airborne  asbestos.


SUMMARY

   Who Should Do the Work:

   Usually a contractor is hired to conduct abatement work that goes beyond special O&M.  Occa-
   sionally, a large school district or an owner of many buildings will train and dedicate an in-house
   asbestos  abatement team.

   Selecting a Contractor:

   Steps in selecting a contractor include checking references, conducting interviews, reviewing in-
   surance coverage, and writing precise contract specifications. Note that the most cost-effective
   contractor is not necessarily the lowest bidder.

   Managing the Work:

   •  Regular on-site inspections will assure conformance with work specifications and avoid  costly
      and hazardous errors.

   •  Before  the contractor is released, the work site should pass both a visual inspection and an
      air test for asbestos fibers to be sure the site has been adequately cleaned. From a technical
      point of view, the TEM method is preferred for  the air test. Although the PCM method  is not
      as specific for asbestos nor as sensitive to thin fibers as the TEM method, it is frequently more
      available  and  easier to implement.


6.1  Who Should Do  the Abatement  Work

Employees  involved in the abatement work must be specially trained and committed to quality work. Train-
ing should:

   •  Familiarize workers with  the general problems  of airborne asbestos;

   •  Teach them to handle ACM safely  and  prevent unnecessary fiber release; and

   •  Explain how to interpret  asbestos abatement work orders.

Either in-house staff or outside contractors can conduct asbestos abatement work. The decision depends
primarily on training, equipment, and experience.
                                             6-1

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In most cases, the in-house maintenance staff will not have enough time to master asbestos abatement
methods for surfacing materials—removal, enclosure, and encapsulation. However, some school districts
with many buildings containing surfacing ACM have formed asbestos abatement teams whose sole respon-
sibility is control of ACM. These in-house teams can thoroughly learn the requirements and methods of
asbestos abatement. With this training and knowledge of the buildings, an in-house team may be the most
effective.  More typically, however, an outside contractor specializing in asbestos abatement is hired for
specific abatement projects.

Building maintenance workers accustomed to repairing equipment with  insulation are frequently trained
to undertake abatement actions involving pipe and boiler insulation. However, outside contractors are typically
hired  to remove extensive amounts of insulation or  to remove both pipe and insulation.


6.2  Selecting a Contractor

Selecting a competent  contractor is the first step toward successful abatement. EPA's experience with
asbestos abatement and comments from technical advisors suggest that many contractors cannot proper-
ly conduct abatement projects. Several contractors,  awarded jobs based on responsive and reasonable
cost bids, proved unable or unwilling to follow contract specifications. Suggestions to help building owners
avoid  these situations are as follows:
    •  Assign the technical advisor who will monitor the abatement work to assist in writing job specifica-
      tions  and selecting the contractor. The  advisor should not be employed by an abatement
      contractor.

    •  Require evidence of prospective contractors' experience and/or training in asbestos abatement.

    •  Check references, including other building owners for whom contractors have worked. (See Ap-
      pendix K for an example checklist of contractor qualifications.)

    •  Ask for detailed written descriptions of how bidders will satisfy the project specifications.

    •  Interview bidders regarding their work, worker protection, and site containment plans. A state-
      ment that the contractor will comply with all EPA, OSHA, and state regulations is not sufficient.
      Ask bidders for copies of their standard operating procedures and employee protection plans,
      specifically their OSHA medical monitoring and respirator training program. The interview is
      invaluable for evaluating each  contractor's capabilities and understanding of the problem.

    •  Obtain documentation of each contractor's fiscal qualifications, including financial performance,
      assets, liabilities, legal  judgments, and insurance.

    •  Be sure that the contractor selected has adequate liability insurance. Some forms of insurance
      may not provide enough long-term protection against inadequate abatement work. The building
      owner's attorney and insurance advisor should determine if coverage is adequate.

    •  Be specific about what constitutes successful job completion. A thorough visual inspection to
      insure adequate cleaning is an absolute necessity. Air monitoring is also recommended (see
      Section 6.4). The person carrying out the air monitoring should not be employed by the abate-
      ment  contractor.

    •  Require evidence of worker certification or have the contractor conduct an on-site training pro-
      gram  for workers.
                                              6-2

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    • Encourage bidding competition, since prices can vary greatly. Multiple bids are desired, but
      too many can confuse the selection process. Remember that successful abatement, not cost
      minimization, is the goal.

    • If possible, avoid contracting for abatement work during the summer. Many school projects are
      conducted during that season, taxing the limited number of competent contractors.

Appendix L contains a list of organizations that have prepared model contract specifications for asbestos
removal. Together with the above suggestions, these models can serve as the basis for writing specifica-
tions tailored to individual projects. Remember that EPA's RAC can provide additional information and
suggestions.

6.3  Managing the Work

As in all construction jobs, the program manager or the manager's representative (frequently the technical
advisor) should visit the abatement work site often (no less than four times per day) to insure that all plans
and  procedures are properly implemented. The  work site monitor should:

    • Be sure  the workers follow specifications;

    • Confirm  compliance  with worker  protection requirements;  and

    • Assure that the containment barriers around  the work site are  properly constructed and
      maintained.

By carefully monitoring the abatement work, the asbestos program manager can correct errors quickly.
Work site inspections are most effective if the manager can refer to a detailed workplan containing specific
work practices. Where work does not follow specifications, the project should be stopped immediately. The
abatement contractor, the asbestos program manager,  and the work site monitor (if different from the pro-
gram manager) should then identify the problems  and take steps to correct them.

The  need for worker protection (protective clothing, respirators, and change facilities) was discussed in
Section 5.1. Although contractors are responsible for their employees, a building owner's concern for the
safety of everyone in the building extends to the abatement workers.

Work area containment is essential for all types  of abatement and for both surfacing material and pipe
and boiler insulation. Once abatement begins, all persons not directly involved in the work should be bar-
red from the area. The work site monitor should make sure plastic barriers are in place (see Section 5.1)
and that warning signs are posted at least 20 ft. in front of the work site entrance.

If abatement activity is limited to repair or  minor removal of pipe and boiler insulation, containment bags
will probably be used (see Section 5.2). The monitor should inspect the construction and use of the bags.
Warning signs should be posted outside the work  site.

The monitor should also check the air lock at the entrance to the work site.  If a negative pressure system
is not used, the air lock (and the entire containment system) should be airtight. If a negative pressure system
is used (as recommended), the air lock must allow  air from the building to enter the work site to replace
the contaminated air that is filtered and exhausted  outside. When  inspecting the work in progress, the
monitor's specific checklist will  depend on the type of abatement. Abatement inspection for  surfacing
materials and pipe and boiler insulation should be based on guidelines and precautions described in Chapter
5 (Sections 5.1  and 5.2, respectively).

Work site inspections greatly increase an  abatement project's likelihood of success. The importance of
doing the job right the first time cannot be over-emphasized. Tests must be performed when the work is
                                              6-3

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finished to determine if the project has been conducted properly and the work site adequately cleaned
(described in 6.4.) However, if the workers have not been diligent throughout the project, proper cleaning
of the work site may not be possible.


6.4   Releasing the Contractor

An asbestos abatement project is successful when the source of fiber release has been controlled and
airborne asbestos generated during abatement has been reduced to an acceptable level. As discussed
earlier in this chapter, success can be built into the project with a sound work plan and constant monitoring
of the work area to insure proper implementation. All workers must be trained and must follow stipulated
work practices. Also, it is important to  use negative air pressure ventilation to capture asbestos fibers
generated during all types of abatement, and  to continually remove debris from the site. When the abate-
ment project is completed,  the entire site should be cleaned at least twice.

Success is confirmed with a final evaluation at each work area. The evaluation consists of visual inspec-
tion and air testing. Visual  inspection is used to determine if the work has been performed properly and
to check for debris and other obvious signs of poor cleaning. Air testing helps confirm that the work site
has been  adequately cleaned.  Only then is the  contractor released.


6.4.1  Visual Inspection

The primary test for releasing the contractor is a thorough visual inspection of the work site. The inspec-
tion should be conducted before the containment barriers have been taken down but after the plastic sheets
have been cleaned with damp mops and cloths or a  HEPA vacuum cleaner. Since elevated levels of air-
borne asbestos may still be present, the inspector should wear a respirator (see Section 5.1).

First, the inspector should confirm job completeness. If ACM has been  removed, substrate surfaces should
be checked to be sure no ACM  remains. Special  attention should be given to pipes, beams, and irregular
surfaces that may have corners and hard-to-reach areas. If the materials were enclosed, check the area
for tight construction (e.g.,  no stray drill holes or openings at corners). Inspect encapsulated surfaces to
insure that the right amount of sealant has been  used: there  should be no holes, voids, or  cracks. Check
surfaces behind obstructions (e.g., pipes or ducts) for these signs.

Next, the  inspector should determine that the work site has been adequately cleaned.  Any activity that
disturbs ACM will release fibers. Therefore, work site cleanup after removal, repair, enclosure, or encap-
sulation is critical.

Examine all surfaces for dust and debris, especially overhead areas like tops of suspended light fixtures.
Use a damp cloth to collect dust from these surfaces and then inspect the cloth for evidence of dust. This
is a practical way to establish that the  "no dust" requirement has  been met.

A more sensitive test for dust is to darken the room and shine a flashlight so that the  beam just  glances
any smooth horizontal surface. Run your finger across the illuminated area. If a line is  left on the surface,
or if airborne particles shine in the light,  dust is still present.

If dust is found by either of the two tests, the entire work area  should be recleaned  and  the tests repeated.
6.4.2   Air Testing

Conduct air monitoring only after the site has passed visual inspection. First, remove all plastic sheets
covering floors, walls, and other surfaces. (The plastic barriers separating the site from the rest of the building
                                              6-4

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and the plastic sheets covering doors, vents, and windows should be left in place until the air test has
been passed.) If a negative air pressure ventilation system was used during abatement, it should continue
operating while air monitoring  is in progress.

As discussed in Section 4.1, measuring airborne asbestos fibers accurately is technically complex and
usually expensive. It involves two steps: air sampling to capture fibers on a filter, and laboratory analysis
to determine the quantity of asbestos. There are several approaches to air sampling and analysis, varying
in technical requirements,  cost, and availability. Which approach is more appropriate is a controversial
subject. The information presented in the remainder of this chapter is based in part on a 1984 workshop
sponsored by EPA and the National  Bureau of Standards. A companion EPA guidance document on air
monitoring following an abatement action discusses the subject in more detail (USEPA 1985b).
6.4.2.1  Sampling

Sampling for asbestos consists of collecting fibers by drawing air through a filter at a known rate. Usually,
sampling equipment is placed at a fixed location for a certain period of time. But this approach may fail
to detect the presence of fibers. For example, if sampling is conducted for a short time during a quiet period
(i.e., when air movement is limited), many fibers will settle out of the air onto the floor and other surfaces
and may not be captured on the filter. Under these conditions, air measurements could show little or no
asbestos.

Previously, EPA recommended sampling for at least eight hours to cover various air circulation conditions
and thus increase the likelihood of capturing asbestos fibers if they are present. A quicker and more effec-
tive way to accomplish this, however, is to circulate the air artificially so that the fibers remain airborne
during sampling.

This "aggressive sampling" is recommended for the post-abatement air test. Recommended methods for
conducting aggressive sampling are presented in Appendix M. They use forced-air equipment such as
a leaf blower to dislodge free fibers, then slow-speed fans to keep the fibers suspended during sampling.

Persons who conduct the sampling should wear a respirator. Even though the work site has been cleaned
and has passed the visual test, levels of airborne asbestos still may be elevated.


6.4.2.2  Analysis of Samples

Three microscopic methods are currently being used to analyze asbestos:  phase contrast microscopy (PCM),
scanning electron microscopy (SEM), and transmission electron microscopy (TEM). The characteristics
and relative merits of each method are summarized in Table 5 and are  described in detail in the compa-
nion EPA guidance document (USEPA 1985b).

As indicated in Table 5, PCM is the method that is most familiar, available, and frequently used. It  is also
the least expensive and has a well-established analytical protocol. (As noted in  Section 4.1.2, OSHA specifies
PCM for monitoring worker exposure in asbestos industries.) However, the NIOSH protocol for PCM does
not distinguish between asbestos and other types of fibers and counts only fibers longer than 5 micrometers.
Nor is PCM sensitive enough to detect the extremely thin fibers typical of airborne asbestos in buildings.
Thus,  the interpretation of PCM results assumes that a low concentration of relatively large airborne fibers
means that the concentration  of asbestos fibers is also low.

The TEM method gives the most complete information on airborne asbestos: it can distinguish asbestos
from other fibers and also is able to detect very thin fibers. However, it can be expensive and time-consuming.
TEM is  not widely available.
                                              6-5

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        TABLE 5. COMPARISON OF METHODS FOR MEASURING AIRBORNE ASBESTOS

                   PCM                      SEM                      TEM
Standard
Methods

Quality
Assurance
Cost

Availability

Time
Requirements
Sensitivity
(Thinnest Fiber
Visible)

Specificity
NIOSH P&CAM 239
Method.1

Proficiency
Analytical  Testing
Program; no NBS3
reference materials.

$25-50

Most available.

1 hr. preparation
& analysis, < 6 hrs.
turnaround.

0.15 /jm at best;
0.25//m typical.
Not specific for
asbestos.
No standard
method.

No lab
testing, or NBS
reference materials.
$50-300

Less available.

4 hrs. preparation
& analysis, 6-24 hrs.
turnaround.

0.05 fjm at best;
0.20/um typical.
More specific than
PCM but not definitive
for asbestos.
EPA provisional
method & update.2

Limited lab testing;
NBS reference
materials available.
$200-600

Least available.

4-24 hrs. preparation
& analysis, 2-7 days
turnaround.

0.0002 /urn at best;
0.0025//m typical.
Definitive for asbestos.
when used to its fullest
capabilities.
 1 NIOSH 1979. The new NIOSH 7400 method is an alternative.
 2USEPA 1977, Yamate 1984.
 3 National Bureau of Standards.

Source: Taken with modification from USEPA 1985b.
The SEM method can be somewhat more specific for asbestos and more sensitive to thin fibers than PCM,
but less so than TEM. It is also less expensive and time-consuming than TEM. At present, however, no
standard measurement protocol is available for SEM. As a result, it has not been systematically evaluated
nor has the reliability of SEM measurements been  established.

EPA acknowledges that all three methods are used in air testing for the purpose of releasing abatement
contractors. However, only PCM and TEM have standard methods and testing programs. A standard method
has not yet been developed for SEM. While TEM is technically the method of choice, PCM is the only
option in many localities.
6.4.2.3  Recommended Test Specifications

Regardless of the microscopic method for measuring asbestos, identifying homogeneous work sites is
the first important step in the process. A site within the abatement work area is homogeneous if it contains
one type of ACM  and  only one type of abatement was used.  For sampling purposes, the  air in each
                                             6-6

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homogeneous site is assumed to be relatively uniform. Guidelines for locating the samplers are included
in Appendix M. Several other aspects of the air test are identical, regardless of microscopic method:

    •  Choose sampling locations within the homogeneous work site to assure representative samples.
      (See Appendix M).

    •  Begin sampling when the work site is dry (24 hours after cleaning).

    •  Conduct aggressive air sampling in all cases.

    •  Follow sampling and analysis specifications,  including procedures for quality control.

The asbestos program manager should be sure the  technical advisor in charge of the air test knows the
specifications listed  below. The advisor should insist that recommended procedures be followed for both
air sampling and laboratory analysis.


Testing with the TEM Method

  Sampling:

    •  Draw at least 3000 liters of air through each  filter at a rate of 2 to 12 liters  per minute.

    •  Collect at least five samples in each  homogeneous work site.

    •  At the same time, collect at least five samples  just outside the work site but within the building.
      These samples will be compared with those collected inside the work site to ensure that the
      work site is at least as clean as the incoming air (see Appendix M for details).1

  Analysis:

    •  Measure the asbestos on each filter with TEM using the EPA provisional procedures and up-
      dates (USEPA 1977 and Yamate 1984).

    •  Use  a direct transfer method of sample preparation if possible (see Appendix M).

    •  Express the results as f/cc, or as ng/m3 if an indirect sample preparation is used.

    •  Include at least one field blank2 and one laboratory blank per abatement job for quality control
      purposes (see Section 6.4.3). Also, split one work site sample and conduct duplicate analyses.

  Release Criterion:

    •  Release the contractor if the average fiber concentration of the work site samples is not statistically
      larger than the average of the outside samples. Each homogeneous site must pass the test
      before the contractor is released. (Appendix  M contains information to  determine statistical
      differences.)

    •  If the average of the work site samples is statistically larger than the average of  the outside
      samples, clean the entire work site again  and repeat the  test (collect new work site samples
      and follow the procedures described  above).
 11f a negative pressure system has not been used, collect the "outside" samples outdoors.
 2 A blank is a filter that is not used for sampling but is otherwise treated in the same way as other filters.
                                              6-7

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Testing with the PCM Method

  Sampling:

    •  Draw at least 3000 liters of air through each filter at a rate of 2 to 12 liters per minute.

    •  Collect at least five samples per homogeneous work site, or one per room, whichever is greater.

  Analysis:

    •  Measure the asbestos on each filter with PCM using the NIOSH P&CAM 239 procedures. (The
      newer NIOSH 7400 procedures can also be used. See Appendix M.)

    •  Include at least one field blank and one laboratory blank per abatement project, for quality con-
      trol purposes. Also, split one work site  sample for duplicate analysis.

  Release Criterion:

    •  Release the contractor if every sample value is below the limit of reliable quantification (approx-
      imately 0.01 f/cc when 3000 liters of air are sampled; see Appendix  M).

    •  If any of the sample values is above the prescribed level, clean the entire work site again, col-
      lect new samples, and evaluate the samples as described above.

For each method, the recommended number of samples and the prescribed use of the data defining the
release criteria are based on a compromise involving practical considerations of cost, time required for
the tests, performance characteristics of the methods,  and statistical criteria. Details of the sampling and
analysis specifications are provided in Appendix M.


6.4.3   Quality Assurance

Notwithstanding the advantages of one microscopic method over another, no method will produce reliable
results unless both the field  sampling and laborabory analysis are properly conducted. To obtain reliable
results, a quality assurance  (QA) program for the collection and analysis of data is essential.

The objective is to produce measurements with sufficient and  documented quality for their intended pur-
pose.  In this case, the purpose is to determine  satisfactory completion of an abatement project. The com-
ponents of a QA program range from clerical activities such as  labeling samples and documenting results,
to performing technically complex tasks in the  laboratory. When establishing the quality of data, however,
all activities are equally important.

Preparing and implementing a QA program requires the assistance of a technical advisor on asbestos
measurement. EPA and OSHA have published  guidelines on quality assurance for TEM and PCM (Yamate
1984, and NIOSH 1979). The QA Program Checklist below can  be used by the asbestos program manager
in reviewing a proposed QA program.


QA Program Checklist

    •  Training and Experience: Be sure that all persons producing the  measurement understand
      their roles and are trained. Select a laboratory with demonstrated proficiency in asbestos analysis.
      Request details of the laboratory's quality control program, and get documentation of the lowest
      level of fibers routinely reported.
                                             6-8

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• Quality Control Checks: Use field and laboratory blanks to check for fiber contamination, cod-
  ed sample labels to avoid analyst bias, duplicate analyses to confirm precision, and a second
  laboratory to spot-check the accuracy of results.

• Chain-of-Custody: Assign responsibility for security of the samples to specific persons at each
  stage of the analysis. Document each step in the passage of the sample from the field to the
  laboratory.

• Documentation: Check and document laboratory results as well as their labeling. The building
  owner should retain all test results and records documenting the testing process.
                                         6-9

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                                        REFERENCES
Chatfield EJ. 1983. Measurement of asbestos fibre concentrations in ambient atmospheres. Ont., Can.:
Ont.  Research Foundation.

Chesson J, Margeson DP, Ogden J, Reichenbach NG, Bauer K, Constant PC, Bergman FJ, Rose DP, Atkin-
son GR, Lentzen DE. 1985a. Evaluation of asbestos abatement techniques, phase 1: removal. Final report.
Washington, DC: Office of Toxic Substances and Environmental Monitoring Systems Laboratory, U.S. En-
vironmental Protection Agency.  Contracts 68-01-6721, 68-02-3938 and 68-02-3767.

Chesson J,  Margeson DP, Ogden J,  Bauer K, Constant PC, Bergman FJ, Rose DP. 1985b. Evaluation of
asbestos abatement techniques; phase 2:  encapsulation. Draft report. Washington, DC:  Office of Toxic
Substances, USEPA. Contracts 68-01-6721 and 68-02-3938.

Lory  EE. 1980. Asbestos friable insulation material (FIM) risk evaluation procedure for Navy facilities. Port
Hueneme, CA: Civil  Engineering Laboratory, U.S. Navy.

NRC. 1984. National Research Council. Asbestiform fibers, non-occupational health risks. Washington, DC:
National Academy.

Nicholson WJ. 1984. Asbestos health assessment update. Washington,  DC: USEPA.

NIOSH. 1972. Natl. Inst. Occupational Safety and  Health. Criteria for a recommended standard: occupa-
tional exposure to asbestos. U.S. Dept.  Health, Education, and Welfare.

NIOSH. 1979. Natl. Institute Occupational Safety and Health. USPHS/NIOSH membrane filter method for
evaluating airborne asbestos fibers. U.S. Dept.  Health, Education, and Welfare.

Pinchin DJ. 1982. Asbestos in  buildings. Mississauga, Ont.,  Can.: Ontario  Research Foundation.

Royal Commission on Matters of Health and Safety Arising from the use of Asbestos in Ontario. 1984. 3
Vols. Toronto, Ont.,  Can.: Ont.  Ministry of the Attorney General.

USEPA. 1977 (rev. June 1978). U.S. Environmental  Protection Agency. Electron microscope measurement
of airborne asbestos concentrations. Research Triangle Park, NC: Office of Research and Development,
USEPA. EPA-600/2-77-178.

USEPA. 1979. U.S. Environmental Protection Agency. Asbestos-containing materials in  school buildings:
a guidance  document, part 1. Washington, DC: Office of Toxic Substances, USEPA.

USEPA. 1980a. U.S. Environmental Protection Agency. Asbestos-containing materials in  school buildings,
guidance for asbestos analytical programs. Washington,  DC: Office  of  Toxic Substances, USEPA.
EPA-560/13-80-017A.

USEPA. 1980b. U.S. Environmental Protection Agency. Asbestos-containing materials in schools, economic
impact  analysis of identification and  notification proposed rule, Sec. 6, TSCA. Washington, DC: Office of
Toxic Substances,  USEPA. EPA-560/12-80-004.

USEPA. 1981. U.S. Environmental Protection Agency. Evaluation of encapsulants for sprayed-on asbestos-
containing materials in buildings. Summary. Cincinnati, OH: Office of Research and Development, USEPA.

USEPA. 1983a. U.S. Environmental Protection Agency. Guidance for controlling friable asbestos-containing
materials in buildings. Washington, DC:  Office  of Toxic Substances, USEPA.  EPA-560/5-83-002.
                                             R-1

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USEPA. 1983b. U.S. Environmental Protection Agency. Airborne asbestos levels in schools. Washington,
DC: Office of Toxic Substances,  USEPA. EPA-560/5-83-003.

USEPA. 1984a. U.S. Environmental Protection Agency. Evaluation of the EPA asbestos-in-schools iden-
tification and  notification rule. Washington, DC: Office of Toxic Substances, USEPA. EPA 560/5-84-005.

USEPA. 1984b. U.S. Environmental Protection Agency. Asbestos in buildings: national survey of asbestos-
containing friable materials. Washington, DC: Office of Toxic Substances, USEPA. EPA 560/5-84-006.

USEPA. 1985a. U.S. Environmental Protection Agency. Asbestos  in buildings: guidance for service and
maintenance  personnel. Washington, DC: Office of Toxic Substances, USEPA. EPA 560/5-85-018.

USEPA. 1985b. U.S. Environmental Protection Agency. Measuring airborne asbestos following an abate-
ment action. Washington, DC: Office of Research and Development and Office of Toxic Substances, USEPA.

Versar Inc. 1980.  Exposure to commercial asbestos, sec 3: comparability of asbestos data. Preliminary
draft report. Washington, DC: Office of Pesticides and Toxic Substances, U.S. Environmental Protection
Agency. Contract No. 68-01-5791.

Yamate G, Agarwal SC, Gibbons RD. 1984.  Methodology for the  measurement of airborne asbestos by
electron microscopy. Draft report. Washington, DC: Office of Research and Development, U.S. Environmental
Protection Agency.  Contract No.  68-02-3266.
                                             R-2

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                 Appendix A.  Asbestos-Containing Materials Found in Buildings41
Subdivision
Surfacing material


Preformed thermal
insulating products


Textiles











Cementitious
concrete-like products











Paper products




Roofing felts



Generic name
sprayed- or
troweled-on

batts, blocks, and
pipe covering
85% magnesia
calcium silicate
cloth3
blankets (fire)3
felts
blue stripe
red stripe
green stripe
sheets
cord/rope/yarn3
tubing
tape/strip
curtains3
(theatre, welding)
extrusion panels
corrugated
flat
flexible
flexible/ perforated
laminated
(outer surface)
roof tiles
clapboard and shingles
clapboard
siding shingles
roofing shingles
pipe
corrugated
high temperature
moderate temperature
indented
millboard
smooth surface
mineral surface
shingles
pipeline
Asbestos (%)
1-95




15
6-8

100
90-95
80
90
95
50-95
80-100
80-85
90

60-65
8
20-45
40-50
30-50
30-50
35-50

20-30

12-15
12-14
20-32
20-15

90
35-70
98
80-85
10-15
10-15
1
10
Dates of use
1935-1970




1926-1949
1949-1971

1910-present
1920-present
1920-present
1920-present
1920-present
1920-present
1920-present
1920-present
1920-present

1945-present
1965-1977
1930-present
1930-present
1930-present
1930-present
1930-present

1930-present

1944-1945
unknown-present
unknown-present
1935-present

1 935-present
1910-present
1 935-present
1925-present
1 910-present
1910-present
1971-1974
1920-present
Binder/sizing
sodium silicate.
Portland cement,
organic binders.


magnesium carbonate
calcium silicate

none
cotton/wool
cotton
cotton
cotton
cotton/wool
cotton/wool
cotton/wool
cotton/wool

cotton
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement

Portland cement

Portland cement
Portland cement
protland cement
Portland cement

sodium silicate
starch
cotton and organic binder
starch, lime, clay
asphalt
asphalt
asphalt
asphalt

 The information in this Appendix is taken, with modification, from: Lory EE, Coin DC. February 1981. Management Pro-
 cedure for Assessment of Friable Asbestos Insulating Material. Port Hueneme, CA: Civil Engineering Laboratory Naval
 Construction Battalion Center.  The U.S. Navy prohibits the use of asbestos-containing materials when acceptable
 nonasbestos substitutes have been identified.
"Laboratory aprons, gloves, cord, rope, fire blankets, and curtains may be common in schools.
                                                     A-1

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                                   Appendix A. (continued)
Subdivision
Asbestos-containing
compounds












Asbestos ebony products
Flooring tile and
Sheet Goods

Generic name
caulking putties
adhesive (cold applied)
joint compound
roofing asphalt
mastics
asphalt tile cement
roof putty
plaster/stucco
spackles

sealants fire/water
cement, insulation
cement, finishing
cement, magnesia

vinyl/asbestos tile
asphalt/asbestos tile
sheet goods/resilient
Asbestos (%)
30
5-25

5
5-25
13-25
10-25
2-10
3-5

50-55
20-100
55
15
50
21
26-33
30
Dates of use
1930-present
1 945-present
1945-1975
unknown-present
1920-present
1959-present
unknown-present
unknown-present
1930-1975

1935-present
1900-1973
1920-1973
1926-1950
1930-present
1950-present
1920-present
1 950-present
Binder/sizing
linseed oil
asphalt
asphalt
asphalt
asphalt
asphalt
asphalt
Portland cement
starch, casein, synthetic
resins
caster oil or polyisobutylene
clay
clay
magnesium carbonate
Portland cement
polyl vinyl (chloride
asphalt
dry oils
Wallcovering
Paints and coatings
vinyl wallpaper
roof coating
air tight
                                                             unknown-present  —
4-7
 15
1 900-present
1 940-present
asphalt
asphalt
                                               A-2

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                  Appendix B. Common Units Used in Measuring
                         Airborne Asbestos Concentrations
Length

        1 meter (m)        = 39.37 inches or 3.28 feet
      100 centimeters (cm)  = 1 meter
1,000,000 micrometers (//m) = 1 meter

Volume
                          1 cubic m (m3)  =  35.3 cubic feet
1,000,000 cm3 = 1 m3
1,000cm3 = 1 liter
Weight (mass)

454 grams (g) = 1 pound
1,000,000,000 nanograms (ng)
1  gram
Concentration (mass contained in a stated volume)

2 fibers per cm3 (the current 8-hour OSHA industrial standard) means that 2 fibers are
present in each cm3 of air. Since there are 1 ,000,000 cm3 in 1 m3, there would be 2,000,000
fibers in a m3.

If each fiber is chrysotile asbestos (density of 0.0026 ng/yum3) and is just long and thick
enough to be detected by the NIOSH  procedure for determining compliance with the OSHA
standard (5 /jm in length and 0.3 /jrr\ in diameter), it would weight 0.0092 ng:
Mass = 77/4 (diameter)2 (length) (density)

       77-74 (0.3 A
-------
asbestos measured in air samples indicate that, on an average, about 30 fibers counted by the
NIOSH procedures equal one nanogram of asbestos. This relationship applies to samples
collected during the spray application of asbestos insulation. For these samples, each fiber
counted weighs an average of 0.033 ng, or about 37 times more than those in the example,
and 2,000,000 of them would weigh about 67,000 ng.
                                        B-2

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Appendix C.  USEPA National Emission Standards for Hazardous Air Pollutants
            (NESHAPS) Asbestos Regulations (40 CFR 61, Subpart M)
        AUTHORITY: Sees. 112 and 301(a) of the
      Clean Air Act, as amended (42 U.S.C. 7412,
      7601.
        SOURCE: 49 PR 13661, Apr. 5, 1984, unless
      otherwise noted.
      § 61.140  Applicability.
       The provisions of this  subpart are
      applicable to those sources specified in
      §§ 61.142 through 61.153.


      § 61.141  Definitions.
       All terms that are used in this sub-
      part and  are  not defined  below are
      given the  same meaning as  in the Act
      and in Subpart A of this part.
       Active waste disposal site means any
      disposal site  other than  an  inactive
      site.
       Adequately wetted means sufficiently
      mixed  or coated  with water or  an
      aqueous solution to prevent dust emis-
      sions.
       Asbestos means the asbestiform vari-
      eties of serpentinite (chrysotile), rie-
      beckite  (crocidolite),  cummingtonite-
      grunerite, anthophyllite,  and  actino-
      lite-tremolite.
       Asbestos-containing waste materials
      means any waste  that  contains  com-
      mercial asbestos and is generated by a.
      source subject to the provisions of
      this subpart. This term includes asbes-
      tos  mill tailings, asbestos waste  from
      control devices, friable asbestos waste
      material, and  bags  or containers that
      previously  contained  commercial  as-
      bestos. However, as applied to demoli-
      tion and  renovation  operations,  this
      term  includes  only friable asbestos
      waste and asbestos waste from control
      devices.
       Asbestos material means asbestos or
      any material containing asbestos.
       Asbestos mill means any facility en-
      gaged in converting, or in any interme-
      diate step in converting,  asbestos ore
      into  commercial   asbestos.  Outside
storage of asbestos material is not con-
sidered a part of the asbestos mill.
  Asbestos  tailings  means  any  solid
waste that contains asbestos and is a
product of asbestos  mining or milling
operations.
  Asbestos waste from control  devices
means any  waste material that con-
tains asbestos and is collected by a pol-
lution control device.
  Commercial asbestos means  any  as-
bestos  that  is extracted from asbestos
ore.
  Demolition means  the  wrecking or
taking  out  of  any load-supporting
structural member of a facility togeth-
er with any related handling  oper-
ations.
  Emergency  renovation  operation
means a renovation operation that was
not planned but results from a sudden,
unexpected  event. This term includes
operations necessitated by nonroutine
failures of equipment.
  Fabricating means any processing of
a manufactured product that contains
commercial  asbestos, with the excep-
tion of processing at temporary sites
for the construction or restoration of
facilities.
  Facility  means  any  institutional,
commercial, or industrial structure, in-
stallation,   or   building   (excluding
apartment buildings  having no  more
than four dwelling units).
  Facility component means any pipe,
duct, boiler, tank, reactor, turbine, or
furnace at or in a facility;  or any struc-
tural member of a facility.
  Friable asbestos  material means any
material containing  more than 1 per-
cent asbestos by  weight that  hand
pressure can  crumble,  pulverize,  or
reduce to powder when dry.
  Inactive waste  disposal site means
any disposal site or portion of it where
additional  asbestos-containing  waste
material will  not  be deposited and
where  the surface is not disturbed by
vehicular traffic.
                                          C-1

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  Manufacturing means the combining
of commercial asbestos—or, in the case
of woven friction  products,  the com-
bining of textiles containing commer-
cial    asbestos—with    any    other
material(s),  including  commercial as-
bestos, and the processing of this com-
bination into a product.
  Outside air means the  air outside
buildings and structures.
  Particulate asbestos material means
finely divided particles of asbestos ma-
terial.
  Planned   renovation   operations
means a renovation  operation, or  a
number  of such operations,  in which
the amount of friable asbestos materi-
al that  will be removed or stripped
within a given period  of time can  be
predicted. Individual nonscheduled op-
erations  are included if a number of
such  operations can  be predicted  to
occur during  a  given  period of time
based on operating experience.
  Remove means to take out friable as-
bestos materials from any facility.
  Renovation means  altering in any
way one or  more facility components.
Operations  in which load-supporting
structural  members are wrecked  or
taken out are excluded.
  Roadways means surfaces on which
motor vehicles  travel.  This term in-
cludes highways, roads, streets, park-
ing areas, and driveways.
  Strip means to take off friable asbes-
tos materials from any part of a facili-
ty.
  Structural member means any load-
supporting member of a facility, such
as beams and load supporting walls; or
any nonload-supporting member, such
as  ceilings  and  nonload-supporting
walls.
  Visible  emissions means  any  emis-
sions  containing particulate asbestos
material that are visually  detectable
without  the aid of instruments. This
does  not include  condensed uncom-
bined water vapor.
[49 FR 13661, Apr.  5, 1984; 49 FR 25453,
June 21, 1984]

§ 61.142   Standard for asbestos mills.
  Each owner or operator of an asbes-
tos mill  shall either discharge no visi-
ble emissions to the outside air from
that asbestos mill  or use the methods
specified by § 61.154 to clean emissions
containing particulate asbestos materi-
al before they escape to, or are vented
to, the outside air.

§ 61.143  Standard for roadways.
 No  person may surface a roadway
with asbestos tailings or asbestos-con-
taining waste material  on that road-
way, unless  it is a temporary roadway
on an area of asbestos ore deposits.

[49  PR 13661, Apr.  5,  1984; 49 FR 25453,
June 21, 1984]

§ 61.144  Standard for manufacturing.
 (a)  Applicability.  This section  ap-
plies  to the following manufacturing
operations using commercial asbestos.
 (1) The manufacture  of cloth, cord,
wicks,   tubing,   tape,   twine,  rope,
thread, yarn, roving, lap, or other tex-
tile materials.
 (2)  The  manufacture of  cement
products.
 (3) The manufacture of fireproof ing
and insulating materials.
 (4)  The  manufacture of  friction
products.
 (5) The manufacture  of paper, mill-
board, and felt.
 (6) The manufacture of floor tile.
 (7) The manufacture of paints, coat-
ings, caulks, adhesives, and sealants.
 (8) The manufacture of plastics and
rubber materials.
 (9) The manufacture of chlorine.
 (10)  The  manufacture of shotgun
shell wads.
 (11)  The  manufacture of  asphalt
concrete.
 (b) Standard. Each owner or opera-
tor of any of the manufacturing oper-
ations to which  this  section applies
shall either:
 (1) Discharge no visible emissions to
the outside  air from these operations
or from  any building or structure in
which they are conducted; or
 (2)  Use the  methods specified  by
§ 61.154 to clean emissions from these
operations containing particulate as-
bestos material before they escape to,
or are vented to, the outside air.

§61.145  Standard for demolition and ren-
    ovation: Applicability.
 The requirements of  §§61.146 and
61.147 apply to each owner or operator
                                   C-2

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of a  demolition or renovation  oper-
ation as follows:
  (a) If the amount of friable asbestos
materials in a  facility  being demol-
ished is at least 80 linear meters (260
linear feet) on pipes or at  least  15
square meters  (160  square feet) on
other facility  components,  all the re-
quirements  of  §§ 61.146 and  61.147
apply, except as provided in paragraph
(c) of this section.
  (b) If the amount of friable asbestos
materials in a  facility  being demol-
ished is less than 80 linear meters (260
linear feet)  on pipes  and less than  15
square meters  (160  square feet) on
other facility components, only the re-
quirements of paragraphs (a), (b), and
(c) (1), (2), (3), (4), and (5)  of §61.146
apply.
  (c) If the facility is being demolished
under an order of  a State or local gov-
ernmental agency, issued because the
facility is structurally unsound and in
danger of imminent collapse, only the
requirements in § 61.146 and  in  para-
graphs (d), (e), (f), and (g)  of § 61.147
apply.
  (d)  If at least 80 linear meters (260
linear feet) of friable asbestos materi-
als  on  pipes  or  at  least  15 square
meters (160 square feet) of friable as-
bestos materials on other facility com-
ponents  are stripped  or  removed at a
facility  being renovated, all the  re-
quirements  of  §§ 61.146 and  61.147
apply.
  (1) To determine whether  paragraph
(d) of this section applies to planned
renovation operations involving indi-
vidual nonscheduled  operations,  pre-
dict the additive amount of friable as-
bestos materials  to  be  removed  or
stripped  over the  maximum period  of
time a prediction  can be made, not  to
exceed 1  year.
  (2) To determine whether paragraph
(d) of this section applies to emergen-
cy renovation operations, estimate the
amount  of friable asbestos materials
to be removed  or  stripped as a result
of the sudden, unexpected  event that
necessitated the renovation.
  (e)  Owners or operators  of  demoli-
tion   and renovation  operations are
exempt  from  the  requirements  of
§§ 61.05(a), 61.07, and 61.09.
[49 FR 13661, Apr.  5, 1984; 49 PR  25453,
June 21, 1984]
§ 61.146  Standard for demolition and ren-
    ovation: Notification requirements.
  Each  owner  or operator  to  which
this section applies shall:
  (a)  Provide  the Administrator with
written notice of intention to demolish
or renovate.
  (b) Postmark or deliver the notice as
follows:
  (1)  At least 10  days  before demoli-
tion begins if  the  operation  is  de-
scribed in § 61.145(a);
  (2)  At least 20  days  before demoli-
tion begins if  the  operation  is  de-
scribed in § 61.145(b);
  (3) As early as possible before demo-
lition begins if the  operation  is  de-
scribed in § 61.145(c);
  (4) As early as  possible  before ren-
ovation begins.
  (c)  Include  the following informa-
tion in the notice:
  (1)  Name and address of  owner  or
operator.
  (2) Description of the facility being
demolished or  renovated,  including
the size, age, and prior use of the facil-
ity.
  (3)  Estimate  of  the approximate
amount  of friable  asbestos material
present in the facility in  terms   of
linear feet of pipe, and surface area on
other facility  components. For facili-
ties  described  in  § 61.145(b), explain
techniques of estimation.
  (4) Location of the facility being  de-
molished or renovated.
  (5)  Scheduled starting  and comple-
tion dates of demolition or renovation.
  (6) Nature of  planned demolition  or
renovation and method(s) to be used.
  (7) Procedures to be used to comply
with the requirements of this Subpart.
  (8) Name and location of the waste
disposal site where the friable asbestos
waste material will be deposited.
  (9)   For   facilities  described    in
§ 61.145(c),  the name,  title, and  au-
thority  of  the  State or local govern-
mental representative who  has ordered
the demolition.
(Approved  by the Office of  Management
and Budget under  control number 2000-
0264.)
[49 PR 13661, Apr.  5,  1984; 49 FR 25453,
June 21,  1984]
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§ 61.147  Standard for demolition and ren-
   ovation: Procedures for asbestos  emis-
   sion control.
  Each  owner  or  operator to whom
this section applies shall comply  with
the following procedures  to  prevent
emissions of particulate asbestos mate-
rial to the outside air:
  (a) Remove friable asbestos materi-
als from a facility being demolished or
renovated before any wrecking or dis-
mantling that would break up the ma-
terials or preclude access to the mate-
rials for subsequent removal. However,
friable asbestos materials need not  be
removed before demolition if:
  (1) They are on a facility component
that is encased in concrete or other
similar material; and
  (2) These materials are adequately
wetted whenever exposed during  dem-
olition.
  (b) When a facility component cov-
ered or  coated  with friable asbestos
materials is being taken out of the fa-
cility as units or in sections:
  (1) Adequately wet any friable asbes-
tos  materials exposed during cutting
or disjointing operations; and
  (2) Carefully lower the units or sec-
tions  to ground level, not  dropping
them or throwing them.
  (c) Adequately wet friable asbestos
materials  when   they  are  being
stripped  from  facility   components
before the members are removed  from
the facility. In renovation operations,
wetting   that  would   unavoidably
damage  equipment is not required if
the owner or operator:
  (1) Asks the Administrator to deter-
mine whether wetting to comply  with
this   paragraph  would   unavoidably
damage equipment, and,  before begin-
ning to strip, supplies the Administra-
tor   with  adequate  information  to
make this determination; and
  (2) When the Administrator does de-
termine that equipment damage would
be unavoidable, uses a local exhaust
ventilation and collection system de-
signed and  operated to  capture the
particulate asbestos material produced
by the stripping and removal  of the
friable asbestos materials. The system
must  exhibit  no visible emissions  to
the outside air or be  designed and op-
erated in accordance with the require-
ments in § 61.154.
  (d) After a  facility component has
been taken out of the facility as  units
or in sections, either:
  (1) Adequately wet friable  asbestos
materials during stripping; or
  (2) Use  a local  exhaust ventilation
and collection system designed and op-
erated to  capture the particulate as-
bestos material produced by the strip-
ping. The system must exhibit no visi-
ble emissions to the outside  air or be
designed and  operated  in accordance
with the requirements in § 61.154.
  (e)  For  friable asbestos materials
that have been removed or stripped:
  (1) Adequately wet the materials to
ensure  that  they remain wet  until
they are collected for disposal in ac-
cordance with § 61.152; and
  (2) Carefully lower the materials to
the ground or a lower floor, not drop-
ping or throwing them; and
  (3) Transport the materials to the
ground  via dust-tight  chutes or  con-
tainers if  they have been removed or
stripped  more  than 50 feet above
ground level and were not removed as
units or in sections.
  (f) When the  temperature  at the
point of wetting is below 0°C (32°F):
  (1) Comply with the requirements of
paragraphs (d) and (e) of this section.
The  owner  or  operator need  not
comply  with  the other  wetting re-
quirements in this section; and
  (2)  Remove  facility  components
coated or covered with friable asbestos
materials as units or in sections to the
maximum extent possible.
  (g)  For   facilities   described  in
§ 61.145(c), adequately wet the portion
of the facility that contains friable as-
bestos materials  during the  wrecking
operation.

8 61.148  Standard for spraying.
  The owner or operator of  an oper-
ation in which asbestos-containing ma-
terials are spray applied shall comply
with the following requirements:
  (a) Use materials that contain 1 per-
cent asbestos or less on a dry weight
basis for spray-on application on build-
ings, structures,  pipes,  and  conduits,
except as provided in paragraph (c) of
this section.
  (b) For spray-on application of mate-
rials that contain more than 1 percent
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asbestos on a  dry weight basis on
equipment and  machinery, except  as
provided in paragraph (c) of  this sec-
tion:
  (1) Notify the Administrator at least
20 days before beginning the  spraying
operation. Include the following infor-
mation in the notice:
  (i) Name and address of owner or op-
erator.
  (ii) Location of spraying operation.
  (iii)  Procedures  to  be followed  to
meet  the requirements of this para-
graph.
  (2) Discharge  no  visible emissions to
the outside air  from the spray-on ap-
plication  of the   asbestos-containing
material or use  the methods specified
by I 61.154 to clean emissions contain-
ing   particulate   asbestos   material
before they escape to, or are vented to,
the outside air.
  (c) The requirements of paragraphs
(a) and (b) of this section do not apply
to the spray-on application of materi-
als  where  the asbestos fibers  in the
materials are encapsulated with a bitu-
minous  or   resinous  binder   during
spraying and the materials are not fri-
able after drying.
  (d) Owners and operators of sources
subject to  this section  are  exempt
from  the requirements of §§61.05(a),
61.07, and 61.09.
(Approved  by the Office of Management
and Budget  under control  number 2000-
0264.)

§ 61.149  Standard for fabricating.
  (a)  Applicability.  This  section  ap-
plies to the  following fabricating oper-
ations using commercial asbestos:
  (1) The fabrication of cement build-
ing products.
  (2) The fabrication of friction prod-
ucts, except those operations  that pri-
marily install asbestos friction materi-
als on motor vehicles.
  (3)'The fabrication of cement or sili-
cate   board  for  ventilation   hoods;
ovens;  electrical  panels;  laboratory
furniture, bulkheads,  partitions, and
ceilings for marine construction; and
flow control devices  for the  molten
metal industry.
  (b) Standard.  Each owner or opera-
tor  of any of  the fabricating oper-
ations to which this section applies
shall either:
  (1) Discharge no visible emissions to
the outside air from any of the oper-
ations or from any  building or struc-
ture in which they are conducted; or
  (2)  Use  the methods  specified by
§ 61.154 to clean emissions containing
particulate  asbestos material  before
they escape  to,  or are vented to,  the
outside air.

§ 61.150  Standard for insulating materials.
  After the effective date of this regu-
lation, no owner or operator of a facili-
ty may install or reinstall on a facility
component  any  insulating materials
that  contain commercial  asbestos if
the materials are either molded and
friable or wet-applied and friable after
drying. The provisions  of this  para-
graph do not apply to spray-applied
insulating  materials regulated under
§61.148.

§ 61.151  Standard for waste  disposal for
    asbestos mills.
  Each owner  or  operator  of  any
source covered under the provisions of
§ 61.142 shall:
  (a)  Deposit all asbestos-containing
waste material at waste disposal sites
operated in accordance with the provi-
sions of § 61.156; and
  (b) Discharge no visible emissions to
the outside air from the transfer of as-
bestos waste from  control devices to
the tailings conveyor, or use the meth-
ods specified by § 61.154 to clean emis-
sions containing  particulate  asbestos
material before  they escape to, or are
vented to, the outside air. Dispose of
the  asbestos waste  from  control  de-
vices in accordance with § 61.152(b) or
paragraph (c) of this section; and
  (c) Discharge no visible emissions to
the outside air  during the collection,
processing, packaging, transporting, or
deposition of any asbestos-containing
waste material, or use one of the dis-
posal methods specified in paragraphs
(c) (1) or (2)  of this section, as  follows:
  (1) Use a wetting agent as follows:
  (i) Adequately mix all asbestos-con-
taining waste material with a  wetting
agent recommended by  the manufac-
turer of  the agent  to effectively wet
dust  and tailings,  before  depositing
the material at a waste disposal  site.
Use the agent as recommended for the
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particular  dust by the  manufacturer
of the agent.
  (ii)  Discharge no visible emissions to
the outside air from the wetting oper-
ation or use the  methods specified by
§ 61.154 to clean emissions containing
particulate  asbestos  material  before
they  escape to, or are vented to,  the
outside air.
  (iii) Wetting may be suspended when
the ambient temperature at the waste
disposal site is less than  -9.5°C (15°F).
Determine  the ambient air tempera-
ture by  an appropriate measurement
method   with   an   accuracy   of
itl°C(±2°F), and record  it  at least
hourly  while the  wetting operation is
suspended.  Keep the records  for at
least  2 years in a  form suitable for in-
spection.
  (2)   Use  an  alternative  disposal
method  that has received  prior  ap-
proval by the Administrator.

§61.152  Standard  for  waste disposal for
    manufacturing demolition, renovation,
    spraying, and fabricating operations.
  Each   owner  or operator of  any
source covered under the provisions of
§§61.144 and 61.149 shall:
  (a)  Deposit  all asbestos-containing
waste material at waste disposal sites
operated in accordance with the provi-
sions of § 61.156; and
  (b) Discharge no visible emissions to
the outside air during the collection,
processing   (including  incineration),
packaging,  transporting, or deposition
of any asbestos-containing waste mate-
rial generated  by the source,  or  use
one of the disposal methods specified in
paragraphs  (bXl), (2), or (3) of  this
section, as follows:
  (1)  Treat asbestos-containing  waste
material with water:
  (i) Mix asbestos waste from control
devices  with water to form a  slurry;
adequately wet other asbestos-contain-
ing waste material; and
  (ii)  Discharge no visible emissions to
the outside air from collection, mixing,
and wetting operations, or use  the
methods specified by § 61.154 to clean
emissions containing particulate asbes-
tos material before they escape to, or
are vented to, the outside air; and
  (iii) After wetting, seal all asbestos-
containing waste material in leak-tight
containers while wet; and
  (iv) Label the containers specified in
paragraph (bXIXiii) as follows:

              CAUTION
Contains Asbestos-
Avoid Opening or
Breaking Container
Breathing Asbestos is Hazardous
to Your Health

  Alternatively,  use  warning   labels
specified by Occupational Safety  and
Health Standards  of the Department
of  Labor,   Occupational Safety  and
Health Administration (OSHA)  under
29 CFR 1910.1001(g)(2)(ii).
  (2)    Process    asbestos-containing
waste material into nonfriable forms:
  (i)  Form  all   asbestos-containing
waste material  into nonfriable  pellets
or other shapes; and
  (ii) Discharge no visible emissions to
the  outside air from  collection  and
processing  operations,  or   use  the
methods specified by § 61.154 to clean
emissions containing particulate asbes-
tos material before they escape to, or
are vented to, the outside air.
  (3)  Use  an  alternative  disposal
method  that has  received  prior  ap-
proval by the Administrator.

[49 PR 13661, Apr. 5, 1984; 49 PR 25453,
June 21, 1984]

§61.153  Standard for  inactive waste  dis-
    posal  sites for asbestos mills and man-
    ufacturing and fabricating operations.
  Each owner or operator of any inac-
tive waste  disposal site that was oper-
ated by sources covered under §  61.142,
§ 61.144,  or § 61.149  and received  de-
posits  of   asbestos-containing   waste
material   generated  by the sources,
shall
  (a) Comply with one of the follow-
ing:
  (1) Either discharge no visible emis-
sions to the outside air from an inac-
tive waste  disposal site subject  to  this
paragraph; or
  (2)  Cover the  asbestos-containing
waste material  with at least 15  centi-
meters (6 inches) of compacted  nonas-
bestos-containing  material,  and grow
and maintain a cover of vegetation on
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the area adequate to prevent exposure
of the asbestos-containing waste mate-
rial; or
  (3)  Cover  the  asbestos-containing
waste material with at least 60 centi-
meters (2 feet) of compacted nonasbes-
tos-containing material,  and maintain
it to prevent exposure of the asbestos-
containing waste; or
  (4) For inactive waste disposal sites
for asbestos  tailings,  apply a resinous
or  petroleum-based dust  suppression
agent that effectively binds dust and
controls wind erosion. Use the agent as
recommended for the particular asbes-
tos tailings  by  the manufacturer of
the dust  suppression  agent.  Obtain
prior approval of the Administrator to
use other  equally  effective  dust  sup-
pression agents.  For  purposes of this
paragraph, waste crankcase  oil is not
considered a dust suppression agent.
  (b)  Unless  a natural  barrier  ade-
quately deters access by  the  general
public,  install  and maintain warning
signs and fencing as follows, or comply
with paragraph (a)(2) or (a)(3) of this
section.
  (1)  Display warning signs  at all en-
trances and at intervals of 100 m (330
feet) or less along the property line of
the site or along the perimeter of the
sections of the site where asbestos-con-
taining waste material was deposited.
The warning signs must:
  (i) Be posted in such  a manner and
location that a person can easily read
the legend; and
  (ii) Conform to the requirements for
51  cmx36  cm  (20"xl4")   upright
format signs  specified  in  29  CFR
 1910.145(d)(4) and this paragraph; and
  (iii) Display the  following legend in
the lower  panel with letter sizes and
styles of a visibility  at  least equal to
those specified in this paragraph.
Legend
Asbestos Waste Disposal Sta
Do Not Create Dust ....
Breathing Asbestos is Haz-
ardous to Vour Health
Notation
2.5 cm (1 inch) Sans Serif,
Gothic or Block
1 9 cm (% inch) Sans Sen*.
Gothic or Block
14 Point Gothic.
  (2) Fence the perimeter of the site in
a manner adequate to deter access by
the general public.
  (3) Upon request and  supply of ap-
propriate information, the Administra-
tor will determine whether a fence or
a  natural  barrier  adequately deters
access by the general public.
  (c) The owner or operator may use
an  alternative control  method  that
has received prior approval of the Ad-
ministrator rather than comply  with
the requirements of paragraph (a) or
(b) of this section.

§ 61.154  Air-cleaning.
  (a) The owner or operator who elects
to use  air-cleaning, as  permitted by
§§61.142,     61.144,     61.147(0(2),
61.147(d)(2),   61.148(b)(2),  61.149(b),
 Spacing between  any two  lines must
 be at least equal to the height of the
 upper of the two lines.
(ii), and 61.152(b)(2) shall:
  (1)  Use  fabric filter collection  de-
vices, except as noted in paragraph (b)
of this section, doing all of the follow-
ing:
  (i) Operating the fabric filter collec-
tion devices  at a pressure drop of no
more than .995  kilopascal (4 inches
water gage), as measured across the
filter fabric; and
  (ii)  Ensuring that the airflow perme-
ability,  as  determined   by  ASTM
Method  D737-75, does not  exceed 9
m3/min/m2 (30 ft3/min/ft2) for woven
fabrics or  H3/min/m2(35 ft3/min/ft2)
for felted  fabrics, except that 12 m3/
min/m2 (40 ft3min/ft2) for woven and
14  m3/min/m2  (45  ft 3min/ft2)  for
felted fabrics is  allowed  for  filtering
air from asbestos ore dryers; and
  (iii) Ensuring  that felted  fabric
weighs at  least  475 grams per square
meter (14 ounces per square yard) and
is at least  1.6  millimeters  (one-six-
teenth inch) thick throughout; and
  (iv) Avoiding  the use  of  synthetic
fabrics that contain  fill  yarn other
than  that which is spun.
  (2)  Properly install, use, operate, and
maintain  all air-cleaning equipment
authorized by this section. Bypass de-
vices  may be used only during upset or
emergency conditions and then only
for so long as it takes to shut down the
operation  generating the particulate
asbestos material.
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  (b)  There are the  following excep-
tions to paragraph (aXl):
  (1) If the use of fabric creates a fire
or explosion hazard, the Administra-
tor may authorize as a substitute the
use of wet collectors designed to oper-
ate with a unit contacting energy of at
least 9.95 kilopascals (40 inches water
gage pressure).
  (2) The Administrator may author-
ize  the  use  of  filtering  equipment
other  than that  described  in para-
graphs (aXI) and (bXl) of this section
if the owner or operator demonstrates
to  the  Administrator's  satisfaction
that it  is equivalent  to the described
equipment in  filtering particulate  as-
bestos material.

[49  PR 13661, Apr.  5, 1984; 49 FR 25453,
June 21, 1984]

§61.155  Reporting.
  (a) Within 90 days after  the effec-
tive date of this  subpart, each owner
or operator of any existing source to
which this subpart applies  shall pro-
vide the following information to the
Administrator, except that any owner
or operator who  provided this infor-
mation  prior to April 5,  1984 in order
to comply with § 61.24 (which this sec-
tion replaces)  is not required to resub-
mit it.
  (1)  A  description of  the  emission
control equipment used for each proc-
ess; and
  (2) If a fabric filter device is used to
control emissions,  the  pressure  drop
across the fabric filter in inches water
gage; and
  (i) If the fabric device uses a woven
fabric, the airflow permeability in m3/
min/m2 and; if the fabric is synthetic,
whether the fill  yarn is spun or not
spun; and
  (ii) If the fabric filter device uses a
felted fabric, the density in g/m2, the
minimum thickness in inches, and the
airflow permeability in m3/min/m2.
  (3) For sources  subject to §§61.151
and 61.152:
  (i) A brief description  of each proc-
ess  that generates asbestos-containing
waste material; and
  (ii) The average weight of asbestos-
containing waste  material disposed of,
measured in kg/day; and
  (iii) The emission  control methods
used in  all stages of water disposal;
and
  (iv) The type of disposal site or in-
cineration site used for ultimate dis-
posal, the name of the  site operator,
and the name and location of the dis-
posal site.
  (4) For sources subject to § 61.153:
  (i) A  brief  description of the site;
and
  (ii) The method or  methods used  to
comply  with  the standard, or alterna- ,
tive procedures to be used.
  (b)  The information required  by
paragraph (a) of this section must ac-
company  the information required by
§ 61.10.  The  information described  in
this  section  must be reported using
the format of Appendix A of this part.
(Approved  by  this Office of  Management
and Budget under  control number 2000-
0264)
(Sec. 114.  Clean Air Act as amended  (42
U.S.C. 7414))

§ 61.156  Active waste disposal sites.
  To be an acceptable site for disposal
of asbestos-containing waste material
under §§61.151 and 61.152, an active
waste disposal  site must meet the re-
quirements of this section.
  (a) Either there must be no  visible
emissions to  the outside air from any
active waste disposal site where asbes-
tos-containing waste material has been
deposited, or  the requirements   of
paragraph (c)  or (d) of this  section
must be met.
  (b)  Unless  a natural barrier ade-
quately deters access by the general
public, either warning signs and fenc-
ing must  be  installed  and  maintained
as follows, or  the  requirements  of
paragraph (c)(l) of this section must
be met.
  (1) Warning signs must be displayed
at all entrances and at intervals of 100
m (330  ft) or less  along the property
line of the site or along the perimeter
of the sections of the site where asbes-
tos-containing waste material is depos-
ited. The  warning signs must:
  (i) Be posted in such a manner and
location that a person can easily read
the legend; and
  (ii) Conform to  the  requirements of
51 cm x  36 cm (20" x 14") upright
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format signs  specified  in  29  CFR
1910.145(d)(4) and this paragraph; and
  (iii) Display the following legend in
the lower  panel with letter sizes and
styles  of a visibility  at  least equal to
those specified in this paragraph.
       Legend
Asbestos Waste  Disposal
 Site.
Do Not Create Oust	

Breathing Asbestos is Haz-
 ardous to Your Health
                          Notation
2.5 cm (1 inch) Sans Serif,
 Gothic or Block
1 9 cm (% inch) Sans Sent,
 Gothic or Block.
14 Point Gothic
                  _L
Spacing  between  any two  lines must
be at least equal to the height of the
upper of the two lines.
  (2)  The  perimeter of  the disposal
site must be fenced in a manner ade-
quate to deter  access by the general
public.
  (3) Upon request and supply of ap-
propriate information, the Administra-
tor will determine whether a fence or
a  natural  barrier adequately  deters
access by the general public.
  (c) Rather than meet the no visible
emission requirement of paragraph (a)
of this section, an active waste dispos-
al site would be  an acceptable site if at
the end of  each operating day, or at
least once every 24-hour period while
the site is in continuous operation, the
asbestos-containing   waste   material
which was deposited at the site during
the operating day or previous 24-hour
period is covered with either.
  (1) At least 15 centimeters (6 inches)
of compacted  nonasbestos-containing
material, or
  (2) A  resinous or petroleum-based
dust suppression agent that effectively
binds dust and  controls wind erosion.
This agent  must be used as  recom-
mended for  the particular dust by the
manufacturer of the dust suppression
agent.   Other  equally  effective  dust
suppression agents may be used upon
prior approval by the  Administrator.
For purposes of this paragraph, waste
crankcase oil is not considered a dust
suppression  agent.
  (d) Rather than meet the no visible
emission requirement of paragraph (a)
of this section, an active waste dispos-
al site  would be an acceptable site if
an  alternative   control  method  for
emissions that has received  prior ap-
proval by the Administrator is used.
(Sees. 112 and 301(a) of the Clean Air Act as
amended (42 U.S.C. 7412, 7601(a)>
                                    C-9

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                  Appendix D. Addresses of EPA NESHAPS Contacts
                         and Regional Asbestos Coordinators
NESHAPs Contacts
(For information on NESHAPs rule compliance and disposal)

Region 1
Asbestos NESHAPs Contact
Air Management Division
USEPA
JFK Federal Building
Boston, MA 02203
(617) 223-4872

Region 2
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
26 Federal Plaza
New York, NY 10007
(212) 264-4479

Region 3
Asbestos NESHAPs Contact
Air Management Division
USEPA
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6552

Region 4
Asbestos NESHAPs Contact
Air, Pesticide & Toxic Management
USEPA
345 Courtland Street N.E.
Atlanta, GA  30365
(404) 881-4901

Region 5
Asbestos NESHAPs Contact
Air Management Division
USEPA
230 S. Dearborn Street
Chicago, IL  60604
(312) 353-2088

Region 6
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
1201 Elm Street
Dallas, TX 75270
(214) 767-9835
Region 7
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2576

Region 8
Asbestos NESHAPs Contact
Air & Waste Management Division
USEPA
1860 Lincoln Street
Denver, CO 80295
(303) 293-1767

Region 9
Asbestos NESHAPs Contact
Air Management Division
USEPA
215 Fremont Street
San Francisco, CA  94105
(415) 974-7648

Region 10
Asbestos NESHAPs Contact
Air & Toxics Management Division
USEPA
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-2724
                                          D-1

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                                  Appendix D. (continued)
Regional Asbestos Coordinators
(For information on asbestos identification, health effects, abatement options, analytic techniques, asbestos in schools,
and contract documents)
Region 1
Regional  Asbestos Coordinator
USEPA
JFK Federal Building
Boston, MA 02203
(617) 223-0585

Region 2
Regional  Asbestos Coordinator
USEPA
Woodbridge Avenue
Edison, NJ 08837
(201) 321-6668

Region 3
Regional  Asbestos Coordinator
USEPA
841 Chestnut Street
Philadelphia,  PA 19107
(215) 597-9859

Region 4
Regional  Asbestos Coordinator
USEPA
345 Courtland Street N.E.
Atlanta, GA 30365
(404) 881-3864

Region 5
Regional  Asbestos Coordinator
USEPA
230 S. Dearborn Street
Chicago,  IL 60604
(312) 886-6879

Region 6
Regional  Asbestos Coordinator
USEPA
First International Building
1201 Elm Street
Dallas, TX 75270
(214) 767-5314
Region 7
Regional Asbestos Coordinator
USEPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2838

Region 8
Regional Asbestos Coordinator
USEPA
999 18th Street
Denver, CO 80202
(303) 293-1730

Region 9
Regional Asbestos Coordinator
USEPA
215 Fremont Street
San Francisco, CA 94105
(415) 974-8588

Region 10
Regional Asbestos Coordinator
USEPA
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-2632
                                            D-2

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Appendix E.  Phone Numbers for Obtaining Information and EPA
Publications
Information & Publications                 (202) 554-1404
                                        (in Washington, DC)


*  EPA Sealant Study

*  Publications

        Asbestos Fact Book.  EPA Office of Public Affairs.

     -  Asbestos Waste Management Guidance.  EPA 530-SW-85-007.

        Asbestos in Buildings:  Guidance for Service and
         Maintenance Personnel.  EPA 560/5-85-018.

        Asbestos in Buildings:  National Survey of Asbestos-
         Containing Friable Materials.  EPA 560/5-84-006.

        Evaluation of the EPA Asbestos-in-Schools Identification
         and Notification Rule.  EPA 560/5-84-005.

        Friable Asbestos-Containing Materials in Schools:
         Identification and Notification Rule (40 CFR Part 763).
                             E-l

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        Appendix F.  Occupational Health and Safety (OSHA)
               Asbestos Regulations (29 CFR 1910.1001)
§ 1910.1001  Asbestos.
  (a) Definitions.  For the purpose of
this section,  (1)  "Asbestos"  includes
chrysotile, amosite, crocidolite, tremo-
lite, anthophyllite, and actinolite.
  (2) "Asbestos fibers" means asbestos
fibers longer than 5 micrometers.
  (b) Permissible exposure to  airborne
concentrations of asbestos fibers—(1)
Standard effective July 7, 1972. The 8-
hour time-weighted average  airborne
concentrations of asbestos  fibers to
which any employee may be exposed
shall not  exceed five fibers, longer
than 5 micrometers, per cubic centime-
ter  of  air,  as  determined  by  the
method prescribed in paragraph (e) of
this section.
  (2) Standard effective July 1, 1976.
The 8-hour time-weighted average air-
borne concentrations of asbestos fibers
to which any  employee  may be ex-
posed  shall  not  exceed  two fibers,
longer than  5 micrometers, per cubic
centimeter of  air, as determined by
the  method  prescribed in  paragraph
(e) of this section.
  (3) Ceiling concentration.  No  em-
ployee shall be exposed at any time to
airborne  concentrations  of  asbestos
fibers  in  excess  of 10 fibers, longer
than 5 micrometers, per cubic centime-
ter  of  air,  as  determined  by  the
method prescribed in paragraph (e) of
this section.
  (c) Methods of compliance—(I) Engi-
neering methods,  (i) Engineering  con-
trols. Engineering controls, such as,
but not limited to, isolation, enclosure,
exhaust ventilation,  and dust collec-
tion, shall be used to meet the expo-
sure limits prescribed in paragraph (b)
of this section.
  (ii) Local  exhaust ventilation, (a)
Local exhaust ventilation and dust col-
lection systems shall be designed,  con-
structed, installed, and maintained in
accordance with the American Nation-
al Standard  Fundamentals Governing
the Design and Operation of Local Ex-
haust Systems, ANSI Z9.2-1971, which
is incorporated by reference herein.
  (6) See 11910.6 concerning the avail-
ability  of  ANSI  Z9.2-1971,  and  the
maintenance of a historic file in  con-
nection therewith. The address of the
American  National Standards  Insti-
tute is given in § 1910.100.
  (iii) Particular tools.  All hand-oper-
ated and power-operated tools  which
may produce or release asbestos fibers
in excess of the  exposure limits  pre-
scribed in paragraph  (b) of  this  sec-
tion, such as, but  not limited  to, saws,
scorers,  abrasive  wheels, and  drills,
shall be provided with local exhaust
ventilation systems in accordance with
subdivision (ii) of this subparagraph.
  (2) Work practices—(i) Wet methods.
Insofar as practicable,  asbestos shall
be handled, mixed, applied,  removed,
cut, scored, or  otherwise worked in a
wet  state  sufficient  to prevent  the
emission of airborne fibers in excess of
the exposure limits prescribed in para-
graph  (b) of this section,  unless  the
usefulness of the product would be di-
minished thereby.
  (ii)  Particular products  and oper-
ations.  No  asbestos  cement, mortar,
coating,  grout,  plaster,  or similar  ma-
terial containing asbestos shall be re-
moved from bags, cartons,  or other
containers in which they are shipped,
without  being  either wetted, or en-
closed, or ventilated  so  as to prevent
effectively the  release of airborne as-
bestos fibers in  excess  of  the limits
prescribed in paragraph (b) of this sec-
tion.
  (iii) Spraying, demolition,  or remov-
al. Employees engaged in the spraying
of asbestos, the removal, or demolition
of pipes, structures, or equipment  cov-
ered or insulated with asbestos, and in
the removal or demolition of asbestos
insulation or coverings shall be provid-
ed with  respiratory equipment in ac-
cordance with  paragraph (d)(2)(iii) of
this section and  with special clothing
in accordance with paragraph (d)(3) of
this section.
  (d) Personal  protective equipment—
(1) Compliance  with  the  exposure
limits  prescribed by paragraph (b) of
this section may not be achieved by
the use of respirators or shift rotation
of employees, except:
  (i) During the time period  necessary
to install the engineering controls and
to  institute the  work  practices  re-
quired by  paragraph (c) of this  sec-
tion;
  (ii) In  work situations in which the
methods prescribed in  paragraph (c)
of this section are either  technically
not feasible or feasible to an  extent in-
sufficient to reduce the airborne  con-
centrations of  asbestos fibers  below
the limits prescribed by paragraph (b)
of this section; or
  (iii) In emergencies.
  (iv) Where both respirators and  per-
sonnel rotation are allowed by para-
graphs (d)(l) (i), (ii), or (iii) of this sec-
tion, and both are practicable, person-
nel rotation shall be  preferred  and
used.
  (2) Where a  respirator is  permitted
by paragraph (d)(l) of this  section, it
shall be selected from among those ap-
proved by  the  Bureau  of Mines,  De-
partment of the Interior, or the  Na-
tional   Institute   for   Occupational
Safety  and  Health,  Department  of
                                    F-1

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Health, Education, and Welfare, under
the provisions of 30 CFR Part  11 (37
PR 6244, Mar.  25, 1972), and shall be
used in accordance  with  subdivisions
(i),  (ii), (iii), and (iv) of this subpara-
graph.
  (i) Air purifying respirators. A reus-
able or single use air purifying respira-
tor, or a respirator described in para-
graph (d)(2) (ii) or (iii) of this section,
shall be used to reduce  the concentra-
tions of airborne asbestos fibers in the
respirator below the exposure  limits
prescribed in paragraph (b) of this sec-
tion, when the  ceiling  or  the 8-hour
time-weighted  average  airborne con-
centrations of asbestos  fibers are rea-
sonably expected to  exceed  no more
than 10 times those limits.
  (ii)  Powered  air  purifying respira-
tors. A full facepiece powered air puri-
fying respirator, or a powered air puri-
fying respirator, or  a  respirator de-
scribed in paragraph  (d)(2)(iii) of this
section, shall  be used  to reduce the
concentrations   of  airborne  asbestos
fibers in  the respirator below the ex-
posure limits prescribed in paragraph
(b)  of this section, when the  ceiling or
the 8-hour time-weighted average con-
centrations of asbestos  fibers are rea-
sonably expected to exceed  10  times,
but not 100 times, those limits.
  (iii) Type  "C" supplied-air respira-
tors,  continuous  flow  or  pressure-
demand class. A type "C" continuous
flow or pressure-demand, supplied-air
respirator shall  be used to reduce the
concentrations   of  airborne  asbestos
fibers in  the respirator below the ex-
posure limits prescribed in paragraph
(b)  of this section, when the  ceiling or
the 8-hour time-weighted average air-
borne concentrations of asbestos fibers
are reasonably  expected to exceed 100
times those limits.
  (iv) Establishment  of a  respirator
program, (a) The employer  shall es-
tablish a respirator program in accord-
ance  with  the  requirements  of  the
American National  Standards  Prac-
tices for Respiratory Protection, ANSI
Z88.2-1969, which is  incorporated by
reference herein.
  (6) See § 1910.6 concerning  the avail-
ability of ANSI Z88.2-1969  and the
maintenance of a historic file in con-
nection therewith. The  address  of the
American  National  Standards Insti-
tute is given in § 1910.100.
  (c) No employee shall be assigned to
tasks  requiring the use of respirators
if, based upon his most recent exami-
nation, an examining physician deter-
mines  that   the  employee  will  be
unable to function normally wearing a
respirator, or that the safety or health
of the employee or other  employees
will be impaired by his use  of  a respi-
rator. Such employee shall  be  rotated
to another job or given the opportuni-
ty to  transfer to a different  position
whose duties  he  is able to perform
with the same employer, in the same
geographical area and with the same
seniority, status, and  rate of  pay he
had just  prior to such transfer, if such
a different position is available.
  (3) Special  clothing:  The employer
shall provide,  and require the use of,
special clothing,  such as coveralls or
similar whole  body clothing, head cov-
erings, gloves, and foot coverings  for
any employee  exposed to airborne con-
centrations of asbestos  fibers, which
exceed the ceiling level prescribed  in
paragraph (b)  of this section.
  (4) Change  rooms: (i) At any fixed
place  of  employment  exposed to air-
borne concentrations of asbestos fibers
in excess of the exposure limits  pre-
scribed in  paragraph (b) of this  sec-
tion,  the  employer   shall   provide
change rooms for employees working
regularly at the place.
  (ii)  Clothes  lockers: The employer
shall provide  two separate  lockers or
containers for each employee, so sepa-
rated  or isolated  as  to prevent con-
tamination  of the employee's street
clothes from his work clothes.
  (iii) Laundering: (a) Laundering of
asbestos  contaminated  clothing shall
be done so as to prevent the release of
air-borne  asbestos fibers  in excess of
the exposure limits prescribed in para-
graph (b) of this section.
  (6) Any  employer who gives asbes-
tos-contaminated clothing to  another
person  for laundering  shall  inform
such  person  of  the requirement in
paragraph (d)(4Xiii)(a) of this  section
to effectively  prevent the  release of
airborne  asbestos  fibers  in excess of
the exposure limits prescribed in para-
graph (b) of this section.
                                     F-2

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  (c) Contaminated  clothing shall be
transported  in   sealed  impermeable
bags,  or  other   closed,  impermeable
containers, and  labeled in accordance
with paragraph (g) of this section.
  
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Legend
Do Not Remain In Area Unless
Your Work Requires It
Breathing Asbestos Dust May Be
Hazardous To Your Health
Notation
V<" Gothic
14 point Gothic
Spacing between lines shall be at least
equal to the height of the  upper of
any two lines.
  (2) Caution labels—(i) Labeling. Cau-
tion  labels shall be affixed to all raw
materials,   mixtures,  scrap,  waste,
debris, and  other products containing
asbestos fibers, or to their containers,
except that no label is required where
asbestos fibers have been modified by
a bonding agent,  coating, binder, or
other material so that during any rea-
sonably  foreseeable   use,  handling,
storage, disposal, processing,  or trans-
portation, no airborne concentrations
of asbestos  fibers in excess of the ex-
posure limits prescribed  in paragraph
(b) of this section will be released.
  (ii) Label specifications. The caution
labels required by paragraph (g)(2)(i)
of this section shall be printed in let-
ters  of sufficient size and contrast as
to be readily visible and  legible.  The
label shall state:

              CAUTION

        Contains Asbestos Fibers

          Avoid Creating Dust

Breathing Asbestos Dust May Cause Serious
             Bodily Harm
  (h) Housekeeping—(1) Cleaning. All
external  surfaces in any place of em-
ployment shall be maintained free of
accumulations  of  asbestos  fibers if,
with their dispersion,  there would be
an excessive concentration.
  (2)  Waste disposal. Asbestos waste,
scrap, debris, bags, containers, equip-
ment,    and   asbestos-contaminated
clothing, consigned for disposal, which
may produce in any reasonably  fore-
seeable use, handling, storage, process-
ing,  disposal, or  transportation  air-
borne concentrations of asbestos fibers
in excess of the  exposure limits  pre-
scribed in paragraph (b) of this section
shall be  collected and disposed of in
sealed impermeable  bags,  or  other
closed, impermeable containers.
  (i)   Recordkeeping—(1)   Exposure
records.  Every  employer shall  main-
tain records of any personal or envi-
ronmental monitoring required by this
section. Records  shall be  maintained
for a period of at  least  20 years and
shall  be made available  upon request
to the Assistant Secretary of Labor for
Occupational Safety  and Health, the
Director of the National Institute for
Occupational Safety  and Health, and
to   authorized   representatives  6f
either.
  (2)   Access.   Employee   exposure
records required by this  paragraph
shall  be provided upon request to em-
ployees,  designated  representatives,
and the Assistant Secretary in accord-
ance with 29 CPR  1910.20 (a)-(e) and
(g)-(l).
  (3)  Employee notification. Any em-
ployee found to have been exposed at
any time to airborne concentrations of
asbestos fibers in excess of the limits
prescribed in paragraph (b) of this sec-
tion shall be notified in writing of the
exposure as soon  as practicable but
not later than  5  days of the finding.
The employee shall also  be timely no-
tified of the corrective  action being
taken.
  (j) Medical examinations—(1) Gen-
eral.  The employer shall provide or
make available at his cost, medical ex-
aminations relative to exposure to as-
bestos required by this paragraph.
  (2)  Preplacement.  The   employer
shall  provide  or make  available to
each of his employees, within 30 calen-
dar days following his  first employ-
ment in an occupation exposed to air-
borne   concentrations   of   asbestos
fibers, a comprehensive medical exam-
ination, which shall include, as a mini-
mum, a chest roentgenogram (posteri-
or-anterior 14 x  17 inches), a history
to elicit symptomatology of respirato-
ry  disease,  and  pulmonary function
tests  to include  forced vital  capacity
(FVC) and forced  expiratory  volume
at 1 second (FEV,.»).
  (3)  Annual  examinations.  On or
before January 31,  1973, and at least
annually thereafter,  every  employer
shall  provide, or  make available, com-
prehensive medical examinations to
each of his employees engaged in occu-
pations exposed to airborne concentra-
tions  of asbestos fibers.  Such annual
examination shall include, as a mini-
mum, a chest roentgenogram (posteri-
                                   F-4

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or-anterior 14 x 17 inches), a history
to elicit symptomatology of respirato-
ry  disease,  and pulmonary  function
tests to include forced vital capacity
(FVC)  and forced expiratory volume
at 1 second (FEV,.0).
  (4) Termination of employment. The
employer shall provide, or make avail-
able, within 30 calendar days before or
after the termination  of employment
of any employee engaged in an occu-
pation exposed to airborne concentra-
tions of asbestos fibers, a comprehen-
sive medical examination which shall
include, as a minimum, a chest roent-
genogram (posterior-anterior 14 x 17
inches), a history to elicit symptoma-
tology  of respiratory disease, and pul-
monary  function   tests  to  include
forced  vital capacity (FVC) and forced
expiratory   volume   at   1   second
(FEV,.o).
  (5) Recent examinations. No medical
examination is  required of  any em-
ployee, if adequate  records show that
the employee  has been  examined in
accordance with this paragraph within
the past 1-year period.
  (6)  Medical   records—(i)  Mainte-
nance. Employers of employees exam-
ined pursuant to this  paragraph shall
cause to  be  maintained complete and
accurate  records of all such medical
examinations. Records shall  be  re-
tained by employers  for  at least 20
years.
  (ii) Access. Records of the medical
examinations required by  this  para-
graph shall  be provided upon  request
to employees, designated representa-
tives, and the Assistant  Secretary in
accordance with 29 CPR  1910.20 (a)-
(e) and (g)-(i). These records shall also
be provided upon  the request to the
Director  of  NIOSH.   Any  physician
who conducts a medical examination
required  by this paragraph shall fur-
nish to the employer of the examined
employee all the information  specifi-
cally required by this paragraph, and
any other medical  information related
to occupational  exposure to  asbestos
fibers.
                                   F-5

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            Appendix G. Specifications for Sampling Materials and Selecting a
                        Qualified Laboratory to Analyze for Asbestos
G.1  Collecting Samples

Taking a sample of ACM can damage the material and cause significant release of fibers. The following
guidelines are designed to minimize both damage and fiber release.1

    • Wear at least a half-face respirator with disposable filters (see Section 5.1).

    • Wet the surface of the material to be sampled with water from a spray bottle or place a plastic
      bag around the sampler.

    • Sample with a reusable sampler such as a cork borer or a single-use sampler such as a glass
      vial. (Figure G-1  shows a single-use sampler constructed from an acrylic tube.)

    • With a twisting motion, slowly push the sampler into the material. Be sure to penetrate any
      paint or protective coating and all the layers of the material.

    • For reusable samplers, extract and eject the sample into a container. Wet-wipe the tube and
      plunger. For single-use samplers,  extract, wet-wipe  the exterior, and cap it.

    • Label the container.

    • Clean debris using  wet towels and discard them in a plastic bag.

    • For surfacing material, use latex paint or a sealant to cover the sample area. For pipe and boiler
      insulation,  use a nonasbestos mastic.
                            1/8" Wall
                                            Clear Acrylic Tube
               Beveled to
               Fine Edge
                                           Length Convenient
                                           to Hold in Hand
                                   Figure G-1 - Sampler/container
                                                                        End Cap
G.2  Selecting a Qualified Laboratory

The U.S. Environmental Protection Agency (EPA) runs a bulk asbestos sample quality assurance program.
Updated lists of participating laboratories, their performance scores, and further information on the pro-
gram are available from the Asbestos Technical Information Service at (800) 334-8571 (Extension 6741).
 1 The guidelines are based on information in John T. Jankovic, "Asbestos Bulk Sampling Procedure," American In-
  dustrial Hygiene Association, 46, B-8 to B-10, 1985.
                                              G-1

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                Appendix H.  Definition and Description of Factors for
                      Assessing the Need for Corrective Action*


H.I Condition of the Asbestos-Containing Material


H.1.1 Factors 1 and 2: Deterioration or Delamination and Physical Damage

An assessment of the condition should evaluate: the quality of the installation, the adhesion
of the friable material to the underlying substrate, deterioration, and damage from vandalism
or any other cause. Evidence of debris on horizontal surfaces, hanging material, dislodged
chunks, scrapings, indentations, or cracking are indicators of poor material condition.

Accidental or  deliberate physical contact with the friable material can result  in damage.
Inspectors should  look for any evidence that the asbestos-containing material has  been
disturbed: finger marks in the material, graffiti, pieces dislodged  or missing, scrape marks
from  movable equipment or furniture,  or accumulation of the friable material on floors,
shelves, or other horizontal surfaces.

Asbestos-containing  material  may deteriorate as a result  of  either  the  quality of the
installation  or environmental factors  which affect the cohesive strength  of the asbestos-
containing material or the strength of the adhesion to the substrate. Deterioration can result
in the accumulation of dust on the surface of the asbestos-containing material, delamination
of the material (i.e., separating into layers), or an adhesive failure of the material where it
pulls away from the substrate and either hangs loosely or  falls to  the floor and exposes the
substrate. Inspectors should touch the asbestos-containing material and determine if dust is
released when the material is lightly brushed or rubbed.

If the coated surface "gives" when slight hand pressure is applied or the material moves up
and down with light pushing, the asbestos-containing  material is no longer tightly bonded to
its substrate.

H.1.2 FactorS: Water Damage

Water damage is usually caused by roof leaks, particularly in buildings with flat roofs or a
concrete slab and steel beam construction. Skylights can also be significant sources of leaks.
Water damage can also result from plumbing leaks and water or high humidity in the vicinity
of pools, locker rooms, and lavatories.

Water can dislodge, delaminate, or disturb friable asbestos-containing materials that are
otherwise in good condition and can increase the potential for fiber release by dissolving and
washing out the binders in the material. Materials which  were not considered friable may
become friable after water has dissolved and leached out the binders. Water can also act as a
slurry to carry fibers to other areas where evaporation will leave a collection of fibers that can
become suspended in the air.

Inspect the area for visible signs of water damage, such as discoloration of or stains on the
asbestos-containing  material; stains on  adjacent walls or floors;  buckling of the walls or
*The information in this Appendix is taken, with  modification, from: Brandner, W. October 1982.
 Asbestos Exposure Assessment in Buildings Inspection Manual.  Kansas City, MO: U.S. Environ-
 mental Protection Agency, Region VII.
                                          H-1

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floors; or areas where pieces of the asbestos-containing material have separated into layers
or fallen down, thereby exposing the substrate.

Close inspection is required. In many areas, staining may occur only in a limited area while
water damage causing delamination may have occurred in a much larger area. In addition, the
water damage may have occurred since the original inspection for friable material, causing
new areas to become friable and require a reinspection.

Delamination is particularly a problem in areas where the substrate is a very smooth concrete
slab. Check to see if the material "gives" when  pressure is applied from underneath.


H.2  Potential for Disturbance or Erosion


H.2.1  Factor 4: Air Plenum or Direct Airstream
An air plenum exists when the return (or, in rare cases, conditioned) air leaves a room or hall
through vents in a suspended ceiling and travels at low speed and pressure through the space
between the actual ceiling and the suspended ceiling or ducts. The moving air may erode any
asbestos-containing  material in the plenum. In evaluating whether an air plenum or direct
airstream is present, the inspector must look for evidence of ducts or cavities used to convey
air to and from heating or cooling equipment or the presence of air vents or outlets which
blow air directly onto friable material.

A typical construction technique is to use the  space between a suspended ceiling and the
actual ceiling as a return air plenum. In many cases, the tiles in the suspended ceiling must be
lifted to check if this is the case. Inspection of the air handling or HVAC equipment rooms may
also provide evidence (such  as accumulated fibers) of the  presence of this material in the
plenums.

Special attention should be paid to whether frequent activities (such as maintenance) disturb
the material in the plenum. It is also important to check for evidence that the material is being
released or eroded (i.e., has  it deteriorated or been damaged so that the material is free to
circulate in the airstream?).
H.2.2 FactorS: Exposure, Accessibility, and Activity

These three considerations are highly interrelated and have been combined into a single
factor.  In general, for a site to show a high potential for disturbance, it must be exposed
(visible) and accessible, and be located near movement corridors or subject to vibration.

The amount of asbestos-containing material exposed to the area  occupied by people will
contribute to the likelihood that the material may be disturbed and  determines whether the
fibers can  freely move through the  area. An  asbestos-containing material  is considered
exposed if  it can be seen. For a  material not to be exposed, a physical barrier must be
complete,  undamaged, and  unlikely to be removed or  dislodged.  An asbestos-containing
material should be considered exposed if it is visible, regardless of the height of the material.

If the asbestos-containing material is located behind a suspended ceiling with movable tiles, a
close inspection must be made of the condition of the suspended ceiling; the likelihood and
frequency of access into the suspended ceiling, and whether the suspended ceiling forms a
complete barrier or is only partially concealing the material.

                                         H-2

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Asbestos-containing material above a suspended ceiling is considered exposed if the space
above the suspended ceiling is an air plenum. Suspended ceilings with numerous louvers,
grids, or other open spaces should be considered exposed.

If friable asbestos-containing material  can be reached by building users or maintenance
people, either directly or by impact from objects used in the area, it is accessible and subject to
accidental or intentional  contact and damage. Material which is accessible is  likely to be
disturbed in the future.

Height above the floor is one measure of accessibility. However, objects have been observed
embedded in ceilings 25 feet or more high.  Nearness of the friable asbestos-containing
material to heating, ventilation,  lighting and plumbing systems requiring maintenance or
repair may increase the material's accessibility.

In addition, the activities and behavior of persons using the building should be included in the
assessment of whether the material is accessible. For example, persons involved in athletic
activities may accidentally damage the material on the walls and ceilings of gymnasiums with
balls or athletic equipment. To become fully aware of occupants' use of the building, the
inspector should consult with building staff or personnel.

When assessing activity levels, consider not only the movement caused by the activities of
people but also movement  from other sources  such as high vibration from mechanical
equipment, highways, and airplanes. Another source of vibration is sound, such as music and
noise, which sets airwaves in motion at certain frequencies. As these sound waves impact on
asbestos-containing material, they may vibrate the material and contribute to fiber release.
Therefore, more fibers may be released in  a music practice room or auditorium  than in the
rest of the building.

The amount of activity of the occupants can best be described by identifying the purpose of the
area as well as estimating the number of persons who enter the area on a typical day.


H.2.3 Factor 6: Change in Building  Use

A planned change in the use of the building  from, for example, a junior to a senior  high school
may imply significant changes in the potential for erosion or disturbance. Of particular note is
the increased potential for damage from balls  to previously inaccessible ceilings in gymna-
siums. The addition of machinery (such as dust collectors in wood or metal shops) to a school
or office building may introduce vibrations  which, again, may be a future cause  of concern.
The inspector should exercise judgement and draw on experience  in evaluating the likely
effect of such changes.
                                        H-3

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                   Appendix I. Example Building Inspection Form
Room:	Sample Number(s):
Building:	Address :	
Evaluator:                               Phone No.:
Coated Area:  Ceiling  Wall(s)  Structural Members Above Suspended Ceiling
              Pipe Lagging      Boiler Insul.    Other:	
Type of
Ceiling:  Concrete      3 Coat Plaster System    Suspended Metal Lath
          Concrete Joists and Beams    Tile    Suspended Lay-In Panels
          Metal Deck      Corrugated Steel   Steel Beam or Bar Joists
Ceiling Height:	ft.
                                   r\
Ceiling Shape:    Flat             Dome            Other
                                                        (draw):
                 Folded Plate         Barrel
Type of Wall (If Coated):   Smooth Concrete    Rough Concrete    Masonry
                            Plasterboard    Other:
Amount of Friable Material in Area being Evaluated:	sq.  ft.
Description       Fibrous        Granular/Cementitious    Concrete Like
of Coating:   (highly friable)         (soft)                (hard)
Thickness:	inch(s)     Is thickness uniform:      Yes       No
Coating debris on Floor/Furniture/Work Surfaces:         Yes      No
Curtains, expandable partitions, etc. being pulled across coating:  Yes     No
Type of Lighting:    Surface Mounted       Suspended        Recessed
No. of Lights:	  Type of Heating/Cooling Systems:	
Type of Floor:   Concrete     Tile    Wood     Carpet    Other:	
What is above the room being evaluated?	
Comments:
                                      1-1

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1.1  Notes to Appendix I

The need for collecting most of the information on this form is discussed in Chapter 5 (Section 5.1).
The form requires one additional piece of information: the presence of curtains or expandable parti-
tions which are pulled across asbestos-containing material. Where this situation is found, the cur-
tains or partitions should be removed or repositioned to eliminate contact with the material. Any
damage to the asbestos-containing material then can be repaired.

This form was provided by Wolfgang Brandner, the Regional Asbestos Coordinator in Region
VII.
                                            I-2

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               Appendix J. Recommended Specifications and Operating
                     Procedures for the Use of Negative Pressure
                          Systems for Asbestos Abatement
J.1 Introduction

This appendix provides guidelines for the use of negative pressure systems in removing
asbestos-containing materials from buildings. A negative pressure system is one in
which static pressure in an enclosed work area is lower than that of the environment outside
the containment barriers.

The pressure gradient is maintained by moving air from the work area to the environment
outside the area via powered exhaust equipment at a rate that will support the desired air flow
and pressure differential. Thus, the air moves into the work area through designated access
spaces and any other barrier openings. Exhaust air is filtered by a high-efficiency particulate
air (HEPA) filter to remove asbestos fibers.

The use of negative pressure during asbestos removal protects against large-scale release of
fibers to the surrounding area in  case of a breach in the containment barrier. A negative
pressure system also can reduce the concentration of airborne asbestos in the work area by
increasing the dilution ventilation  rate (i.e., diluting contaminated air in the work area with
uncontaminated air from outside) and exhausting contaminated air through HEPA filters. The
circulation of fresh air through the  work area reportedly also improves worker comfort, which
may aid the removal process by increasing job productivity.
J.2 Materials and Equipment


J.2.1  The Portable, HEPA-Filtered, Powered Exhaust Unit

The exhaust  unit establishes lower pressure inside than outside the enclosed work area
during asbestos abatement. Basically, a unit (see Figure J-1)  consists of a cabinet with an
opening at each end, one for air intake and one for exhaust. A fan and a series of filters are
arranged inside the cabinet between the openings. The fan draws contaminated air through
the intake and filters and discharges clean air through the exhaust.

Portable exhaust units used for negative pressure systems in asbestos abatement projects
should meet the following specifications.


J.2.1.1 Structural Specifications

The cabinet should be ruggedly constructed and made of durable materials to withstand
damage from rough handling and transportation. The width of the cabinet should be less than
30 inches to fit through standard-size doorways. The cabinet must be appropriately sealed to
prevent asbestos-containing dust from being emitted during use, transport, or maintenance.
There should be easy access to all air filters from the intake end, and the filters must be easy
                                        J-1

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Inlet









^—



—

—
—

—

—



—
—
—
—
—
— -

ooooooooooooo c
                                                                             Exhaust
                             HEPA filter
    Rubber
    gasket
         Prefilter

             Intermediate
                filter

                  Figure J-1. An example of a HEPA-filtered exhaust unit. This scheme is
                                one of several possible designs.


to replace. The unit should be mounted on casters or wheels so it can be easily moved. It also
should be accessible for easy cleaning.
J.2.1.2  Mechanical Specifications
J.2.1.2.1 Fans

The fan for each unit should be sized to draw a desired air flow through the filters in the unit
at a specified static pressure drop. The unit should have an air-handling capacity of 1,000 to
2,000 ftVmin (under "clean" filter conditions). The fan should be of the centrifugal type.

For large-scale abatement projects, where the use  of a larger capacity, specially designed
exhaust system  may  be more practical  than several smaller units,  the fan  should be
appropriately sized according to the proper load capacity established for the application, i.e.,
                 Total ftVmin (load) =
Volume of air in ft3 x air changes/hour
            60 min/hour
                                          J-2

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Smaller-capacity units (e.g., 1,000 ftVmin) equipped with appropriately sized fans and filters
may be used to ventilate smaller work areas. The desired air flow could be achieved with
several units.
J.2.1.2.2 Filters

The final filter must be the HEPA type. Each filter should have a standard nominal rating of at
least 1,100 ftVmin with a maximum pressure drop of 1 inch hUO clean resistance. The filter
media (folded into closely pleated panels) must be completely sealed on all edges with a
structurally rigid frame and cross-braced as required. The exact dimensions of the filter
should correspond with  the  dimensions of the filter housing  inside the cabinet or the
dimensions of the filter-holding frame. The recommended standard size HEPA filter is 24
inches high x 24 inches wide x 11-1/2 inches deep. The overall dimensions and squareness
should be within 1 /8 inch.

A continuous rubber gasket must be located between the filter and the filter housing to form a
tight seal. The gasket material should be 1 /4 inch thick and 3/4 inch wide.

Each filter  should be  individually tested and certified  by the  manufacturer  to have an
efficiency of not less than 99.97 percent when challenged with 0.3-/vm dioctylphthalate (OOP)
particles. Testing should be in accordance with Military Standard Number 282 and Army
Instruction Manual 136-300-1 75A. Each filter should bear a UL586 label to indicate ability to
perform under specified conditions.

Each filter should  be marked with: the name of the manufacturer, serial number, air flow
rating, efficiency and resistance, and the direction of test air flow.

Prefilters, which protect the final filter by removing the larger particles, are recommended to
prolong the operating life of the HEPA filter. Prefilters prevent the premature loading of the
HEPA filter. They can also save energy and cost. One (minimum) or two (preferred) stages of
prefiltration may be used. The first-stage prefilter should be a low-efficiency type (e.g., for
particles 10 yum and larger). The second-stage (or intermediate) filter should have a medium
efficiency (e.g., effective for particles down to 5 fjm). Various types of filters and filter media
for prefiltration applications are available from many manufacturers. Prefilters and inter-
mediate filters should be installed either on or in the intake grid of the unit and held in place
with special housings or clamps.


J.2.1.2.3 Instrumentation

Each  unit should  be  equipped with a Magnehelic gauge  or manometer  to measure the
pressure drop across the filters and indicate when filters have become loaded and need to be
changed. The static pressure across the filters (resistance) increases as they become loaded
with dust, affecting the ability of the unit to move air at its rated capacity.


J.2.1.3  Electrical
J.2.1.3.1 General

The electrical system should have a remote fuse disconnect. The fan motor should be totally
enclosed, fan-cooled,  and the nonoverloading type. The unit must use a standard 115-V,
                                         J-3

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single-phase, 60-cycle service. All electrical components must be approved by the National
Electrical Manufacturers Association (NEMA) and Underwriter's Laboratories (UL).
J.2.1.3.2 Fans

The motor, fan, fan  housing, and cabinet should be grounded. The unit should have an
electrical (or mechanical) lockout to prevent the fanffrom operating without a HEPA filter.


J.2.1.3.3 Instrumentation

An automatic shutdown system that would stop the fan in the event of a major rupture in the
HEPA filter or blocked  air discharge is recommended. Optional warning lights are recom-
mended to indicate normal operation, too high of a pressure drop across the filters (i.e., filter
overloading), and too low of a pressure drop (i.e.,  major rupture in HEPA filter or obstructed
discharge). Other optional instruments  include a timer and automatic shut-off and an elapsed
time meter to show the total accumulated hours of operation.


J.3 Setup and  Use of a Negative Pressure System


J.3.1 Preparation of the Work Area


J.3.1.1 Determining  the Ventilation Requirements for a Work Area

Experience with negative  pressure  systems on  asbestos abatement projects indicates a
recommended rate of one air change every 15 minutes. The volume (in ft3) of the work area is
determined by multiplying the floor area by the ceiling height. The total air flow requirement
(in ftVmin) for the work area is determined by dividing this volume by the recommended air
change rate (i.e., one  air change every 15 minutes).*

                  Total ftVmin = Volume of work area (in ft3)/"! 5 min

The number of units needed for the application is determined by dividing the total ftVmin by
the rated capacity of the exhaust unit.

            Number of units needed = [Total ft3/min]/[Capacity of unit (in ft3)]


J.3.1.2 Location of Exhaust Units

The exhaust unit(s) should be located so  that makeup air enters the work area primarily
through the decontamination facility and traverses the work area as much as possible. This
may be accomplished by positioning the exhaust unit(s)  at a maximum distance from the
worker access opening or other makeup air sources.

Wherever  practical, work area exhaust units  can  be located on the floor in or near unused
doorways or windows. The end of the unit or its  exhaust duct should be placed through an
opening in the plastic barrier or wall covering.  The plastic around the unit or duct should then
be sealed with tape.
fThe recommended air exchange rate is based on engineering judgment.
                                         J-4

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Each unit must have temporary electrical power (115V AC). If necessary, three-wire extension
cords can supply power to a unit. The cords must be in continuous lengths (without splice), in
good condition, and should not be more than 100 feet long. They must not be fastened with
staples, hung from nails, or suspended by wire. Extension cords should be suspended off the
floor and out of workers' way to protect the cords from damage from traffic, sharp objects, and
pinching.

Wherever possible, exhaust units should be vented to the outside of the building. This may
involve the use of additional lengths of flexible or rigid duct connected to the air outlet and
routed to the nearest outside opening. Windowpanes  may have to be removed temporarily.

If  exhaust  air cannot be vented  to the  outside of the building or if  cold temperatures
necessitate measures to conserve heat and minimize cold air infiltration,  filtered air that has
been exhausted through the barrier may be recirculated into an adjacent area. However, this
is  not recommended.

Additional makeup air may be necessary to avoid creating too high of a pressure differential,
which could cause the plastic coverings and temporary barriers to "blow in." Additional
makeup  air also may  be needed  to  move  air most  effectively through the work area.
Supplemental  makeup air inlets may be made by making openings in the plastic sheeting that
allow air from outside the building into the work area. Auxiliary makeup air inlets should be as
far as possible from the exhaust unit(s) (e.g., on an opposite wall), off the floor (preferably near
the ceiling), and away from barriers that separate the work area from occupied clean areas.
They should be resealed whenever the negative pressure system is turned off after removal
has started. Because the pressure differential (and ultimately the effectiveness of the system)
is  affected by the adequacy of makeup air, the number of auxiliary air inlets should be kept to a
minimum to maintain negative pressure. Figure J-2 presents examples of negative pressure
systems denoting the location of HEPA-filtered exhaust units and the direction of air flow.


J.3.2 Use of the Negative  Pressure System


J.3.2.1 Testing the System

The  negative pressure system should  be tested before any asbestos-containing material is
wetted or removed. After the work area has been prepared, the decontamination facility set
up, and the exhaust unit(s) installed, the unit(s) should be started (one at a time). Observe the
barriers and plastic sheeting. The plastic curtains of the decontamination facility should move
slightly  in toward the work area. The  use of ventilation smoke tubes and a rubber bulb is
another easy and inexpensive way to visually check system performance  and direction of air
flow through openings  in the barrier. Another test is to use a Magnehelic gauge (or other
instrument) to measure the static  pressure differential across the barrier. The measuring
device must be sensitive enough to detect a relatively low pressure drop. A Magnehelic gauge
with a scale of 0 to 0.25 or 0.50 inch of H2O and 0.005 or 0.01  inch graduations is generally
adequate. The  pressure drop across the barrier is measured from the outside by punching a
small hole in the plastic barrier and inserting one end of a piece of rubber or Tygon tubing. The
other end of the tubing is connected to the "low pressure" tap  of the instrument. The "high
pressure" tap must be open to the atmosphere. The pressure is read directly from the scale.
After the test is completed, the hole in the barrier must be patched.
                                         J-5

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                               r4
                                                        Exhaust duct
                                                        vented to
                                                        window
Wt
                                           DF

                       DF
                                                                          Auxiliary
                                                                        I  makeup air
                                                                            DF
Figure J-2. Examples of negative pressure systems. DF, Decontamination Facility; EU, Exhaust Unit; WA, Worker
Access; A, Single-room work area with multiple windows; B, Single-room work area with single window near
entrance; C, Large single-room work area with windows and auxiliary makeup air source (dotted arrow). Arrows
denote direction of air flow Circled numbers indicate progression of removal sequence.
                                              J-6

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J.3.2.2 Use of System During Removal Operations

The exhaust units should be started just before beginning removal (i.e., before any asbestos-
containing material is disturbed). After removal has begun, the units should run continuously
to maintain a constant negative pressure until decontamination of the work area is complete.
The units should not be turned off at the end  of the work shift or when removal operations
temporarily stop.

Employees  should start  removing  the  asbestos material at a location farthest from  the
exhaust units and work toward them. If an electric power failure occurs, removal must stop
immediately and should not resume until power is restored and exhaust units are operating
again.

Because airborne asbestos fibers are microscopic in size and tend to remain in suspension for
a long time, the exhaust units must keep operating throughout the  entire  removal and
decontamination processes. To ensure continuous operation, a spare unit should be available.

After asbestos removal equipment has been moved from the work area, the  plastic sheeting
has been cleaned, and all surfaces in the work area have been wet-cleaned, the exhaust units
can be allowed to run for at least another 4 hours to remove airborne fibers that may have
been generated during wet removal and cleanup and to purge the work area with clean
makeup air. The  units may be allowed to run for a  longer  time  after decontamination,
particularly if dry or only partially wetted asbestos material was encountered  during removal.


J.3.2.2.1  Filter Replacement

All filters must be accessible from the work area or "contaminated" side of the barrier. Thus,
personnel responsible for changing filters while the negative pressure system is in use should
wear approved respirators and other protective equipment. The operating life of a HEPA filter
depends on the level  of particulate contamination in the environment in which it is used.
During use, filters will become loaded with dust, which increases resistance to air flow and
diminishes the air-handling capacity of  the unit. The difference in pressure drop across the
filters between "clean" and "loaded" conditions (AP) is a convenient  means of estimating the
extent of air-flow resistance and determining when the filters should be replaced.

When AP across the filters (as determined by the Magnehelic gauge or manometer on the
unit) exceeds 1.0 inch of H2O, the prefilter should be replaced  first.  The prefilter, which fan
suction will generally hold in place on  the intake grill,  should be  removed with the unit
running by carefully rolling or folding in its sides. Any dust dislodged from the prefilter during
removal will be collected on the intermediate filter. The used prefilter should be placed inside
a plastic bag, sealed and labeled, and disposed of as asbestos waste. A new prefilter is then
placed on the intake grill. Filters for prefiltration applications may be  purchased as individual
precut panels or in a roll of specified width that must be cut to size.

If the AP still exceeds  1.0 inch of HaO after the prefilter has been replaced, the intermediate
filter is replaced. With the unit operating, the prefilter should be removed, the intake grill or
filter access opened,  and the intermediate filter removed. Any dust  dislodged from  the
intermediate filter during removal will be collected on the  HEPA filter. The used intermediate
filter should be placed in a sealable plastic bag (appropriately labeled) and disposed of as
asbestos waste. A new replacement filter is then installed  and the grill or access closed.
Finally, the prefilter on the intake grill should be replaced.
                                        J-7

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The HEPA filter should be replaced if prefilter and/or intermediate filter replacement does not
restore the pressure drop across the filters to its original clean resistance reading or if the
HEPA filter becomes damaged. The exhaust unit is shut off to replace the HEPA filter, which
requires removing the prefilter first, then opening the intake grill or filter access, and finally
removing  the HEPA filter from the unit. Used  HEPA filters  should be placed in a scalable
plastic bag (appropriately labeled) and  disposed of as asbestos waste.  A new HEPA filter
(structurally identical  to the original filter) should then be installed. The intake grill  and
intermediate filter should be put back in place, the unit turned on, and the prefilter positioned
on the intake grill. Whenever the HEPA filter  is replaced, the prefilter and intermediate filter
should also be replaced.

When several exhaust units are used to ventilate a work area, any air  movement through an
inactive unit during the HEPA filter replacement will be into the work area. Thus, the risk of
asbestos fiber release to the outside environment is controlled.

Any filters used in the system may be replaced more frequently than the pressure drop across
the filters indicates is  necessary. Prefilters, for example, may be replaced two to four times a
day or when accumulations of particulate matter become visible. Intermediate filters must be
replaced once every day or so,  and the HEPA filter may be replaced at the beginning of each
new project. (Used  HEPA filters must be disposed of as asbestos-containing waste.) Condi-
tions in the work area dictate the frequency of filter changes. In a work area where  fiber
release is effectively controlled by thorough wetting and good work  practices, fewer filter
changes may be required than in work areas where the removal process is not well controlled.
It  should also be noted that the collection efficiency of  a filter generally improves as
particulate accumulates on  it. Thus, filters can be used effectively until resistance (as a result
of excessive particulate loading) diminishes the exhaust capacity of the unit.
 J.3.2.3 Dismantling the System

 When a final  inspection and the results of final air tests indicate that the area has been
 decontaminated, all filters of the exhaust units should be removed and disposed of properly
 and the units shut off. The remaining barriers between contaminated and clean areas and all
 seals on openings  into the work area and fixtures  may be  removed and disposed  of as
 contaminated waste. A final check should be made to be sure that no dust or debris remain on
 surfaces as a result of dismantling operations.
                                        J-8

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             Appendix K. Checklist for Determining Contractor Qualifications


a.   Contractors shall demonstrate reliability in performance of general contracting activities through the
     submission of a list of references of persons who can attest to the quality of work performed by the
     contractor.

b.   Contractors must demonstrate ability to perform asbestos abatement activities by submitting evidence
     of the successful completion of training courses covering asbestos abatement. At a minimum, the
     contractor shall furnish proof that employees have had instruction on the dangers of  asbestos ex-
     posure,  on respirator use, decontamination, and OSHA regulations.

c.   Contractors must be able to demonstrate prior experience in performing previous abatement projects
     through the submission of a list of prior contracts, including: the names, addresses, and telephone
     numbers of building owners for whom the projects were performed. In rare circumstances inexperienced
     contractors may be qualified if they can demonstrate exceptional qualifications in the other contrac-
     tor standards.

d.   Additional evidence of successful completion of prior  abatement projects should be demonstrated
     by contractors through the submission of air monitoring data, if any, taken during and after comple-
     tion of previous projects in accordance with 29 CFR 1910.1001 (e).

e.   Contractors must possess written standard operating procedures and employee protection plans which
     include specific reference to OSHA medical monitoring and respirator training programs. In addition,
     the contractor must be prepared to make available for viewing at the job site a copy of OSHA regula-
     tions at 29 CFR 1910.1001 governing asbestos controls,  and Environmental Protection Agency regula-
     tions at 40 CFR Part 61, Subpart M, (NESHAPS) governing asbestos stripping work practices, and
     disposal of asbestos waste.

f.    In those States which have contractor  certification programs,  contractors must possess State cer-
     tifications  for the performance of asbestos abatement projects.

g.   Contractors must be able to provide a description of any  asbestos abatement projects which have
     been prematurely terminated, including the circumstances surrounding the termination.

h.   Contractors must provide a list of any contractual penalties which the contractor has paid for breach
     or noncompliance with contract specifications, such as overruns of completion time or liquidated
     damages.

i.    Any citations levied  against the contractor by any  Federal, State, or local government  agencies for
     violations related to asbestos abatement, shall be identified by contractors, including  the name or
     location  of the project, the date(s), and how the allegations were resolved.

j.    Contractors must submit a description detailing all legal proceedings, lawsuits or claims which have
     been filed or  levied against the contractor or any of his past or present employees for asbestos-related
     activities.

k.   Contractors must supply a list of equipment that they have available for asbestos work. This should
     include negative air machines, type "C" supplied air systems, scaffolding, decontamination facilities,
     disposable clothing, etc.
                                              K-1

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                Appendix L. Guide Specifications for Abatement Projects


The following organizations have developed contract specifications that can be used as a guide for abate-
ment projects:

Association of the Wall/Ceiling Industries—International, Inc.
   Guide Specifications for the Abatement of Asbestos Release from Spray- or Trowel-Applied Materials
   in Buildings and Other Structures. December 1981. The Foundation of the Wall and Ceiling Industry,
   25 K Street, N.E., Washington, DC 20002 USA.

Maryland State Department of Health and Mental Hygiene
   Recommended Contract Specifications for Asbestos Abatement Projects.

Federal Construction Guide Specifications (FCGS): 02085. Asbestos Abatement Procedures.

GSA Guide Specifications PBS (PCD): 02085. Asbestos Abatement Procedures.
                                            L-1

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                 Appendix M. Detailed Specifications for Sampling and
                               Analyzing Airborne Asbestos


The following specifications are summarized from "Measuring Airborne Asbestos Following an Abatement
Action" (USEPA 1985).
M.1  Sampling


M.1.1   Sampling Equipment

Standard sampling equipment consists of a pump (operated at a 2 to 12 liter per minute flow rate), a filter
in a cassette and associated tubing and  supports. Three types of filters can be used:

   PCM — cellulose ester with 0.8 to 1.2 /vm pore  size;

   TEM — polycarbonate with 0.4 //m pore size (preferred); or cellulose ester with 0.8 jjrr\ pore size.


M.1.2  Number of Samples


M.1.2.1   TEM

A minimum of five samples inside and five outside the work site is recommended. When a negative air
pressure ventilation system has been used during the abatement operation the "outside" samples should
be collected outside the work site, but  inside the building. This provides a comparison between the work
site and the incoming air. If a negative air pressure ventilation system has not been used, the "outside"
samples should be collected outdoors.  These sample  sizes are based on calculations of statistical reliabili-
ty and on the following characteristics:

   •  The coefficient of variation for TEM measurements is between 100% and 150% based on data
      from EPA research studies.

   •  A false positive rate of .10 (i.e., based on the statistical test comparing  inside and outside
      measurements, 10% of the "clean" work sites will fail and have to be recleaned).

   •  A false negative rate of at  most .10 (i.e., the statistical  test comparing  inside and outside
      measurements will identify at least 90% of the sites that must be recleaned).


M.1.2.2   PCM

A minimum of five samples is recommended. A sample size of five controls the false negative error rate.
At least 90% of the sites where the actual fiber concentration exceeds 0.01 f/cc will fail the test. If the actual
concentration is 0.02 f/cc the probability of failure is  99%.
                                             M-1

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M.1.3  Location of Samplers

M.1.3.1  Indoors

Indoor samplers should be placed so they are not influenced by unusual air circulation patterns. Avoid
corners of rooms and obstructions (like furniture). Within the above constraints, samplers should be plac-
ed at random around the work site. For example, if the site is a single room of 1000 or more sq.  ft., the
five samplers should be distributed in an approximately uniform manner. If the site includes more than
five rooms, the rooms to be sampled may be selected randomly. The companion EPA document (USEPA
1985) describes this procedure in more detail.

When TEM is used for the air test and a negative air pressure ventilation system has been employed dur-
ing the abatement operation, the five "outside" samplers should be placed outside the work site but inside
the building, and the negative air system left  running during sampling. These outside samplers  should
be located to avoid any air that might  escape  through the containment barriers. Minimum recommenda-
tions are at least 50 ft. from the entry portal to the work site, or 25 ft. from the plastic containment barriers.

M.1.3.2 Outdoors

If TEM is to be used for the air test and a negative air pressure ventilation system has not been used dur-
ing abatement, then five samplers should be  placed outdoors. These should be placed at ground level
(about 2 meters high), if possible, and  away from obstructions that may influence wind patterns. If access
to electricity and concerns about security dictate a roof-top site, do not place samplers near vents or other
structures on the roof.

M.1.4  Sampling Volumes

M.1.4.1  TEM

The required sampling volume for the TEM air test is calculated from the theoretical detection limit of the
TEM analysis procedures, and from typical  levels of asbestos against which measurements in the work
site will be compared:

        Volume =    d  f/10 grid squares)    x   (855 mm*)    x  _J1Jiter)_ =  3Q54 ^n
                         (0.005 f/cc)           (0.0056 mm2)      (1000 cc)


Where:  •  1 f/10 grid squares (the maximum recommended filter counting area) is the smallest number
           of fibers needed  to make a non-zero measurement. (This is below the limit of reliable
           quantification.)

        •  0.005 f/cc is a typical outdoor asbestos level in urban areas,  as measured by TEM (Chat-
           field 1983).

        •  855 mm2 is the collection area  of a 37 mm diameter filter.

        •  0.0056  mm2 Is the area of each grid square (75 fjm per side) in  a 200 mesh electron
           microscope grid. This value will vary from 0.0056 to 0.0081 mm2 for different grids. Larger
           grid squares  will  improve  measurement accuracy for the same sampling volume.


This equation is appropriate for TEM analysis using a direct sample transfer technique (see Section  M.2.1).
If an indirect technique is used, the required sampling volume is increased in proportion to the dilution
used. For  example, if the sample is diluted by a factor of 10, the required volume is 10 times larger.


                                             M-2

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M.1.4.2   PCM

The equivalent PCM  limit of reliable quantification for a sampling volume of 3000 liters is:

    Quantification =      (10 f/100 fields)	  x    (855 mm*)    x   (1 liter)   =  Q(J1 f/cc
        Limit              (3000 liters)            (0.003 mm2)       (1000 cc)


Where:   •  10 f/100 fields is the limit of reliable  quantification for the P&CAM 239 method.

         •  855 mm2 is the collection area of a 37 mm diameter filter.

         •  0.003 mm2 is the size of a typical field of view for a PCM microscope. This value will vary
           from 0.003 to 0.006 mm2 for different  microscopes.  Larger fields of view  will improve
           (decrease) the limit of reliable quantification.

By increasing the sampling volume, the PCM test criterion can be made proportionally more stringent:

                        Volume                    Quantification Limit

                        3000 liters                     0.01 f/cc
                        5000                          0.006
                        7500                          0.004

If the sampling scheme associated with the new NIOSH 7400 PCM method is used, the limit of reliable
quantification will  be  lower for the same sampling  volume.



M.1.5   Aggressive Sampling

Procedures for sampling aggressively are:

         •  Before starting the sampling pumps,  direct the exhaust from forced air equipment (such
           as a 1  horsepower leaf blower) against all walls, ceilings, floors, ledges and other surfaces
           in the room.  This  should take  at least 5 minutes per  1000 sq. ft. of floor.

         •  Place a 20-inch fan in the center of the room. (Use one fan per 10,000 cubic feet of room
           space.) Place the  fan on slow speed and point it toward the ceiling.

         •  Start the  sampling pumps and sample for the required time.

         •  Turn off the pump and then the fan(s) when sampling is complete.


M.2  Analysis



M.2.1   TEM

Use the update to the EPA provisional method (Yamate 1984). The sample should be transferred directly
from the polycarbonate filter to the electron microscope grid. If high levels of organic materials are suspected
or found, cellulose ester filters  and indirect transfer (involving ashing, sonicating, and refiltering the fibers)
is recommended.  However, levels of airborne organic particles should be low in a cleaned work site.
                                              M-3

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M.2.2  PCM

Use the NIOSH P&CAM 239 method (NIOSH 1979). The newer NIOSH 7400 methods can also be used,
although OSHA has yet to replace P&CAM 239 with 7400 for workplace compliance monitoring. NIOSH
reports that 7400  is at least as accurate as P&CAM 239.


M.3  Interpretation of Results


M.3.1   TEM

Use student's "t" test to compare inside and outside levels.

        •  Compute the  natural logarithm of fiber concentration for each sample.

        •  Compute means of the log transformed data  for inside samples and outside samples.

        •  Form  the ratio
                                     T=
Where:


                     Yi = average of log concentrations inside the work site

                     72 = average of log concentrations outside the work site

                     s = [(Kvu-y,)2 + I(y2l-y2)2)/(n1+n2-2)p

                     n, = number of samples collected inside the  work site

                     n2 = number of samples collected outside the work site


Then compare T to the 95 percentile point of a "t" distribution with n,  + n2-2 degrees of freedom. (When
5 samples are collected inside and outside the 95 percentile point is 1.86.) If T exceeds the 95 percentile
point,  reclean. Otherwise, release the contractor.
                                            M-4

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The following two examples illustrate the method:

Example 1

              Measurements inside                          Measurements outside
                the work site (f/cc)                             the work site (f/cc)

                     0.002                                         0.001
                     0.007                                         0.010
                     0.030                                         0.008
                     0.028                                         0.001
                     0.001                                         0.025

                 Y!  = -5.03                                 y2 = -5.39

                 S = 1.49

                 T = 0.38

T is less than  1.86. The contractor is released.

Example 2

              Measurements inside                          Measurements outside
                the work site (f/cc)                             the work site (f/cc)

                     0.052                                         0.001
                     0.130                                         0.010
                     0.005                                         0.008
                     0.240                                         0.001
                     0.375                                         0.025

                 Y!  = -2.54                                 y2 = -5.39

                 S = 1.59

                 T = 2.84

T is greater than 1.86. The site  must be recleaned.

The test is based on the assumption that a homogenous work site has been selected. If one sample has
a much higher concentration than the others it is possible that the site is not homogenous. Common sense
should prevail  in  this case. Irrespective of the result of the "t" test, the high value should be investigated.
The sample should be reanalyzed, additional samples collected, or the site recleaned and tested before
the contractor is released.
Wl.3.2  PCM

The measured level of each sample is compared with the PCM limit of reliable quantification for the volume
of air sampled (approximately 0.01 f/cc for 3000 liters). If any of the samples exceeds 0.01 f/cc, the work
site must be re-cleaned.
                                             M-5

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References

Chatfield EJ. 1983. Measurement of asbestos fibre concentrations in ambient atmospheres. Ont., Can.:
Ontario Research Foundation.

NIOSH. 1979. National Inst. for Occupational Safety and Health. USPHS/NIOSH membrane filter method
for evaluating airborne asbestos fibers. U.S. Dept. of Health,  Education, and Welfare.

USEPA. 1985. U.S. Environmental Protection Agency. Measuring airborne asbestos following an abate-
ment action. Washington,  DC:  Office of Research and Development and Office of Toxic Substances,
USEPA.

Yamate G, Agarwal SC, Gibbons RD. 1984. Methodology for the measurement of airborne asbestos by
electron microscopy. Draft report. Washington, DC: Office of Research and Development, U.S. Environmen-
tal Protection Agency. Contract No. 68-02-3266.
                                            M-6

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                                           Appendix N.  Glossary
        Abatement

        Asbestos



        Cementitious

        Containment


        Delaminate

        (Human) Exposure




        (Material) Exposure

        Fibrous

        Friable

        Homogenous
          (Material)

        Homogenous
          (Work Site)

        Peak levels


        Prevalent levels

        Resolve

        Risk
Asbestos control beyond a special operations and maintenance program.

A group of naturally occurring minerals that separate into fibers. There are six
asbestos minerals used commercially: Chrysotile, Amosite, Crocidolite, Anthophyllite,
Tremolite,  and Actinolite.

Friable materials that are densely packed and  nonfibrous.

Isolation of the work area from the rest of the building to prevent escape of asbestos
fibers.

To separate  into layers.  As used  here, to separate from the substrate.

The presence of people in an area where levels of an airborne contaminant are
elevated. A more technical definition sometimes found in scientific literature is: The
total amount of airborne contaminant inhaled by a person, typically approximated
by the product of concentration and duration.

The amount or fraction of material visible.

Spongy, fluffy, composed of  long strands of fibers.

Capable of being  crumbled,  pulverized, or reduced to  powder by hand pressure.

Similar in  appearance and texture.


Contains only one type of asbestos-containing material and only one type of abate-
ment method was used.

Levels of airborne contaminant which are much higher than average and occur for
short periods of time  in  response to sudden release of the contaminant.

Levels of airborne contaminant occurring under normal conditions.

To distinguish  different objects with a microscope.

The likelihood of developing  a disease as a result of exposure to a contaminant.
' U S Government Printing Office- 1987-517-149/62774
                         N-1

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50272 -101
 REPORT DOCUMENTATION  ! »-. REPORT NO.
        PAGE
EPA 560/5-85-024
 4. Title and Subtitle
      Guidance  for Controlling Asbestos-Containing
      Materials in Buildings:   (1985 Edition)
 7. Author(s)
      DALE  L.  KEYES, BERTRAM P.  PRICE,  JEAN  CHESSON
                                                                       3. Recipient's Accession No.
                                                                       5. Report Date
                                                                             June 1985
                                           6.
                                                                       8. Performing Organization Rept No
 9. Performing Organization Name and Address
      BATTELLE  COLUMBUS  LABORATORIES
      2030  M  Street, N.W.
      Suite 800
      Washington, D.C.  20036
                                           10. Project/Task/Work Unit No.


                                           11. Contract(C) or Grant(G) No.

                                             68-01-6721
                                           (G)
 12. Sponsoring Organization Name and Address
      ENVIRONMENTAL PROTECTION AGENCY
      Office  of Toxic Substances
      Exposure Evaluation  Division
      Washington, D.C. 20460	
                                                                       13. Type of Report & Period Covered
                                           14.
 IS. Supplementary Notes
      This  report was prepared for the  Exposure Evaluation Division  of the Office  of  Toxic
      Substances.  Copies  of the document can be obtained by calling toll-free
      800-424-9065.   (Call  554-1404  in  the District  of  Columbia._)_	
 16. Abstract (Limit- 200 words)

      This  revised document provides  EPA guidance on  controlling asbestos-containing
      materials found in  buildings.   The document   (1)   provides a  current summary of
      data  on  exposure  to  airborne asbestos,  (2)   survey  procedures for determining
      if  asbestos-containing material  is present in  buildings,  (3)   explains how  to
      establish a special  operations  and maintenance  program in a building found to
      contain  asbestos,   (4)  reviews  technical issues  confronted when assessing the
      postential  for  exposure to airborne asbestos,  in  particular indoor settings,
      (5)   suggests a structured process for selecting  a particular course of action
      given information  on physical  condition of the  asbestos,  exposure levels,
      assessment methods,  and abatement techniques,   (6)  summarizes and updates in-
      formation on applicability, effectiveness, and  relative costs of alternative
      remedial actions,   (7)  introduces and discusses  criteria for determining
      successful  asbestos  control.   The material presented is a summary of information
      and  experience  gained by EPA through its Asbestos in Schools  and Buildings
      Program and by  a  wide spectrum of experts in  the  field.
 17. Document Analysis a. Descriptors
   b. Identifiers/Open-Ended Terms
         Airborne  Asbestos
         Asbestos  Abatement
         Asbestos-Containing Materials
         Asbestos  Control Program
         Asbestos  Exposure
         Asbestos  Special Operations and Maintenance Program
   c. COSATI Field/Group
 18. Availability Statement

       Available to  the Public
                             19. Security Class (This Report)
                              Unclassified
                                                        20. Security Class (This Page)
                                                          Unclassified
21. No. of Pages
    160
                                                      22. Price
(See ANSI-Z39.18)
                                        See Instructions on Reverse
                                                     OPTIONAL FORM 272 (4-77)
                                                     (Formerly NTIS-35)
                                                     Department of Commerce

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