United States
          Environmental Protection
          Agency
            Air And Radiation
            (EN-341W)
EPA 340/1 -90-007
Revised November 1990
EPA
Guidelines For
Asbestos NESHAP
Demolition And Renovation
Inspection Procedures

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                               EPA-340/1-90-007
       Guidelines for
     Asbestos NESHAP
Demolition and Renovation
   Inspection Procedures
     U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Air Quality Planning and Standards
       Stationary Source Compliance Division
          Washington, DC 20460
            November 1990

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                                   DISCLAIMER

The  opinions,  findings, and  conclusions  expressed are those  of the authors and not*
necessarily those of  the  Environmental Protection  Agency  or the cooperating agencies.
Mention  of company  or product names is  not to be considered as an endorsement by the
Environmental Protection Agency.  The guidance provided in this manual does not create any
rights for defendants  nor responsibilities for the Environmental  Protection  Agency.   The
Agency reserves  the  right to  act  at variance with  these procedures at, any time without
notice  to the regulated community.  Nothing contained  in this manual can be used as a
defense in an enforcement action.  The  safety precautions set forth in this manual are general
in nature.  The precise  safety precautions required for any given situation depend upon and
must be tailored to the specific circumstance or situation.  Alliance Technologies Corporation
expressly disclaims any liability for any personal health problems, death, or economic loss
arising from any actions taken in reliance upon this manual.
                               ACKNOWLEDGMENTS

This  document  was  prepared  for  the  U.S.  Environmental Protection  Agency (EPA) by
Alliance Technologies, Inc.  under  Contract  No. 68-02-4465.   Alliance appreciates  the
support and  input given  by  the EPA Project Manager,  Ms.  Omayra Salgado  during  the
preparation of this document.  Review and comments were provided by legal and technical
staff of all Regional  Offices along with Headquarters OAQPS (SSCD and ESD) OECM and
EHSD. Their input is gratefully acknowledged.
                                          11

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                                          Table of Contents
 Section
 TV  i  '
 Disclaimer. ..................... .. ..... . ...... ........ ........ . ........................         •  -  .   .
 Acknowledgments .......... . .................... . .......... , .......... ..... •  ,
 Figures  . ........ . .......................      .......................... ' ..... ' ......................... "' .................. ........................ .......... ,.,.,11
 Tables  ...............................   ...... ' ........................................... • ........................ ' ............................ "••- ...... '•'••'•<" v?
                        •    ....... •••"••" ........ ••-' ......... • .................... • ....... • ....... • .................... ..,.».......,...,., ..... .... ....... vi

 1       INTRODUCTION.. .......... ........ ..... ....... ______ ................ ............................ ;...,.....,.,.. 4i    t            It
         PURPOSE OF INSPECTIONS ......... . ...... ..... .       •'""" " .......... ' ............ """""    """"•"""' ....... •• '
         GLOSSARY OF TERMS ............... ..... ........      ' ....... ' ................ '"" ................... ' ..... ' .............. " ...... "' v"f
                                                ................................... '•••'• ........ '•" ...... ...... ...........i... ...... ., 1-2,

 2       IDENTIFYING ASBESTOS CONTAINING MATERIALS.. ...............                     21
         IMPORTANT DEFINITIONS ................ ......... ...... ,....".       k             ««......,...., ...................... -
         ASBESTOS USES AND CHARACTERISTICS .......... 7777.7777777777777 7777   '    2-2
                 Typical Friable Asbestos Materials ........ ...... . ....... ..... ..... 7777777777777777  7   2-5
                 Typical Category I Nonfriable Asbestos Materials ............... .... ..... . ........ .... ...... ,...7.7 7  77 2-6
                 Typical Category II Nonfriable Asbestos Materials ......           ........................ '""" o ^
        ASBESTOS SURFACING MATERIALS ..... .......... ......... .",. ..... ;...„.„.... ....... 7777777777777 ..... "2-6
                 Condensation Control .......................... . ...... .... ............. ,.,....„., ........ '.,""! . 1  ...... ""'"*""" .........
                 Fireproofing ...... . .................... t [[[ .'.!!!."..1'1..I.'!!!!!1'! " , ." ..... 2-7
                 ^Vcon^sf ipfll  '                    "                     *                    ~'
        "DERMAL SYSTEM" INSULAJlioNZ"!!
                 Pipe Insulation ......... •.; .......... . ..... „..„.. ........ .................. ...... ..    """"."" '""'"'""" ...............   -V?
                 Boilers and Hot Water Tanks ............. ..-;« ..... ..,.,.. ..... ,..,....,„,„...„.   I...."]"!l"!!! ..... '"""" ......... „ «
                 Elbows, Valves and T-Fittings .................... . ...*...,   ...!.!!."!.."  7    .........  3-4
                 Other Medical/Physical Considerations in Respirator Usage ...... . .................. ..'l.".!]l.!"!.!.,.!.!! 3-9
                 Field Inspection and Checkout Procedures. .......... . ..... . ....... ........ ..... .,..,.. ..... ^...,.....".7!!"!. '.   3-10
                 Respirator Maintenance ................................... k ............    .  t      ..... "•«• '.""..u ...... » ..... ^
       OPERATIONAL PRACTICES FOR ENTERING AND > EXTIWG ^TES 777777777777777 3-12
                Entering and Exiting Site with a Three-Stage Decontamination System ...... .7.77777777 3-12
                Entering and Exiting Sites Without a Three-Stage Decontamination System .. . ................. 3-1 s
       DISPOSAL OF CONTAMINATED CLOTHING ....................                 ........ ' ........... 3 16
       OTHER SAFETY CONSIDERATIONS IN ASBESTOS WORK.777777777777777777! 7 3-17

4      PRE-INSPECTION PROCEDURES [[[            t     4il
                Review Notification [[[ ti ............  ^    t ^   "'""4-1
                Identifying Non-Notifiers .................................... . ................... "7.777..7.77... 77,7 . ........ 4-1
                Preparation of Inspection Equipment..... ...... . ....................... ..... ........ . ......... . ..... t.7777!7  7  4-2

5      ONSITE FACILITY INSPECTIONS ................. . .............................. ...... ..................... .;.            5^
       PRE-ENTRY REMOTE OBSERVATIONS ...   .      ............................................. ' ..................... /,
                   INTERVIEW [[[ 77.777777777777777"77 ......... 5-2
                Interview Questions .......................... . ............ ..... ....... . .......................   t ^  t   '••••—> ..........

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                                  Table of Contents
Section
                                                                                   Page
       PRE-REMOVAL INSPECTION	5-5
               Applicability	•	5-5
               Notification	,	•	5-5
               Planned Emission Controls	<—	5-6
               Disposal Techniques.	5-6
               Evidence Collection....	•	•	5-6
       ACTIVE REMOVAL INSPECTIONS	,	•	-	•	5-?
               Removal Area Entry Preparation	«	5-7
               Applicability	'5"°
               Notification......................	,.	•	•	•	——	5-8
               Emission Controls	.	•	•	•	5-9
               Evidence Collection	...5-13
               Disposal Techniques	•	•	5-13
               Waste Shipment Records...	•	5-14
               TSCA Compliance...	.	•	•	-	•—•	5-14
               Exiting the Removal Area,...	.	•	•	•	5-14
       POST-REMOVAL INSPECTION......	;	r	•	5-15
                Applicability	.'.	•	•	•	'	5-15
                Notification	-	•	5-16
                Emission Controls	•	•	•	•	5-16
                Waste Disposal	—	5-16
                Evidence Collection	•	'•—•	5-17
       POST-INSPECTION INTERVIEW	5-17
       EXIT OBSERVATIONS	5"18

 6     POST-INSPECTION	•	•	6^
       INSPECTION FOLLOWUP	•	i6"1
       DOCUMENTATION	6-1
                Document Control	•	^"2
                Corrections to Documentation	•	6-2
       RECORDS MAINTENANCE	6'3
       INSPECTION REPORTS	6"3

 7     LANDFILL INSPECTIONS	•	7"1
       REVIEW PERMIT CONDITIONS	•	7"1
       EVALUATE WASTE SHIPMENT RECORDS	-7-2
       OTHER ACTIVE WASTE DISPOSAL SITE REQUIREMENTS	7-2
       SURVEILLANCE	7"3
                Off-loading of suspect ACWM unaccompanied by a waste manifest	 7-3
                Landfill inspection	•	7'3

 8     ASBESTOS BULK SAMPLING AND ANALYSIS	8-1
       PROTECTIVE EQUIPMENT	8'1
       SAMPLING EQUIPMENT	8"2
       COLLECTION TECHNIQUES	8'2
                Non-Abatement Inspections	8~3
                Abatement Inspections	8"3
                                             IV

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                                       Table of Contents
Section
Page
        BULK SAMPLE ANALYSIS	-.	8-4
        QUALITY ASSURANCE	.	8-5
                 Sample I.D. Numbers	..	.....	.	 8-5
                 Chain-of-Custody Forms	......	,	8-5
                 Quality Control (QQ Samples	8-5
                 Accredited Laboratories	.	..	...;...........„. 8^5
Appendices
      A     National Emission Standards for Hazardous Air Pollutants (NESHAP)
            (SubpartM- Asbestos)	
 .A-l
     . B     Respiratory Protection Selection Checklist	B-i

      C     Field Inspection Checklists	C-l
            C-l Asbestos NESHAP Demolition and Renovation Inspection Equipment Checklist	C-3
            C-2 Facility Inspection Checklist	......4...................	C-5
            C-3 Landfill Inspection Checklist	C-23
            C-4 AHERA Inspection Checklist	C-35
            C-5 Worker Protection Rule Checklist....	C-39

References  :	,	R-l

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                                        Figures
Number
8-1    Representative chain-of:custody record.
 Page





	8-6
                                         Tables
Number
 Page
1-2    Trade Names.	.2-2



2-2    Summary of Asbestos-Containing Products	.2-3
                                            VI

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                                    SECTION 1
                                INTRODUCTION
The EPA has identified a need for nationally consistent inspection guidelines to assist EPA,
State and local air agency personnel in conducting asbestos NESHAP inspections specific to
demolition and renovation (D/R) of buildings containing ACM. The primary purpose of this
manual is to present clear, concise inspection procedures which individuals who are involved
in enforcement of the asbestos NESHAP (40 CFR Part 61, Subpart M) may follow.

EPA first published guidance entitled EPA Demolition and Renovation Inspection
Procedures  in 1975 following the original promulgation of the asbestos NESHAP in 1973.
Subsequently, EPA issued numerous policy memoranda providing additional guidance and
clarification on the asbestos NESHAP to agency staff charged with enforcing the regulation.

Additionally, EPA developed two workshops for asbestos inspectors, 1988 NESHAP
Asbestos Demolition and Renovation Inspection Workshop and Asbestos NESHAP Inspector
Safety Workshop, In 1989 these two workshops were consolidated to form the Demolition
and Renovation Inspection and Safety Procedures Workshop, and a field manual, Guidelines
for Asbestos NESHAP Demolition and Renovation Inspection Procedures, was produced.

This document is a revision of the 1989 field manual. It incorporates all pertinent information
cited in the repromulgated asbestos NESHAP regulation (September 1990) and also
includes revised health and safety recommendations detailed in the EHSD Health and Safety
Guidelines for EPA Asbestos Inspectors.

Since EPA, State and local agencies are beginning to implement coordinated asbestos
programs under the CAA and TSCA, asbestos NESHAP inspectors may be asked to
evaluate compliance with certain provisions of the AHERA and WPR regulations. To
support the integration programs, this manual includes basic guidelines for asbestos
NESHAP inspectors to follow to determine compliance with these regulations as well as
NESHAP.

Although the guidance in this manual is geared toward EPA asbestos NESHAP inspectors,
it is also appropriate guidance for State and local regulatory inspectors (either in lieu of, or as
a supplement to specific State and local program requirements).
                                                                                 l-l

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PURPOSE OF INSPECTIONS

Inspectors are assigned at the EPA, State and local agency level to visit facilities involved in
demolition and renovation activities. Where violations of the asbestos NESHAP are
detected, observations made and evidence collected by the inspector form the foundation of
subsequent compliance action.

The major objectives of a regulatory inspector are to:

       •      determine the need for immediate action in order to protect the public and the
             asbestos abatement worker (This may necessitate obtaining a temporary
             restraining order under Section 113 of the CAA or use of Section 303 of the
             CAA "imminent and substantial endangerment to public health" to seek a
             court order to stop work.);
       •      verify that the demolition and renovation operations are carried out according
             to all requirements of the asbestos NESHAP regulation;
       •      gather evidence of any violations of the asbestos NESHAP;
       •      determine whether a potential AHERA or WPR violation exists; and
       •  ..    create a regulatory presence as a deterrent to potential violators.

The overall asbestos NESHAP inspection and compliance program follows a national
strategy document entitled Asbestos Demolition and Renovation Enforcement Strategy
(March 1988).  The guidance contained in this manual is consistent with the national
strategy document regarding inspector training, inspection criteria, and enforcement
procedures. This guidance is also consistent with EPA policy to coordinate all asbestos
program offices.

GLOSSARY OF TERMS
ACM

ACWM

AHERA
Air Lock
Asbestos-Containing Material.

Asbestos-Containing Waste Material

Asbestos Hazard Emergency Response Act. Requires
schools to inspect for asbestos, implement response
actions, submit asbestos management plans to states
and re-inspect every three years. Specifies use of
accredited inspectors, air sampling methods, and
waste disposal procedures.  40 CFR 763, Subpart E.

A system of enclosures consisting of two polyethylene
curtained doorways at least 3 feet apart that should
permit air movement from clean to contaminated
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Amended Water
Asbestos NESHAP
Atmosphere Supplying
Respirators
CAA
Category I Nonfriable ACM
Category n Nonfriable ACM
Clean Room/Area
areas.  Air locks are usually part of a decontamination
chamber attached to an abatement area which is under
negative pressure.              J                    ;

Water to which a chemical wetting agent (surfactant)
has been added to improve penetration into asbestos-
containing materials that are being removed.

The specific portion of Section 112 of the CAA that
addresses asbestos. Specific regulations are
contained in 40 CFR Part 61, Subpart M.

Respiratory protection devices which exclude
workplace air altogether and provide clean air from
some independent source. (i.e., SCB A and Type C
SAR).

Clean Air Act. The legislation that provides EPA with
authority for the regulation of sources of air pollution.

Asbestos-containing packings, gaskets, resilient floor
covering, and asphalt roofing products, containing more
than 1 percent asbestos as determined using polarized
light microscopy according to the method specified in
Appendix A, Subpart F, 40 CFR Part 763.

Any material, excluding Category I nonfriable ACM,
containing more than 1 percent asbestos as determined
using polarized light microscopy according to the
method specified in Appendix A, Subpart F, 40 CFR
Part 763 that,  when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.

The first stage or room of the decontamination
enclosure system in which workers prepare to enter
the work area.
Decontamination .
Enclosure System
EHSD
A series of connected rooms with polyethylene
curtained doorways for the purpose of preventing
contamination of areas adjacent to the work area.
Usually comprised of a clean room, shower and
equipment (dirty) room.

Environmental Health and Safety Division (formerly
OHSS or Occupational Health and Safety Staff). The
group within EPA that is responsible for developing
health and safety guidance specific to EPA employees.
                                                                                   1-3

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 EPA
 Equipment/Dirty Room
 Friable Asbestos
 Material (FAM)
 Full Facepiece
 Respirator
 Glovebag
 Heat Cramps
Heat Exhaustion
 Environmental Protection Agency. The organization
 within the Federal government which is ultimately
 responsible for enforcing the asbestos NESHAP in
 order to protect people who work or live near potential
 asbestos release areas such as buildings undergoing
 demolition or renovation.

 The last stage or room of the worker decontamination
 system before entering the work area.

 According to the Asbestos NESHAP,  any material
 containing more than 1 percent asbestos as determined
 by the method specified in Section 1, Polarized Light
 Microscopy (PLM) of Appendix A, Subpart F, 40 CFR
 Part 763 that, when dry, can be crumbled, pulverized,
' or reduced to powder by hand pressure. If the
 asbestos content is less than 10 percent as determined-
 by a method other than point counting by PLM, verify
 the asbestos content by point counting using PLM.

 A respirator which covers the wearer's entire face
 from across the forehead, around the temples, along
 the cheek bones to below the chin.

 A sealed compartment with attached inner gloves for
 the handling of asbestos-containing materials.
 Properly installed and used, glovebags provide  a small
 work area enclosure used typically for small-scale
 asbestos stripping operations.  Information on
 glovebag installation, equipment and supplies, and
 Work practices is contained in the OSHA final rule on
 occupational exposure to asbestos (Appendix G to 29
 CFR 1926.58).

 A form of heat stress resulting in painful spasms of
 heavily-used skeletal muscles such as hands, arms,
 legs, and abdomen, sometimes accompanied by dilated
pupils and weak pulse resulting from depletion of the
 salt content of the body.

A form of heat stress resulting from dehydration and/or
salt depletion, or lack of blood circulation usually
accompanied by fatigue, nausea, headache, giddiness,
clammy skin, and a pale appearance.
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Heat Stroke
HEPA
NIOSH
Nonfriable Asbestos-
containing Material
OPTS
OSHA
Owner/Operator
PAPR

Personal Protective
Equipment (PPE)
PF
The most severe form of heat stress disorders
resulting from the loss of the body's ability to sweat;
characterized by hot dry skin, dizziness, nausea,
severe headache, confusion, delirium, loss of
consciousness, convulsion, and possibly coma.

High Efficiency Paniculate Air filter rated capable of
trapping and retaining 99.97% of all particles larger . .
than 0.3 microns.

National Institute for Occupational Safety and Health.
The organization within the Federal government which,
is responsible for research and development of worker
safety equipment and work practices.

Any material containing more than 1 percent asbestos
as determined using the method specified in Appendix
A, Subpart F, 40 CFR Part 763, Section 1, Polarized
Light Microscopy, that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.

Office of Pesticides and Toxic Substances.  The group
within EPA which is responsible for implementing and
carrying out programs to enforce the TSCA regulations.

Occupational Safety and Health Administration. The
Federal organization which is responsible for enforcing
regulations that protect the health of workers, including
those removing asbestos from buildings.

Any person who owns, leases, operates, controls, or
supervises any building, structure, facility, or
installation which emits or may emit any air pollutant.

Powered Air Purifying Respirator.

Any material or device worn to protect a worker
from exposure to, or contact with, any harmful material
or force. May include a respirator, coveralls, hard hat,
steel toed shoes, safety glasses, etc.

Protection factor as provided by a respirator;
determined by dividing the airborne fiber concentration
outside of the mask by the concentration inside the
mask.
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Phase Contrast
Microscopy (PCM)
Polarized Light
Microscopy (PLM)
Pressure Demand
Airline Devices
Regulated asbestos-
containing material (RACM)
Scanning Electron
Microscopy (SEM)
SCBA
SSCD
Transmission Electron
Microscopy (TEM)
An optical microscopic technique used for counting
fibers in air samples, but which does not distinguish
asbestos fibers.

An optical microscopic technique used to distinguish
between different types of fibers based on their shapes
and unique optical properties; commonly used to
determine the presence of asbestos in bulk samples of
suspected asbestos- containing materials.

A respiratory protection device which has a
regulator and valve designed to maintain positive
pressure in the facepiece at all times.

Means (a) friable asbestos material, (b) Category I
nonfriable ACM that has become friable, or (c)
Category II nonfriable ACM that has a high probability
of becoming or has become crumbled, pulverized, or
reduced to powder by the forces expected to act on,the
material in the course of demolition or renovation
operations regulated by the asbestos NESHAP.

A method of microscopic analysis which utilizes an
electron beam directed at the sample and then collects
the beams that are reflected to produce an image from
which fibers can be identified and counted.

Self Contained Breathing Apparatus. A respirator with
air provided by a tank worn by the user; provides the
highest level of protection.  Can be used when a
contaminant's concentration is unknown.

Stationary Source Compliance Division.  The group
within EPA that is responsible for implementing and
carrying out a program to assure that the regulated
community complies with the asbestos NESHAP.

A method of microscopic analysis which utilizes an
electron beam that is focused onto a thin sample. As
the beam penetrates (transmits) through the sample,
the difference in densities produces an image on a
fluorescent screen from which samples can be
identified and counted.
1-6

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TSCA


Visible Emissions
Wetting Agents
WPR
260/160/35
Toxic Substances Control Act. Asbestos is regulated   ':
as a toxic substance under this legislation.

Any emissions (excluding condensed uncombined
water vapor) visually detectable without the aid of
instruments, coming from asbestos-containing material  '
or asbestos-containing waste material or from any
asbestos milling, manufacturing or fabricating operation.

Materials (such as surfactants) that are added to
water which is used for wetting the asbestos-
containing material in order for the water to penetrate
more effectively.
Worker Protection Rule. TSCA regulation which
protects public employees performing asbestos
abatement work in states not covered by asbestos
standards. 40 CFR 763, Subpart G.

260 linear feet (80 linear meters) of ACM on pipes,
160 square feet (15 square meters) of ACM on other
facility components, or 35 cubic feet of ACM off facility
components where the amount of ACM previously on
pipes and other facility components is unknown.  These
figures form the basis of applicability in the asbestos
NESHAP standard.
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1-8

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                                    SECTION 2

          IDENTIFYING ASBESTOS CONTAINING MATERIALS
In order to properly conduct NESHAP asbestos inspections, inspectors must be
knowledgeable of the various commercial uses and applications of asbestos products and
which of these are regulated under the asbestos NESHAP. Recognizing the various
appearances, compositions, uses, and application techniques can assist the inspector in
deciding if a violation has or has not occurred. The remainder of this section provides
information that should assist inspectors in recognizing ACM, both in the intact and
disturbed state.

IMPORTANT DEFINITIONS

Asbestos-containing Material (ACM)—friable asbestos material, Category I nonfriable
ACM that is in poor condition, or Category II nonfriable ACM that has a high probability of
becoming crumbled, pulverized, or reduced to powder by the forces expected to act on the
material in the course of demolition or renovation operations regulated by this subpart.

Asbestos-containing Waste Materials (ACWM)—any waste that contains commercial
asbestos and is generated by a source subject to the provisions of this subpart. This term
includes filters that control devices, friable asbestos waste material,  and bags or other
similar packaging contaminated with commercial asbestos. As applied to demolition and
renovation operations, this term also includes friable asbestos waste and Category n
nonfriable ACM waste that becomes crumbled, pulverized, or reduced to powder by forces
that acted on the material during the course of demolition and renovation operations
regulated by this subpart, and materials contaminated with ACM including disposable
equipment and clothing.

Category I Nonfriable ACM—asbestos-containing packings, gaskets, resilient floor
covering, and asphalt roofing products, containing more than 1 percent asbestos as
determined using polarized light microscopy according to the method specified in
Appendix A, Subpart F, 40 CFR Part 763.

Category II Nonfriable ACM—any material, excluding Category I nonfriable ACM,
containing more than 1 percent asbestos as determined using polarized light microscopy
according to the method specified in Appendix A, Subpart F, 40 CFR part 763 that, when dry,
cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Friable Asbestos Materials—any material containing more than 1 percent asbestos as
determined by the method specified in Section I, Polarized Light Microscopy (PLM) of
                                                                                  2-1

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 Appendix A, Subpart F, 40 CFR Part 763 that, when dry, can be crumbled, pulverized, or
 reduced to powder by hand pressure. If the asbestos is less than 10 percent as determined
 by a method other than point counting by PLM, verify the asbestos content by point counting
 using PLM.

 In Poor Condition—Means that the binding of the material is losing its integrity as indicated
 by peeling, cracking, or crumbling of the material.

 ASBESTOS USES AND CHARACTERISTICS

 Table 2-1 lists the types of application and associated trade names of asbestos products.
 Asbestos cement products (flat sheets or sidings, tiles, corrugated roofing sheets, rainwater
 pipers, gutters, and pressure piping) constitute approximately 66 percent of the total. These
 products generally contain 10 to 15 percent asbestos, which functions as a fibrous
 reinforcement in the cement.  A list of specific uses of asbestos and associated binders in
 building materials along with the average percent asbestos appears in Table 2-2.
                              TABLE 2-1.  TRADE NAMES
 Type of application
                          Trade names
 Sprayed-on
 Pipe and
 Boiler Wrap
Asbestos - Spray
Monokote - MK III
Cafco - Soundshield
Audi - Cote
Cafco - Type I

Johns-Manville (JM) and
 Hewells 85%
JM Suprex Blocks
JM Marinite
JM Asbestos Sponge
JM Thermobestos Blocks
JM Newtherm
Atlas 650, 660, 250, 280,
 18 Cold Water Paste
Atlas Aircell and Finecell
"Newalls" Newtembelt
Limpet
Sabinite
Spraydpn
Cafco - Type D
Spraycraft
Kilnoise Plaster
Cafco -Blaze Shield
Cafco - Heat Shield
Magnesia Blocks, Pipe Coverings, and
 Cement
JM and Atlas Sponge Felt Pipe Covering
JM Thermo-Wrap and Thermo Tape
JM 302 and 352 Insulating Cements
JM Asbestocell
JM Fibrofill
Atlasite, Caposite

JM and Atlas Rope Lagging
2-2

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TABLE 2-2. SUMMARY OF ASBESTOS-CONTAINING PRODUCTS
Subdivision
Surfacing material


Preformed thermal
insulating products


Textiles











Cementitious
concrete-like products











Paper products




Roofing felts



Generic name
sprayed- or
troweied-on

batts. blocks, and
pipe covering
85% magnesia
calcium silicate
cloth
blankets (fire)
felts:
blue stripe
red stripe
green stripe
sheets
cord/rope/yarn
tubing
tape/strip
curtains
(theatre, welding)
extrusion panels:
corrugated
flat
flexible
flexibly 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

2O-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
1 920-present
1920-present
1 920-present
1 920-present
1 920-present
1 920-present
1 920-present
1 920-present

1 945-present
1965-1977
1 930-present
1 930-present
1 930-present
1 930-present
1 93O-present

1 93O-present

1944-1945
unknown-present
unknown-present
1 935-present

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


magnesium carbonate
calcium silicate

none
cotton/wool
cottpn
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
Portland cement
Portland cement

sodium silicate
starch
cotton and organic binder
starch, lime, clay
asphalt
asphalt
asphalt
asphalt
                                                        2-3

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                             TABLE 2-2 (Continued)
Subdivision
Asbestos-containing
compounds












Asbestos ebony products
Flooring tile and
Sheet Goods

Wallcovering
Paints and coatings

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
vinyl wallpaper
roof coating
air tight
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
6-8 .
4-7
15
Dates of use
1 930-present
1 945-present
1945-1975
unknown-present
1 920-present
1959-present
unknown-present
unknown-present
1930-1975

1 935-present , ,
1900-1973
1920-1973
1926-1950
1 930-present
1 950-present
1 920-present
1 950-present
unknown-present
1 900-present
1 940-present
Binder/sizing
linseed oil
asphalt
asphalt
asphalt
asphalt
asphalt
asphalt
Portland cement
starch, casein, synthetic
1 resins
caster oil or polytsobutylene
clay
clay
magnesium carbonate
Portland cement
po!y(vinyl)chlonde ..
asphalt
dry oils
— . .
asphalt
asphalt
2-4

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Some forms of asbestos fibers have high tensile strength and thermal stability.  In addition,
asbestos is non-combustible and a good acoustical and thermal insulator. Asbestos is
effective in condensate control and resistant to corrosion and friction.

Chrysotile use comprises approximately 93 percent of the total consumption of asbestos
fibers. The remaining 7 percent comes from the amosite and crocidolite groups. Each may be
used individually in asbestos products, but mixtures of chrysotile, crocidolite and amosite are
commonly found,

Chrysotile is used in asphalt flooring, vinyl floor tiles, pavings, and road surfaces. It is also
found in brake linings, clutch facings, gaskets, and reinforced plastics.  .

Amosite is less flexible but more heat and acid resistant than chrysotile. It has often been
used in high temperature applications and may also be found in small amounts as filter aids
in pressure piping products.

Crocidolite is very resistant to acids and to the effects of outdoor exposure and may be found
in combination with chrysotile in asbestos cement pressure pipes, textiles, and filtration
products.                                                                          ,

Anthophyllite, actinolite, and tremolite are used primarily in adhesives and cements. They
are too brittle for textile products or for use as fibrous reinforcement.

The following principle categories of asbestos use in buildings may be subject to the
asbestos NESHAP if the building is renovated or demolished.

Typical Friable Asbestos Materials

       •       Spray applied materials (fibrous, fluffy)
                   fireproofing
                   decorative coatings
                   condensation control

       •       Hand troweled insulation (granular, cementitious)
                   acoustical insulation
                   thermal insulation (such as pipe lagging)

       »       Molded Insulation
                   thermal insulation (such as pipe wraps)
                                                                                      2-5

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 Typical Category I Nonfriable Asbestos Materials

        •      gaskets
        •      resilient floor covering
        •      asphalt roofing products
        •      packings

 Typical Category II Nonfriable Asbestos Materials

        •      asbestos/cement sheet and piping
        •      coatings
        •      sealants
 ASBESTOS SURFACING MATERIALS

 Asbestos-containing surfacing materials are coatings which were spray-applied or troweled
 onto steel I-beams, decks, concrete ceilings and walls, and other surfaces. They were
 applied primarily as thermal insulation, fireproofing, soundproofing, and for decorative
 purposes.

 Sprayed coatings are typically rough and fluffy in appearance, while troweled coalings have a
 smooth finish and may be covered with a layer of plaster or other non-asbestos material.
 Both sprayed and troweled asbestos coatings are friable in most applications. Most spray-
 applied asbestos coatings were banned for fireproofing/insulating in 1973 and for decorative
 purposes in 1978.

 In its 1986 standard OSHA banned all applications of asbestos-containing products through
 spray techniques. However, the U.S. Court of Appeals for the District of Columbia reviewed
 this ban and concluded that "the support for the ban plainly fails to meet the 'substantial
 evidence' standard... (and stated that the) "ban cannot stand."

 Effective January 19,1990, OSHA amended the regulatory text of the final asbestos standard
 by deleting the prohibition regarding the spray application of asbestos-containing products.
 It is believed that deleting this prohibition will not significantly increase the risk to
 employees.

 Condensation Control

 Asbestos insulation was often applied to steel, concrete, or other building surfaces to
 minimize condensation.  The low thermal conductivity of the applied asbestos prevented the
 cooling of such surfaces, thereby eliminating ceiling and wall "sweating" and reducing metal
 corrosion and rotting of wood components.
2-6

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Fireproofing

Since high temperatures can result in a deterioration of ductility, tensile and compressive
strengths in building materials, asbestos has been widely used by the construction industry
to fireproof structural steel.

Acoustical

Since asbestos is fibrous in nature and thus lacks a reverberant surface, it has proved to be
an excellent soundproofing material. It was used extensively in schools (hallways,
stairwells, band rooms, gymnasiums), restaurants, hotels, and auditoriums for this purpose
prior to the 1970's.

THERMAL SYSTEM INSULATION

Thermal system insulation includes materials applied to pipes, fittings, boilers, breechings,
tanks, ducts, and other interior structural components to prevent heat transfer or water
condensation.  These materials are present in a wide variety of forms. The following
examples of thermal insulation are based on product categories.

Pipe Insulation

Preformed pipe insulation with an asbestos content of about 50 percent has been used for
thermal insulation of steam pipes in industrial, commercial, institutional, and residential
applications. This product is usually white and chalky in appearance and typically was
applied as 3-foot long, half-round sections, held onto the pipe by a covering of plaster-
saturated canvas and metal bands. This insulation was applied on straight pipe sections,
while wet-applied coatings were used on elbows, flanges, and other irregular surfaces. The
installation of wet-applied and preformed asbestos insulations was banned in  1975.

Another type of pipe insulation is manufactured from asbestos-containing paper. Asbestos-
containing paper products are manufactured on conventional papermaking equipment using
asbestos fibers rather than cellulose. The raw asbestos paper produced in this process
contains up  to 85 percent asbestos. The final product is typically coated or laminated with
other materials.

The typical  asbestos-paper pipe covering, often referred to as air-cell insulation, looks and
feels like corrugated cardboard and is generally rolled onto the pipe in several layers.  It is
medium gray in color and commcnly held in place with a canvas wrap and metal bands.

Boilers and Hot Water Tanks

Asbestos-containing preformed block insulation has been used as thermal insulation on
boilers, hot water tanks, and heat exchangers in industrial, commercial, institutional, and
residential applications. The blocks are commonly chalky white, 2 inches thick and from 1 to
3 feet square. They are often held in place around the boiler by metal wires or expanded
                                                                                      2-7

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 metal lath.  A plaster-saturated canvas was often applied as a final covering or wrap. The
 installation of this type of asbestos insulation was banned by EPA in 1975.  Asbestos-
 containing fire brick and gaskets may also be found as heating system components.

 Elbows, Valves and T-Fittings

 Batch mixed ACM has been trowel-applied to irregular joints (elbows, valves, T-fittings,
 etc.) on thermal systems. The insulation is often covered with a canvas wrap or other
 covering similar to the adjacent pipe wrap which may make it difficult to distinguish from the
 material in the straight runs. It is not uncommon to find asbestos-containing "elbow mud" or
 "lagging" adjacent to straight-runs of non-asbestos pipe insulation. ACM may also be found
 in valve packings

 MISCELLANEOUS BUILDING MATERIALS

 Both friable and non-friable forms of other asbestos-containing building materials exist.
 Friable materials include ceiling viles (such as the 2 ft x 3 ft drop-in types and the. 1 ft x 1 ft
 glue-in panels), asbestos-containing paper (commonly found underneath wooden floor
 boards) and joint compound.  It is estimated that 5 to 10 percent of currently installed ceiling
 tiles contain asbestos.

 Typical non-friable miscellaneous asbestos materials include resilient floor covering,
 asbestos cement sheet (Transite), siding shingles, and asphalt roofing products. Generally,
 the asbestos in these products is tightly bound and nonfriable. However, with age, or during
 the course of demolition or renovation, such materials may become friable.  Because of this,
 inspectors must evaluate such materials for their potential to become friable on a case-by-
 case basis.                                            ,
2-8

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                                    SECTIONS
                ASBESTOS INSPECTOR SAFETY GUIDANCE
Safety requirements and/or guidelines for government employees involved in asbestos'
inspection activities are addressed in one form or another in regulations and policies
developed by four separate Federal government agencies/groups. Each approaches the
subject differently, not always citing asbestos inspectors specifically, but contributing to the
overall purpose.

The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental
Protection Agency (EPA) have each promulgated regulations pertaining specifically to
workers involved in the asbestos industry. The OSHA standards (29 CFR 1910 and 1926)
apply to workers involved in the removal, demolition, installation, repair, maintenance,
transportation and disposal of asbestos-containing materials.

The National Institute for Occupational Safety arid Health (NIOSH) and EPA, as part of a
joint venture, were responsible for publishing respiratory protection safety guidance for
persons who work in the asbestos abatement industry. This 1986 document, A Guide to
Respiratory Protection for the Asbestos Abatement Industry, provides information on the
hazards associated with airborne asbestos, a model respiratory protection program and
recommendations concerning appropriate respirators for reducing asbestos exposure.

The EPA Worker Protection Rule (40 CFR 763) extends provisions of the OSHA asbestos
standard to state and local asbestos workers not covered by the Federal OSHA standard.

Most applicable to EPA inspectors assessing compliance with the asbestos NESHAP
regulation are the guidelines provided in the Health and Safety Guidelines for EPA Asbestos
Inspectors prepared by EPA's Environmental Health and Safety Division (EHSD),formerly
the Occupational Health and Safety Staff (OHSS). These guidelines are specific to EPA
asbestos inspectors and incorporate many of the procedures and practices recommended or
required by the previously mentioned regulations and policies.

PROTECTIVE CLOTHING

Protective clothing is necessary, and in most cases required, during asbestos inspections.
Protective clothing for the inspector of asbestos abatement projects usually consists of
disposable coveralls, foot and head coverings, and gloves. These items are available in
many styles and are made of several types of materials. The advantages of a particular style
depend on the type of inspection conducted.
                                                                                   3-1

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 Inspectors should be prepared to wear the following protective clothing when entering a
 removal, demolition, or renovation area:

        *      a disposable, full-body, hooded outer coverall (e.g., Tyvek® or equivalent).  A
               coverall with an expanded back should be worn with an SCBA.  In certain
               cases, an inspector may be required to  use specialty coveralls such as
               Saranex-coated Tyvek® (chemical resistance) or Nomex (fire retardant)-
        •      a bathing suit (or equivalent) or an inner disposable coverall. When possible,
               particularly when a changing or decontamination area is available, all street
               clothing should be removed before donning protective clothing.  When clothing
               is removed, the inspector may choose to wear a bathing suit under the
               protective clothing. If it is not possible to remove street clothing, the inspector
               should roll-up pant legs and sleeves and don an inner disposable coverall.
        •      disposable gloves (PVC or equivalent) taped to coverall.

        •      disposable inner booties (e.g., Tyvek® or equivalent may be part of coverall).
        •      disposable outer booties (water-resistant material) taped to outer coverall.
        •      hard hats, safety glasses, safety shoes, hearing protection, when required by
               the situation or by the owner/operator.                                 ,


 The use of protective clothing during pre-removal, post-removal and outside inspection
 situations will be a discretionary decision on the part of the inspector.  In general, protective
 clothing should be worn any time friable ACM is being disturbed or if there is any uncertainty
 as to the adequacy of cleanup of an area. Protective clothing should be worn whenever
 asbestos waste storage areas are inspected or if the inspector will be opening bags to
 determine if the asbestos is adequately wet.

 RESPIRATORY PROTECTION

 Classes of Respirators

 The two major types of respiratory protection equipment available for use by asbestos
 inspectors are air-purifying respirators (APRs) and supplied-air respirators (S ARs).  Air-
 purifying respirators have filters through which air passes before it is breathed.  APRs may
 be classified as positive or negative pressure respirators depending on whether the user
 creates the suction to draw air into the mask (negative pressure) or a fan propels filtered au-
 to the facepiece (positive pressure). S ARs deliver air through a hose or airline from a tank
 or compressor to the user.  EPA's Environmental Health and Safety Division's (EHSD's)
 Health and Safety  Guidelines for EPA Asbestos Inspectors details when each should be used
 at asbestos worksites. Specific information regarding  the selection of appropriate respiratory
 protection can be found later in this section.
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Air-Purifying Respirators

Negative-Pressure Respirators             s.

Although several types of negative-pressure respirators exist (e.g., disposable, quarter-
face, half-face, full-face) the EHSD Health and Safety Guidelines for EPA Asbestos
Inspectors permits the use only of the full-face type which provides a protection factor of 50.

Full-face, air-purifying, negative-pressure respirators fit across the forehead, along the
temples, and cheeks and under the chin.  These devices are held onto ones' face by a 5- or 6-
point suspension harness.

When a person wearing such a respirator inhales, the slight vacuum (negative pressure)
created in the facepiece causes ambient air to be drawn through the filtration medium (HEP A
filter) and into the facepiece. Expired air exits through an exhalation valve at the bottom of
the facepiece.

Powered Air-Purifying Respirators

Powered air-purifying respirators function like negative-pressure respirators except that a
battery-powered motor blows HEPA-filtered air into the facepiece. Since this creates a
slight positive pressure in the facepiece, any breach in the facepiece seal should permit only
the outward flow of air from the mask and thereby prevent inhalation of contaminated air.

PAPRs may have tight-fitting facepieces or loose-fitting hoods or helmets. However, the
EHSD Guidelines permit EPA inspectors to use only the tight-fitting variety. Tight-fitting
PAPRs must supply a minimum of 4 cubic feet of air per minute (4 CFM) to the facepiece.

Like full-face negative pressure respirators, tight-fitting PAPRs provide a protection factor
of 50 and may be chosen for use by inspectors where minimal respiratory protection is
required.

Supplied Air Respirators

Two types of supplied air respirators provide adequate protection for use in asbestos-
contaminated environments: air-line respirators and self-contained breathing apparatus
(SCBA).

Since agencies are unlikely to supply air-line equipment to inspectors because of its expense
and impracticality, and because EHSD prohibits the use of contractor-supplied equipment,
asbestos inspectors will typically use SCBAs instead of air-line respirators in situations
where a supplied air respirator is required.
                                                                                      3-3

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Self-Contained Breathing Apparatus (SCBA)

An SCBA consists of a full-facepiece, regulator, and a respirable compressed air supply.
The SCBA allows the user to carry the air supply, thus'-eliminating the need for a stationary
air supply. The SCBA must be operated in the pressure demand mode to be used in
asbestos atmosphere.

Selection of Respirators

The following presents the criteria for respirator selection provided in the EPA
Environmental Health and Safety Division (EHSD) Health and Safety Guidelines for EPA
Asbestos Inspectors,  The EHSD document addresses the use of known or expected fiber
concentrations and the type of inspection activity as the principal criteria for determining
respirator usage. The entire EPA guidelines document should be reviewed by anyone
conducting asbestos inspections.

General Requirements

In general, inspectors should not wear respirators unless they have been deemed "medically
fit" to wear such protection. The determination of whether the individual is medically fit is
made by a physician relying on information obtained through a medical and work history
questionnaire, a physical examination including a chest x-ray, pulmonary function tests and
gastrointestinal exam, and other tests or information deemed necessary by the medical
monitoring provisions of EHSD and OSHA regulations.

Inspectors should use only agency-owned respiratory protection equipment that they have
been specifically trained and fit-tested to use.  Inspectors  should never use equipment
offered by the abatement contractor.  Supplied air respirators other than SGBAs probably will
not be worn by inspectors since it is doubtful that their agencies will provide the equipment
necessary for this type of system.

Respirator Selection Criteria

Ideally, respirators should be selected according to the actual or potential airborne asbestos
concentrations present at the site. When an exposure level cannot be determined, an
unknown exposure condition exists. Such a situation requires the use of SCBA.  SCBA
offers the maximum level of respiratory protection. The buddy system is required in      ;
situations  where the SCBA user is in an atmosphere that is either oxygen deficient or highly
toxic and would be life threatening in case of respirator failure. AH activities  covered by
these guidelines which would not result in a life-threatening or permanent injury situation
would not require using the buddy system.

Fortunately, much is known about the exposure conditions encountered at various
worksites. In 1989, Alliance Technologies Corporation, under contract with EPA, reviewed
PCM analytical data  for over 4,000 air monitoring samples taken during renovation activities
at schools, residential buildings, hospitals, offices and industrial buildings. The study
3-4

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concluded that, when the OSHA asbestos standards for renovations were followed, no
concentrations in excess of 0.82 f/cc were found in the removal areas during active abatement
95 percent of the time.

The OSHA permissible exposure limit (PEL) for asbestos is 0.2 f/cc and the NIOSH
recommended exposure limit is 0.1 f/cc. The EPA, on the other hand, recommends that
inspectors' exposures to asbestos be limited to below 0.01 f/cc as an 8 hour Time Weighted
Average (TWA). Respirator selection criteria found in the Health and Safety Guidelines are
based on this TWA.

If asbestos inspectors can make a determination of a project's OSHA compliance prior to
entering containment, they can choose to use the lowest acceptable level of respiratory
protection, a NIOSH-approved, full facepiece respirator with HEPA filtration or any
approved tight-fitting (i.e. having a tight face to facepiece seal) powered air-purifying
respirator (PAPR) with HEPA filtration. This conclusion is based on the following
assumptions:                                                                 ......

       •     exposures in renovation sites in compliance with OSHA do not exceed 2.0
             95% of the time;
       •     full facepiece air-purifying respirators (and tight-fitting PAPRs) provide a
             protection factor of 50x;
       •     inspectors will not be in the asbestos enclosure envelope for more than two
             hours per day.

A 50x protection at an exposure level of 2.0 f/cc for two hours would result in an exposure of
0.01 f/cc TWA.  Actually, most exposures would be far less than 0.01 f/cc, for most     ;
individuals attain greater than a 50x protection factor from full-face respirators and tight-
fitting PAPRs and rarely will be in the envelope for two hours.

Air-purifying respirators include powered air purifying respirators (PAPR). These guidelines
assume that PAPRs provide the same protection as other air-purifying respirators due to the
possibility that overbreathing (i.e. inhaling at a rate that is greater than the air supplied to
the facepiece, resulting in a negative pressure in the facepiece) can occur.  This guideline is
consistent with the NIOSH Respiratory Decision Logic of 1987 with respect to the protection
offered by PAPRs. Additional PAPR  studies are being planned by NIOSH; if PAPRs are
shown to have higher protection factors in the future, appropriate changes will be made
regarding selection of respiratory protection.

OSHA Asbestos Standard Compliance

An abatement project's compliance with the OSHA asbestos standards can be gauged by
findings that:
                                                                                    5-5

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1.     Records on- or off-site show that all employees have been trained as required by
       OSHA standards.  When records are kept off-site, the inspector should ask the
       supervisor to state that proper records exist and are available for later review.
       (Passing an approved AHERA class is desirable but not required for buildings not
       covered by the AHERA regulations.  Compliance with state and local training
       requirements should be checked on a case-by-case basis.);

2.     Records, either on- or off-site, show that project employees have been given medical
       exams, including a determination that they are fit to wear respirators;

3.     Amended water is being used to wet the ACM. (Check to see that amended water is
       on-site outside the envelope.);

4.     No power tools are being used to remove ACM;

5.     The envelope is secure and no dust or debris appears to be coming from the removal
       area;

6.     Warning signs are posted and adequately labeled containers are being used in the
       removal of ACM;

7.     A permit for disposal has been obtained from the State or local government;

8.     Employees are carefully removing ACM and not dropping materials on the floor;

9.     Decontamination accommodations, including shower facilities, are in place;

10.    Existing monitoring data indicate that asbestos fibers in the work area do not exceed
       2.0 f/cc as an 8-hour TWA;

11.    There is a written respiratory protection program and respirators are being used; and

12.    A removal plan has been (or can be) made available for review.

The asbestos NESHAP inspector must exercise proper judgment in determining that air-
purifying respirators will provide adequate protection. The capability to make such
determinations must be obtained through both classroom and on-the-job training.

EPA inspectors entering a removal, demolition or renovation area should select the
appropriate respiratory protection according to the following locations and conditions.

No Respiratory Protection Required

No respiratory protection is required outside of the asbestos  area-enclosing envelope when:
3-6

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       •      inspecting office areas and other locations outside the barrier.  All barrier
              seals must be intact, and all envelope entrances must have at least a double
              barrier. No visible airborne dust or debris that is potentially asbestos-
              contaminated should be present on any surface in the area;
       •      secondary containment is in place during glove-bagging operations. The
              secondary containment enclosure must be complete, and, for all but small-
              scale, short-duration operations, must also be under negative pressure;
       •      materials removed from the envelope have been cleaned and the pathway for
              removal of bags and equipment is clear and clean;
       •      all ventilation systems in the envelope are off and sealed (This excludes
              negative pressure systems designed for the removal project.); and
       •      wet methods are being used.

No respiratory protection is required inside the envelope when:

       •      inspecting any restricted area has already passed an appropriate clearing test
              (e.g., minimum of aggressive sampling demonstrating a concentration below
              O.Olf/cc by PCM); or
       •      no removal work has begun and all ACM is intact, not disturbed, not damaged,
              no debris is present, and the inspection will not disturb any ACM.


Respiratory Protection Required

Respiratory protection will be required in many situations encountered by inspection
personnel, both inside and outside the active removal area. For example, respiratory
protection and personal protective equipment are required for inspections conducted outside
the work area if all of the previously listed conditions have not been met.  In addition,
respirators and personal protective equipment are required whenever an inspector enters a
work area that has not been cleared for reoccupancy.

To determine the type of respiratory protection required, an inspector must rely on available
information and observations of the conditions at the work site.  As a minimum, the EHSD
document requires either a full-face,  air-purifying, negative-pressure respirator with HEPA
filters or a powered air purifying respirator (PAPR)  with HEPA filters. An inspector can
upgrade respirator selections at any time, but should never downgrade selection.

To determine the type of respirator to use,  a number of conditions must be met. These
conditions can be identified through a records review, pre-entry observations and
interviewing site personnel. If adequate information is not available to document all of these
conditions, an inspector must use his/her judgment to determine the level of respiratory
protection to wear. If upon entering the work area enclosure the inspector determines that
the conditions have not been met, he/she should immediately leave the work area and
upgrade the level of respiratory protection.
                                                                                    3-7

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Air-purifying Respirators

Full facepiece air-purifying respirators or tight-fitting PAPRs shall be worn by inspectors
when:
       •     inspecting outside the barrier where workers outside the barrier are wearing
             air-purifying respirators;
       •     inspecting outside the barrier where the barrier is not complete and/or
             asbestos-containing debris is present;
       •     inspecting inside the envelope when an inspection of the operation shows it to
             be in compliance with the OSHA asbestos standard. If upon entering the
             envelope, visible emissions are seen or other evidence suggesting non-
             compliance is apparent, the inspector will immediately leave the area. Prior to
             returning to the removal area to document violations, the inspector shall  don
             SCBAgear;
       •     inspecting inside the barrier and no active removal or disturbances have
             occurred in the past 24 hours and the inspection will not disturb any ACM.

Atmosphere-supplying Respirators

Atmosphere-supplying respirators are required when:

       •     performance of the asbestos abatement project is not in accordance with
             OSHA standards;
       •     materials are being removed which are not being properly wetted, or removal
             causes the generation of significant levels of dust;
       •     monitoring data at the site show levels in excess of 2.0 f/cc;
       •     the inspector will be spending more than 2 hours inside the containment
             envelope; and         .          -.-•'--.
       •     others at the site are Wearing atmosphere-supplying respirators.

If the above conditions are not met, or if during the course of the inspection the conditions
change, a self-contained breathing apparatus (SCB A) will be required. Supplied air
respirators (SARs) may not be acceptable if this would require the inspector to use
contractor equipment.

A Respiratory Protection Selection Checklist is provided for the convenience of inspectors as
Appendix B of this inspection manual.
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Other Medical/Physical Considerations in Respirator Usage

Medical Monitoring .

       •      Wearing & respirator imposes a physical stress on the user.  Air-purifying
              respirators require some effort during inhalation and exhalation to overcome
              the resistance of the filter media and valve seals.  The physical weight of an
              SCBA may create a problem especially if extended work time and strenuous
              work are required.  Air-line respirators impose some physical stress due to
              the weight of the attached air-line hose.  OSHA regulations state that a
              person shall not be required to wear respiratory protective devices unless it
              has been determined that he/she is physically capable of doing so. A
              physician knowledgeable in the field of occupational health should assess
              one's pulmonary and cardiovascular status relative to respirator usage.
       •      Pulmonary considerations:  the wearer should be examined for any respiratory
              impairment from disorders such as emphysema,;obstructive lung disease,
              bronchial asthma, etc.  Medical tests required are pulmonary function (PFT),
              FEV, FVC, and chest x-rays. This testing is preceded by the completion of a
              medical and work history questionnaire.          ,....,,             ,
       •      Cardiovascular: the wearer must be evaluated according to one's medical
              history and current cardiovascular status. A stress test may be required for
              certain individuals in order to determine the absolute risk.
                                            . f.1, -.'...  ,  ,  , .  '•     ~ „
Miscellaneous Considerations

              Facial hair: OSHA standards  prohibit the use of respirators if one has any
              growth of facial hair. The effect of .facial hair on a respirator's performance
              (half-mask and full-facepiece respirator) depends upon the degree to which
              the hair interferes with the sealing surface of the respirator,  the physical
              characteristics of the facial  hair, the type of respirator worn in relation  to the
              wearer's facial characteristics, etc. In all cases, however, the wearer cannot
              expect to obtain a face  seal  as satisfactory as those obtained by persons who
              are clean shaven.
       •      Scars, hollow temples,  high cheekbones, deep  skin creases,  and the lack of ,
              teeth or dentures may cause respirator sealing problems.  Full dentures
              should be worn when wearing a respirator, but partial dentures may or: may
              not have to be removed. Full lower dentures may be a problem since the
              lower edge of the mask may unseat the dentures.     	
       •      An inspector may be deemed medically fit to wear a respirator; however,
              he/she may feel claustrophobic in one and therefore be considered
              "psychologically" unfit. Prior to using personal protective clothing and a
              respirator during an actual inspection, an inspector is advised to conduct a test
              run.
                                                                                     3-9.

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Field Inspection and Checkout Procedures

Immediately prior to use, a respirator must be thoroughly inspected by the individual who
will be using it.  As a minimum, OSHA standards require that the respirators be inspected
for the following:

       •      tightness of all connections;
       •      integrity of the facepiece, valves, connecting tube, and canisters; and
       •      proper functioning of the regulator and warning devices on SCBA.

Specific to each respirator type, the following should be performed each time the respirator is
used.

Air Purifying Respirator

       •      Examine the facepiece for scratches, cracks, tears, holes, distortion, excessive
              or residual lint, dirt, etc.
       •      Examine facepiece seal to ensure that it is flexible and that there are no cracks
              or tears.
       •      Examine filter cartridge holders for cracks, badly worn threads or missing
              gaskets.
       •      Check head straps and harness for breaks, loss of elasticity, broken or
              malfunctioning buckles, or excessively worn serrations.
       •      Determine the existence of inhalation and exhalation valves and examine them
              for wear, foreign particles, cracks, tears, improper seating or installation, or
              breaks or cracks in the valve body seating surface.
       •      Ensure that cartridges are the correct type.  Cartridges must be from the same
              manufacturer as the respirator and must be approved for use in an asbestos
              atmosphere (type H, high efficiency filter, magenta color code).
       •      If the device has a corrugated breathing tube, examine for broken or missing
              end connectors, gaskets or o-rings, missing or loose hose clamps, or
              deterioration of the tubing.
       •      If respirator is a PAPR, determine whether the battery is fully charged, the
              cartridges are properly connected, the fan is functioning properly, and
              appropriate amounts of air are being delivered to the facepiece.
       •      Conduct a negative pressure test.  With the respirator on and adjusted, block
              the flow into inhalation valves and inhale. The facepiece should collapse
              inward with no noticeable leaks.
       •      Conduct a positive pressure test.  With the respirator on and adjusted, block
              the flow from the exhalation valve and exhale. The facepiece should balloon
              outward slightly with no noticeable leakage.
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Self-Contained Breathing Apparatus (SCBA)

       •      Check the facepiecfe in a similar fashion as for air-purifying respirators.
       •      Check the air supply system for:
                   integrity and good condition of air supply lines and hoses, including
                   attachments and end fittings;
                   correct operation and condition of all regulators, valves, and alarms; and
                   sufficient air charge in the high pressure cylinder for the use period.
                   Preferably, the tank should be fully charged.
Respirator Maintenance

Cleaning and Disinfecting

Respirators should be cleaned after each use in accordance with the manufacturer's
instructions. This cleaning is usually done by the wearer if respirators are individually
assigned. If such is not the case, it is best to have one person responsible for daily cleaning
and inspection of respirators.

OSHA regulations specify that a respirator must be cleaned and disinfected as frequently as
necessary to insure that the wearer is provided proper protection. In asbestos abatement
operations, it is recommended that respirators be rinsed after each inspection and thoroughly
cleaned and inspected at the end of each days' use. Each worker should be briefed on the
cleaning procedure and be assured that a clean and disinfected respirator will always be
issued.  This is of greatest significance when respirators are not individually assigned.

The following general instructions may be helpful in cleaning and disinfecting the respirator,

       •     Remove all cartridges, canister, filters and gaskets or seals not affixed to their
             seats.
       •     Remove headband assembly, straps, exhalation valve Cover and cartridge
             holders.
       •     Remove speaking diaphragm or speaking diaphragm-exhalation valve,
             assembly.
       •     Remove inhalation and exhalation valves.
       •     Wash components separately from the facemask.
             Wash facepiece and breathing tube in cleaner/sanitizer powder mixed with
             warm water, preferably at 120° to 140°F. Most respirator manufacturers
             market their own cleaners/sanitizers which are dry mixtures of a bactericidal
             agent and a mild detergent. One-ounce packets for individual use and bulk
             packages for quantity use are usually available.  Remove heavy soil from
              surfaces with  a hand brush.
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              Remove all parts from the wash water and rinse twice in clean warm water.
              Air dry parts in a designated clean area.
              Wipe facepieces, valves, and seats with a damp, lint-free cloth to remove any
              remaining soap or other foreign materials. Reassemble respirator.
Storage
Follow the manufacturer's storage instructions. Instructions are always furnished with new
respirators or affixed to the lid of the carrying case. In addition, these general instructions
may be helpful:

       •      After inspection, cleaning and necessary repair, store respirators where they
              will be protected from dust, sunlight, heat, extreme cold, excessive moisture,
              or damaging chemicals. Note: Respirators should be thoroughly dried before
              being sealed in any container for storage.
       •      Store respirators in a convenient, clean, and sanitary location. The purpose of
              good respirator storage is to ensure that the respirator will function properly
              when used.
       •      Do not store respirators in clothes lockers, bench drawers, or tool boxes.
              Place them in wall compartments at work stations or in a work area
              designated for emergency equipment. Store them in the original carton or
              carrying case.
       •      Pack or store respirators so that the facepiece and exhalation valves will rest
              in the normal position. Respirators should not be hung by their straps. This
              will ensure that proper function is not impaired by distortion of the respirator
              or its straps.

OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES

The procedures for entering and exiting sites described in this section are a summary of
those described in the Health and Safety Guidelines, and have been generalized to cover
both the use of an air-purifying respirator and SCBA.

Entering and Exiting Site with a Three-Stage Decontamination System

A three-stage decontamination system consists of a clean room,  shower room, and
equipment room (sometimes referred to as a dirty room) contiguous with the active removal
area.  The OSHA asbestos Construction Industry Standard (29 CFR 1926.58) requires the
use of this type of decontamination system for removal, demolition, and renovation projects
(detailed in Appendix F of the OSHA standard).
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Prior to Entering the Clean Room
     Determine that the respirator is functioning properly.
     Make sure that you have all materials and equipment necessary to
     conduct the inspection safely (e.g., protective clothing, respirator, extra
     plastic bags, spray bottle, disposable towels, flashlight, camera, etc.).
     All materials carried into the contaminated, area should be sealed in a
     plastic bag to minimize contamination.
     If you take a camera into the contaminated area, precautions must be
     taken to minimize contamination and to decontaminate the camera when
     exiting. Use of a waterproof camera or sealing a conventional camera in
     an impermeable clear camera box will facilitate a more complete
     decontamination.
In the Clean Room
     Remove all street clothing including socks and underwear.  If desired,
     wear a bathing suit (or equivalent), appropriate footwear (sneakers,
     steel toed shoes, etc.) and inner disposable footcoverings. The inspector
     should leave his/her clothes in a clean sealed plastic bag to protect
     against accidental contamination by abatement workers. Any equipment
     not taken into the contaminated area should also be placed in the plastic
     bag.
     If an SCBA will be used, close the air flow valve and don the SCBA; let
     the respirator facepiece hang from the neck by the strap.
     Don disposable, full-body, hooded coverall (e.g.,  Tyvek® or equivalent).
     If using an SCBA, wear a coverall with an expandable back or oversize
     (XXL) Tyvek® over the SCBA.
     Don disposable outer boots and seal to outer  suit with duct tape.
     (Tyvek® booties will rip quite easily once they become wet.  The
     inspector may wear disposable rubber boots or reinforced rubber boots).
-    Fit respirator facepiece to face. Perform negative and positive pressure
     field checks for air-purifying respirator. For SCBA, open air valves and
     adjust facepiece straps.
     Fit the coverall hood snugly around the respirator facepiece and zip up • • •
     coverall. Use duct tape to close gap at neck if desired.
     Don disposable gloves; use duct tape to seal them to the coveralls.
     Proceed through the shower area and equipment room and into the work
     area; disposable towels and soap may be left behind in the shower area).
     Conduct the inspection.
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             Before Leaving the Contaminated Area
                  HEPA vacuum (if possible) any visible debris from protective clothing
                  and sample containers, sampling equipment, and any other items which
                  are being taken out of the work area.  Proceed to the equipment room.

             In the Equipment Room

                  If possible, decontaminate all non-disposable equipment including
                  footwear at the site. If not, seal all contaminated non-disposable
                  materials in a plastic bag and take them with you to decontaminate at a
                  later time.
                  While still wearing the respirator, carefully remove the outer booties and
                  gloves and take off the coveralls, rolling them inside out in the process.
                  Place all contaminated protective clothing in a properly labeled waste
                  disposal, container.
                  If a PAPR or an SCBA is worn, removal of protective clothing can be
                  awkward since the respirator must continue to function. For a PAPR,
                  remove the belt and harness on which the motor and filter mount and hold
                  while removing coveralls and proceed to the shower. For an SCBA,
                  carefully remove coveralls, lower the tank assembly to the ground or
                ,  balance it between your legs and proceed to the shower.

             In the Shower Area
                  For negative pressure respirators, take a deep breath and thoroughly
                  shower your head with the respirator on; remove respirator and clean it.
                  Dispose of HEPA filter cartridges as asbestos-containing waste.
                  For PAPRs or SCBA, hold battery and mechanical parts away from
                  shower water while rinsing your head and the respirator facepiece.
                  Remove the respirator facepiece and then wet-wipe the other
                  components of the PAPR or SCBA. Dispose of HEPA filters as
                  asbestos-containing waste.
                  If wearing a bathing suit, remove and thoroughly rinse it and place it in a
                  plastic bag.  Finish showering, thoroughly washing the entire body with
                  soap and water.
                  Proceed to the clean room.

             In the Clean Room
                  Dress in street clothes.
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Entering and Exiting Sites Without a Three-Stage Decontamination System

Often inspections are required at sites where a three-stage decontamination system is not
available.  When confronted with such a site, the inspector must use his or her judgment
regarding the safest method of conducting the inspection.

             Before Entering the Contaminated Area
                   Make sure the respirator is operating properly.
                   Make sure you have all materials and equipment necessary to conduct
                   the inspection safely (e.g., protective clothing, respirator, disposable
                   towels, extra plastic bags, spray bottle, flashlight, camera etc.).
                   Materials carried into the work area should be sealed in a plastic bag to
                   minimize contamination.
             -     If you take a camera into the contaminated area, precautions must be
                   taken to minimize contamination or to decontaminate the camera. Use of
                   a waterproof camera or sealing a conventional camera in an impermeable
                   clear camera box will enable more complete decontamination.
                   Leave all street clothing on. Short-sleeve shirts and short pants are
                   preferable. If you are wearing long pants or long sleeves, roll them up.

                   Don an inner disposable coverall and inner booties (e.g., Tyvek® or
                   equivalent) over street  clothes.
                   If an SCBA will be used, close the air flow valve and don the SCBA; let
                   the respirator facepiece hang from the neck by the strap.
                   DonthePAPR.
                   Don outer disposable coverall. Wear coverall with an expandable back if
                   an SCBA is used, but do not zip it up.  (An oversize (XXL) Tyvek® suit
                   may substitute for an expandable back suit).
                   Don disposable outer boots; use duct tape to attach the boots to the
                   outer coverall.  (Tyvek® booties will rip quite easily once they become
                   wet. Disposable rubber boots or reinforced rubber boots may be used).
                   Fit the respirator facepiece  to the face, open the air valve of the SCBA
                   and tighten the facepiece straps. If an air-purifying respirator is used,
                   conduct negative pressure and positive pressure field tests.
                   Fit the coverall hood snugly around the respirator facepiece arid zip up
                   the coverall.
                   Don disposable gloves; use duct tape to seal gloves to the outer coverall.
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                   Proceed into the work area.
                   Conduct the inspection.

              Before Leaving the Contaminated Area
                   Standing near the exit, HEPA vacuum (if possible) and wet wipe all
                   visible debris from the outer protective clothing (use a spray bottle
                   containing water and disposable towels to wet wipe the suit; use plenty
                   of water). Standing at the doorway inside the work area, remove outer
                   protective clothing, role the coveralls inside out, and immediately step
                   outside the area. Place the suit in a labeled waste container.

              Outside the Contaminated Area
                   Thoroughly  wet wipe and mist spray the respirator and inner disposable
                   coverall. Move away from the doorway and remove the inner protective
                   clothing. Place the disposable coverall into a labeled waste container.
                   Wet and seal all contaminated non-disposable materials in a plastic bag
                   and take them with you to decontaminate later.
DISPOSAL OF CONTAMINATED CLOTHING

Contaminated or potentially contaminated protective clothing worn during asbestos
inspections should be discarded as asbestos-containing waste. These materials include the
coveralls, disposable boots, disposable gloves, respirator cartridges, and any other
miscellaneous materials such as paper towels or wet wipes. Usually, inspectors can discard
their contaminated clothing in labeled, scalable waste containers provided by the
owner/operator. Since the owner/operator must treat the waste disposed in this container as
asbestos-containing, the inspector can assume that the material he or she discards will be
disposed of properly. Although this procedure is generally acceptable, it is always a good
idea to obtain permission from the owner/operator before discarding contaminated clothing.

There will be cases, however, when disposal of contaminated clothing will present a problem
to the inspector. For example, the inspector may be conducting an inspection where the
owner/operator is not properly disposing of waste or where permission to discard inspector
waste is not granted. In such cases, proper handling and subsequent disposal of
contaminated clothing becomes the responsibility of the inspector.  It is important, therefore,
that the inspector come to the site prepared for such instances and that policies exist within
his/her agency to deal with asbestos-containing waste.

Contaminated clothing must be placed in sealed plastic bags before leaving the site. The
inspector should carry disposal bags with him/her. Preferably, these bags should be pre-
labeled, scalable waste containers, but plastic trash bags will serve the purpose provided
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that they are eventually placed in labeled bags before final disposal. The exact procedures to
follow in handling the bagged waste and ultimately disposing of the material is up to the
policy of the regulatory agency.                                      .

OTHER SAFETY CONSIDERATIONS IN ASBESTOS WORK

Because inspections are often conducted in a building undergoing demolition or renovation,
increased asbestos exposure is only one of the many hazards inspectors may encounter.

             Heat Stress—Due to the protective clothing and equipment worn and the
             often hot and humid conditions in which they work, inspectors are in jeopardy
             of developing heat stress.
             The loss of water via perspiration is the main factor responsible for various
             forms of heat stress which include heat cramps, heat exhaustion, and heat
             stroke.

             Since dehydration is the main contributing factor, heat stress can be prevented
             almost entirely by ensuring adequate fluid intake. Plain water is the best
             liquid, but fruit juices and other drinks which do not contain  excessive amounts
             of salt, sugar, or caffeine may be drunk.

             Use of a PAPR, increased local exhaust ventilation and gradual acclimatization
             to the hot environment will also  help prevent heat stress.

             For any inspection lasting more than 15-minutes in an atmosphere of 70°F or
             higher, inspectors should follow the recommendations found in the NIOSH
             interagency document Health and Safety Guidelines for Hazardous Waste
             Workers.

       •     Climbing Hazards—Inspectors may need to examine elevated surfaces during
             an inspection. Since wearing a respirator may reduce an inspector's vision
             and stairways, railings, scaffolding and ladders may not be in prime condition,
             great care must be taken.
             OSHA standards require that when free-standing mobile scaffolding is used,
             the height must not exceed four times the minimum base dimension. For
             mobile scaffolding, the base dimension must be one-half the height. Most
             safety precautions involving ladders and stairways require common sense.
             For example, inspectors should not stand on the top step of a ladder and
             should ensure the ladder is on solid footing.

       •     Working Surfaces—Polyethylene sheeting will be on the floors at most
             removal jobs. When wet, this floor covering is very slippery.  Additionally, air
             lines, water lines, bags of waste, electrical cords, stripped asbestos and ,
             debris, and disposable boots worn by the inspector may present a tripping
             hazard.
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              Lighting—Lighting may be unavailable for pre-removal or post-removal
              inspections.  In these situations, an inspector must use a hand-held
              flashlight. Hazards of poor lighting include risk of head injury from suspended
              objects such as low hanging pipes, light fixtures, etc., and other injuries due to
              tripping or falling over objects on the floor.
              Electrical Safety—Due to the use of wet methods, electrical shock is a risk
              in the vicinity of electrical panels, conduits, light fixtures, alarm systems,
              junction boxes, computers, and transformers. Inspectors should ensure that
              the electrical system is ground-faulted (as required by OSHA). Common
              recommendations for electrical safety include use of non-conductive sample
              collection devices (wood,  plastic, rubber) and avoidance of puddles of water
              near electrical wires or extension cords.
              Falling/Fallen Objects—Where there is a possibility of head injury from
              impact or from falling or flying objects, inspectors should wear head protection
              which meets ANSI Z89.1-1969 safety requirements for industrial head
              protection.
              Biological Hazards—Wild animals in abandoned buildings, rats, snakes,
              insects.
              Chemical Hazards—PCBs, spray poly (intense ammonia smell), solvents,
              dry ice.
              Lack of Oxygen—Crawl  spaces or other areas with little or no ventilation.
              Unsafe Structures—Floors and  stairs in old buildings may be unsafe and in
              danger of collapse.  The inspector should take care when conducting
              inspections in old or partially demolished buildings.
              Painted Skylights—Stepping on such an area can cause serious injury.
              Claustrophobia—Panic induced by protective equipment and confined spaces
              can cause serous injury.
              Noise—Inspectors should carry hearing protection with them as standard
              equipment and use it when necessary.
              Machinery Hazards—Adequate safety precautions should be taken when
              visiting sites where power washers, shredders, or high-powered vacuum
              machines are in use.
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                                    SECTION 4
                      PRE-INSPECTION PROCEDURES
In-office activities of a NESHAP inspector prior to onsite inspections ensure smooth field
inspections.  Specific activities include reviewing notifications, tracking non-notifiers and
preparing inspection equipment. Specific details are presented below.

Review Notification

The notification should be reviewed for completeness relative to the requirements of
61.145(b). When scheduling an inspection, an inspector should focus particular attention on
the following details:

       •     Location of the facility;
             Schedule for demolition or renovation; and
             Quantity of friable, nonfriable having the potential to become friable, and
             nonfriable ACM (to determine applicability of the asbestos NESHAP).

Asbestos removal operations at schools should be coordinated with the Regional Asbestos
Coordinator, if possible, to check for compliance with AHERA and WPR regulations.

Identifying Non-Notifiers

The worst-case violation of the notification requirements of 61.145(b) would be the complete
failure to notify. The following techniques can be used by inspectors to identify noh-notifiers;

              Respond to complaints from the general public, employees, or competitors who
              may have recognized a very low bid award. Also, use cross-referral
              information from other Federal, State and" local agency inspectors.
       •      Drive by the site enroute to or from other inspections while the
              demolition/renovation appears to be in progress. The presence of a roll box for
              disposal of construction debris is strong evidence of demolition/renovation
              activities.
              Observe trucks entering a landfill and question their origin if suspected
              asbestos debris is on board. Regularly conducting inspections at landfills to
              review asbestos receiving records will also provide information on contractors
              who have notified.
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        •      Review demolition or renovation permits written by the local building
              department.
        •      Review trade journals, newspapers, etc., for ongoing or past projects.

 Preparation of Inspection Equipment

 In order to ensure the most efficient and complete inspection possible, an inspector must
 gather and pack all equipment necessary for the inspection.  A detailed list of equipment and
 explanations of the purpose of each item follows.  A checklist is provided in Appendix C for
 the convenience of inspectors.

        •      Copy of Notification—-If notification has been provided, it should be available
              to verify the accuracy of information required to be included under 61.145.
        •      Protective Equipment—The EHSD guidance recommends that the following
              items be used by asbestos inspectors (refer to Section 3 for further details):
                   respirator(s)
                   disposable full-body, hooded coveralls
                   disposable gloves
                   disposable inner and outer booties
                   hard hat
                   safety shoes
                   duct tape
                   liquid soap
                   disposal towels
                   bathing suit (or equivalent)

        •      Employee Identification—Proper credentials to prove authority for performing
              the inspection, and any certification cards of respiratory fit-testing or medical
              monitoring.
        •      Copy of Asbestos NESHAP Regulation—Helps resolve disagreements if the
              owner/operator is unfamiliar with regulations; it is advantageous to leave a
              copy with the owner/operator.
        •      Bound Notebook and Writing Implements—Note that inspectors should take
              notes and fill out checklists to every extent possible before entering the
              removal area. (Note: in some situations, it may be critical to enter the work
              area quickly to assess potential violations; in  these cases the checklist and
              notebooks can be filled out after the inspections). Where practical, leave the
              notebook and checklist outside the contaminated area and fill out immediately
              after decontamination. Alternatively, plastic  clipboards, plastic transparency
              sheets and waterproof pens or divers' underwater writing materials, all of
              which can be decontaminated, may be used.
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Field Data Collection Checklists—Checklists are useful as a reminder of the
baseline information needed for all inspections. See Appendix C for a copy of a
representative checklist.
Camera (with flash)—Take photographs of sample locations and visible
emission sources. Waterproof cameras are convenient when wet removal is
occurring, and decontamination is required.
Flashlight—Work may be conducted in areas with inadequate lighting such as
basements, above drop ceilings, and buildings in which the electricity has been
turned off.
Binoculars—Necessary for offsite observations.
Tape Measure—Inspectors should carry tape measures so that they may
accurately quantify the amounts of friable ACM.  As an alternative, an
inspector may pace off distances and estimate distance based on a previously
measured pace.
Chain-of-Custody Forms and Labels—These forms and labels allow
inspectors to properly distinguish each sample and to maintain a record of
sample possession and transfer.
Shipping Supplies—Samples may be sent to a laboratory from the field.
Sampling Equipment—The following equipment and materials are used for
bulk sample collection (refer to Section 8 for further details):

      sample containers
      water  spray bottle
      adhesive tape
      tools (knife, tweezers, coring device, etc.)
      drop cloth
      wet wipes
      plastic bags
      glovebag (for those situations where bags are opened outside the
      containment area)
      disposable towels

Extra fresh batteries - for camera and flashlight
Business cards
Building diagrams (if available)
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                                    SECTION 5

                      ONSITE FACILITY INSPECTIONS
Onsite facility inspections provide the foundation for all asbestos NESHAP enforcement
actions for substantive violations and therefore are critical to enforcing NESHAP. Onsite
inspections are also used to determine whether potential AHERA or WPR violations exist.
(Field Inspection Checklists are included as Appendix C to this document.)

In most cases it is necessary for the inspector to enter active removal areas to determine
compliance and to collect evidence of non-compliance.  Due to irregularly scheduled asbestos
removal, inspectors may find themselves conducting a pre-removal inspection if a job is
delayed, or a post-removal inspection if a job is completed ahead of schedule. The following
provides step-by-step inspection procedures common to pre-removal, active removal, and
post-removal inspections.  All inspections for the asbestos NESHAP are intended to be
unannounced.

PRE-ENTRY REMOTE OBSERVATIONS

The pre-entry observations (which may be conducted remotely using binoculars) enable the
inspector to determine the location and type of activities in progress.  Additionally, pre-entry
observations provide the inspector with information regarding the appropriate safety
equipment to use. Upon arriving at the site, an asbestos inspector should do the following:

              Look for visible emissions to the outside air (from window, doors, etc.).
       •      Look for suspected asbestos-containing debris outside the removal area.
       •      Observe waste storage areas (dumpsters) and evaluate the quantity and
              condition of the waste created.
       •      Note land use surrounding the site in order to assess exposure liabilities. Are
              there residences, schools, playgrounds, etc. nearby? (Draw a land-use
              diagram in the field notes.)
              Attempt to establish the magnitude and location of the asbestos project within
              the facility.
              Sketch the general site layout and areas to be inspected. Verify that all
              pertinent locations are incorporated into the inspection plan.
              Check safety equipment. TheEHSD Health and Safety Guidelines for EPA
              Inspectors states that EPA employees should use only EPA- owned
              respiratory equipment that they have been specially trained and fit-tested to
              use.
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               Observe trucks being used to haul suspect ACWM.  Are they properly
               marked?
 PRE-ENTRY INTERVIEW

 During the pre-entry interview, it is critical that discussions are properly documented. They
 may later be considered admissions of guilt if violations are detected. The following steps
 should be followed once an inspector arrives onsite:

       •      Request to see the owner/operator or site foreman.
       •      Show identification credentials and explain the authority and purpose of the
              inspection.  (State and local agency inspectors may need to carry specific
              licenses or certifications.)
       •      Discuss the inspection procedure:
                   photographs
                   samples

       •      If denied entrance, do not be forceful. Simply explain that the authority for this
              type of inspection is explicitly given in Section  114 (a)(2) of the Clean Air Act
              which states that EPA inspectors shall:
              "...have a right of entry to,  upon, or through any premises in
              which an emission source is located..."

              Also state that:

                   the agency's regulatory attorney will be informed and, if necessary,
                   the agency will apply for a warrant to gain entry.

              Show medical monitoring credentials. In some instances, a facility
              owner/operator may demand to see proof that an inspector is meeting the
              requirements of the OSHA medical monitoring program. Because this is a
              reasonable request, inspectors are advised to carry an agency medical
              monitoring credential. (Note: EPA personnel are not specifically subject to
              the OSHA standard; however, they are subject  to the EHSD  guidelines which
              stipulate similar requirements.)
              Review the notification.                    •
              Sign no waivers. It is EPA's policy that liability waivers never be signed.
              Other inspectors should refer to the specific policies of their State or local
              agencies.
              Establish the identities of all responsible individuals, from the person being
              interviewed to the building owner. Also document the name and title (and
              address, if possible) of all parties interviewed during the inspection.
              (Collecting business cards of these individuals is a good practice.)
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             Determine a logical sequence for the site inspection to promote its overall
             efficiency.  Determine if there are any safety considerations in addition to
             those already anticipated.


Interview Questions

During the interview inspectors should attempt to gain an understanding of the procedures.
being employed onsite to minimize asbestos fiber release. Inspectors should ask both
general and site- specific questions, examine on-site documents and observe work practice
procedures outside the work area in order to choose appropriate personal protective
equipment (pursuant to the EHSD Guidelines - see Section 3) and to determine preliminary
compliance with NESHAP, AHERA and the WPR. Answers to the following may become
valuable evidence in the event violations are detected.

General Questions

             Has the owner/operator ever engaged in removal of asbestos before?
       •     What formal training has the owner/operator or his staff had regarding the
             handling of asbestos?
             What is the owner/operator' s understanding of the NESHAP requirements for
             the handling of asbestos during removal?


Site-specific Questions

             Has removal work begun?  (If not, is all ACM intact, undisturbed and
              undamaged, and no debris present?)
              Is there a written respiratory protection program and are respirators being
              used?
        •      Is the work area completely enclosed with plastic sheeting or equivalent?
        •      Have all the ventilation systems that have components in the envelope been
              shut off? _ .                         .
              Are all vents in the work area taped shut?
        •      Are decontamination means, including shower facilities, in place?

        •      If glove bags are being used:                              ,  ,
                   Is secondary containment which is under negative pressure in place?
                   (OSHA 29 CFR 1926.58 requires that "wherever feasible, the employer
                   shall establish negative pressure enclosures before commencing
                   removal, demolition and renovation operations.)

                   Are the glove bags themselves under negative pressure? (A special
                   attachment to a HEPA vacuum may be used to create a reduced pressure
                   atmosphere within the bag while the removal takes place. Secondary
                   containments most likely will not be used in this case.)
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               What kind of asbestos is reing removed? (Is it capable of being adequately
               wetted?
               Are wet methods being used (i.e. no dry scraping, wire brushing of dry
               materials, nor sweeping or other handling of dry debris)?
               Is amended water being used to wet the ACM? (Check to see that amended
               water is onsite outside the envelope.)
               If wet methods are not being used, what emission control methods are being
               used?                                        .,..-..
               Are power tools being used to remove ACM?
               Are employees removing ACM appropriately (i.e., using dust-tight chutes, not
               dropping materials to the floor, etc.)?
               Has a waste disposal permit been received?  (not required by NESHAP)
 Document Examination
              Do existing monitoring data indicate that asbestos fibers in the work area do
              not exceed 2.0 f/cc?
              Do records on site show that all employees have been trained as required by
              OSHA, State and local authorities?
              Do records show that project employees have been given medical exams,
              including a determination that they are fit to wear respirators?
              Has the area already passed an appropriate clearing test (minimum of
              aggressive sampling with a concentration below 0.01 f/cc by PCM)?
              Is there information posted and available for inspection documenting that at
              least one on-site representative has received training in the provisions of the
              NESHAP regulation? (This requirement is effective 1 year after promulgation
              of the revised NESHAP.)
 Pre^entry Worksite Observations
              Are warning signs posted?
              As a minimum, have all envelope entrances been constructed as a double
              entry system (usually two or three sheets of plastic draped between each
              stage of the entry system)?
              Are all barrier seals intact with no dust or debris coming from the removal
              area?
              Is there any dust or debris that is potentially asbestos- contaminated present
              on any surface in the area?
              Are adequately labeled containers being used in the disposal of ACM?
              Have materials removed from the  envelope been cleaned?
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             Is there a clear and clean pathway for the removal of bags and

             equipment?
PRE-REMOVAL INSPECTION

Facility inspections conducted prior to commencement of asbestos removal do not enable the
inspector to fully evaluate the owner/operator's compliance with the asbestos NESHAP.
However, if an inspector does arrive onsite prior to removal, useful information can be
gathered. In this case, the principal objectives are to verify that the asbestos NESHAP is
applicable, and to gain a sense of the owner/operator's ability to remove the asbestos
appropriately.

As with any inspection, safety must be considered before the inspection begins. The specific
safety requirements will be left to the discretion of the inspector. As a general rule,
however, if any friable ACM or nonfriable ACM in poor condition is being disturbed, the
inspector should treat the inspection as an active removal situation and follow the suit-up
procedures in Section 3.

The following summarizes inspection activities relative to NESHAP requirements. The
entire NESHAP text can be found in this manual as Appendix A.,

Applicability (61.141,61.145)

             Verify that the site meets the definition of a facility:
              "any institutional,  commercial, public, industrial, or residential
              structure, installation, or building (residential buildings having
              four or  fewer dwelling units are excluded); any  ship;  and aiiy
              active or inactive waste disposal site."

       •      Determine whether the activity is classified as a demolition or renovation.
              Measure the amount of ACM that is scheduled to be disturbed to determine if
              the minimum quantity of 260/160/35 is exceeded.                 ,        ^ •

Notification [61.145(b)]

       •      Determine whether a notification exists and, if it does, verify that the
              information conveyed verbally during the inspection agrees with the
              information provided in the notification.            ,
              Determine if the amount of ACM designated by the owner/operator for
              removal is accurate relative to the amount that the inspector thinks will
              potentially be disturbed during the demolition or renovation.
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 Planned Emission Controls [61.145 (c)]

 Observe equipment onsite and elicit verbal explanations of planned emission control
 procedures to ascertain whether the owner/operator is sufficiently equipped and
 knowledgeable to meet the wetting and handling requirements of 61.145 (c). Consider the
 following:

        •     Will water and wetting agents be available for wetting ACM before removal and
              maintaining it in a wet condition until it is collected for disposal?
        •     If wet methods will not be used, what emission control methods are planned?
        •     Will ACM be removed or stripped more than 50 feet above ground level? If so,
              how will it be brought down?

 Be aware that the asbestos NESHAP allows exemptions from removal, stripping, wetting,
 and packaging of ACM in certain situations. A detailed description of these exemptions can
 be found in "Emission Controls" of the ACTIVE REMOVAL INSPECTIONS portion of this
 section.                  --,.,.•

 Disposal Techniques (61.150)

 Although several waste disposal options are delineated by the asbestos NESHAP, most
 owner/operators choose to remove ACM and package it for off-site transport. Inspectors     < '
 should determine the following:      ,

       •      Are leak-tight containers or wrapping available to package removed ACM?
       •      Do these containers or wrappings exhibit the required OSHA warning label?
       •      If the removed ACM is destined for off-site transport, are these containers or
              wrapping materials labeled with the name of the waste generator and the
              location at which the waste was generated?
              Where will the ACWM be deposited and how often will it be removed from the
              worksite?
       •      Has a permit for disposal been obtained? (not required by NESHAP)
       •      Are waste shipment record forms available for use?
       •      Is the owner/operator aware of the NESHAP requirements regarding their use?

Evidence Collection

In addition  to the general information conveyed by the owner/operator, the following evidence
should be collected by an inspector during a pre-removal inspection:

       •       Measurements of area, linear footage or volume of suspect ACM that has
              already been or will be removed during the project (Is 260/160/35 exceeded?)
              Samples of material which were stated in the notification  to be ACM.
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             Collect these samples using techniques described in Section 8 and document
             (using sketches and photographs) their specific locations within the facility. If
             the owner/operator later states that the notification was misrepresentative
             (i.e., that the material removed did not contain asbestos), these samples may
             provide legal evidence to the contrary.        (

             Samples of suspect ACM (friable, nonfriable which has become friable during
    ,  ..:.,.  the demolition or renovation operation, and nonfriable ACM that the inspector
             feels will be disturbed during the demolition or renovation) which were not
             listed by the owner/operator in the notification
             Collect these samples using techniques described in Section 8 and document
             (using sketches and photographs) their specific locations within the facility.

ACTIVE REMOVAL INSPECTIONS

To fully evaluate compliance of the asbestos NESHAP, an inspector must be prepared to
enter the active removal area. The inspector will follow the procedures discussed previously
for pre-inspection observations and interview. The information gathered during pre-
inspection activities will enable the inspector to select appropriate safety equipment and
procedures to follow, as detailed in Section 3.

The inspector' s principal objectives in entering the active asbestos removal area are to:
(1) make first-hand observations of the adequacy,of wetting and maintaining wetness until
ACM is collected for disposal; (2) take samples of any suspect ACM to serve as evidence
that a violation involved asbestos-containing material; and (3) accurately determine whether
the quantity of suspect ACM exceeds the minimum regulated quantity of 260/160/35.

Removal Area Entry Preparation

Inspectors should prepare to enter the active site only after determining the safety
equipment needed. The following steps summarize the procedures detailed in Section 10:

       •     If a three-stage decontamination unit is available, the inspector will enter the
             clean room, remove street clothes (except bathing suit), and suit-up in
              accordance with the procedures in Section 3.  Street clothes should be stored
             in a plastic bag to ensure that no accidental contamination occurs.
              If there is no 3-stage decontamination unit, the inspector will suit-up with
             double disposable coveralls over his or her street clothes following the step-
              by-step procedures listed in Section 3.


Inspection/Sampling Equipment

Only items that can be washed or showered should be taken into the active removal area; all
other items should  be left outside.  Critical inspection and sampling equipment to bring inside
include:                                  . ..                ,
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        •      Pre-labeled sample containers (as described in Section 8);
        •      Waterproof camera - automatic 35mm with flash;
        •      Waterproof clipboard with a plastic sheet on which to write (white paper
              inside a zip-lock bag provides a good background);
        •      Indelible marker for taking notes on the plastic sheet; and
        •      Waterproof flashlight.

 This equipment may be carried in a zip-lock bag taped to the side of the disposable coverall,
 or through which a belt is strapped.

 Applicability [61.145(a)]

 Violations of the asbestos NESHAP cannot be validated unless the inspector has sufficient
 evidence that the site of asbestos removal meets the applicability requirements of
 [61.145(a)] The following specific criteria must be met:

        •      For renovations - if the amount of ACM that will be stripped or removed from
              a facility exceeds 260/160/35, then all notification requirements of 61.145(b)
              and emission control requirements of 61.145(c) apply.
        •      For demolitions - if the amount of ACM in the facility exceeds 260/160/35,
              then all notification requirements of 61.145(b) and emission control
              requirements of 61.145(c) apply.
        •      For demolitions - if the amount of ACM in a facility that will be disturbed is
              less than 260/160/35 (even if no asbestos is present), only the notification
              requirements of 61.145(b) apply.

 The definition of demolitions and renovations differ in that a demolition specifies that a load-
 supporting structural member is wrecked or removed. The term "demolition" also includes
 any related handling operations which could be interpreted as any asbestos removal prior to
 actual demolition, and intentional burning of a facility.

 Notification [61.145(b)]

       •      Verify that a notification exists and, if so, verify that the information conveyed
              verbally during the inspection agrees with the information provided in the
              notification.

       •      Determine if the amount of ACM designated by the owner/operator for
              removal is accurate relative to the amount that the inspector thinks will
              potentially be disturbed during the demolition or renovation.
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Emission Controls [61.145 (c)]

Each owner/operator of a demolition or renovation activity must comply with the provisions
of 61.145 (c).

61.145 (c)(l)—Remove all ACM from a facility being demolished or renovated before any
activity begins that would break up, dislodge, or similarly disturb the material or preclude
access to the material for subsequent removal.

61.145 (c)(2)—When a facility component that contains, is covered with, or is coated with
ACM is being taken out of the facility as a unit or in sections, adequately wet all ACM
exposed during cutting or disjoining operations and carefully lower them to the floor or ground
level. Do not drop, throw, slide or otherwise damage or disturb the ACM.

61.145 (c)(3)—Adequately wet ACM while it is being stripped from in-place facility
components.

61.145 (c)(6)—For all ACM, including material that has been removed or stripped,
adequately wet the material and ensure that it remains wet until collected and contained or
treated in preparation for disposal. Carefully lower the material to the ground and floor
without dropping, throwing, sliding or otherwise damaging or disturbing it. If the ACM has
been removed or stripped more than 50 feet above ground level and it was not removed as
units or in sections, transport it to the ground in leak-tight chutes or containers .

61.145 (c)(8)—Effective 1 year after promulgation of this regulation, no ACM shall be
stripped, removed, or otherwise handled or disturbed at a facility unless at least one on-site
representative, such as a foreman or management-level person or other authorized
representative, trained in the provisions of this regulation and the means of complying with
them is present. Every 2 years this individual must receive refresher training in the
provisions  of this regulation. Evidence that the required training has been completed must
be posted and made available for inspection by the Administrator at the demolition or
renovation site.

61.145 (c)(9)—When a facility is ordered to be demolished, keep the portion of it containing
ACM adequately wet during the wrecking operation.

61.145 (c)(10)—If the facility is demolished by intentional burning, remove all ACM,
including Categories I and n nonfriable ACM before burning.

61.145 (c)(ll)—If Category I nonfriable ACM is sanded, ground, sawed or abraded, the
owner or operator, discharge no visible emissions to the outside air during such operations;
and adequately wet the material or use a local exhaust and ventilation and collection system
designed and operated to capture the paniculate asbestos material generated during such an
operation.
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Emission Control Exemptions

If the owner/operator is not following standard work practices relating to removal, strippping,
wetting and packaging of ACM, the inspector must carefully evaluate whether activities seen
are justified by the following exemptions in the asbestos NESHAP:

Removal of ACM is not required before demolition if it:

       •      61.145 (a)(3) - is located in a building which has been ordered by a
              government authority to be demolished.  Wetting of the portion of the facility
              that contains ACM is required during the wrecking operation [61.145 (c)(9)]
              and ACWM must be handled in accordance with waste disposal requirements
              (61.150).
       •      61.145 (c)(l)(i) - is Category I nonfriable ACM in good condition.
       •      61.145 (c)(l)(ii) - is  on a facility component encased in concrete or other
              similarly hard material and is adequately wet whenever exposed during
              demolition. (Doubled concrete-block walls with risers inside do not meet the
              "encased in concrete" definition.)
       •      61.145 (c)(l)(iii) - was not discovered until after demolition began and cannot
              be safely removed. The ACM must be adequately wet whenever exposed
              during demolition.
       •      61.145 (c)(l)(iv) - is Category II nonfriable ACM and the probability is low
              that the material will become friable during demolition.

Stripping of ACM from facility components is not required:

       •      61.145 (c)(4) - if the components have been taken out of the facility as a unit
              or in sections contained in leak-tight wrapping.
       •      61.145 (c)(5) - if the ACM attached to certain large facility components
              (excluding beams) which are handled without disturbing the ACM, are
              appropriately labeled and wrapped leak-tight.

Wetting is not required in renovation operation's if

       •      61.145 (3)(i) - it causes unavoidable equipment damage or presents a safety
              hazard. Written approval from the Administrator must be obtained (and kept
              at the worksite) and either a local exhaust ventilation and collection system,
              glove-bag system or  leak-tight wrapping prior to dismantlement must be
            •  employed.

       •      61.145 (3)(ii) - the Administrator has given written approval to an alternate
              equivalent method. This approval must be kept onsite.
       •      61.145 (c)(7) - the temperature at the point of wetting is below freezing.
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             Facility components must be removed as units or in sections to the maximum
             extent possible.

Packaging of ACWM prior to disposal is not required if the ACWM results from a
government-ordered facility demolition (61.150). Wetting requirements still apply.

Determination of Adequately Wet

Adequately wet, as defined in 61.141 means to:

         "sufficiently  mix  or penetrate  with  liquid to  prevent  the  release of
         particulates.   If visible emissions are observed coming  from asbestos-
         containing  material,  then  that  material  has not  been  adequately
         wetted.   However, the absence of visible emissions is not sufficient
         evidence of being adequately wet."

The inspector is responsible for the overall determination of "adequately wet" relative to the
above listed citations from the asbestos NESHAP. It is important for an inspector to
document whether or not material has been adequately wetted and how this determination
was made. The following questions and procedures will help document compliance with this
provision of the asbestos NESHAP:

       •      Is there a water supply in place?
       •      Is water or a wetting agent observed being sprayed onto the suspect ACM or
              ACWM both during stripping or removal and afterwards while the material
              awaits proper disposal? If yes, carefully note the method of application used
              (e.g., misting, fogging, spraying of surface area only or drenching to penetrate
              the ACM throughout).
       •      Does the equipment used to apply the wetting agent appear to be operating
              properly?
              If an aqueous solution is not being used, determine why it is not and document
              the reason. Possible (although not necessarily valid) reasons include:
                   prior permission obtained from the Administrator (safety hazard,
                   potential equipment damage);
                   no water source at the facility;
                   temperature at the point of wetting below  32 degrees F;
                   portable water supply ran out and contractor continued to work; or
                   contractor prepared the area earlier, etc.

              Examine a stripped or removed piece of suspect ACWM or ACM which wets
              readily. Does it appear to be wetted throughout? If it does not, adequately
              wet the sample. Describe and photograph how  the physical characteristics of
              the material change upon wetting (e.g., color, weight, texture, etc.). Take
              samples, as necessary, to document the presence of asbestos in the suspect
              material.
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        •      When examining materials that do not readily absorb a wetting agent (e.g.,
               premolded thermal system insulation, ceiling tiles, floor tiles) inspectors
               should note whether all exposed surfaces of these materials have been wetted
               as required.

        »      Is there visible dust (airborne or settled), or dry suspect AGWM debris in the
               immediate vicinity of the operation? Inspectors should collect samples of such
               materials for analysis of their possible asbestos content,
 Inspection of Waste Containers

 The presence of a regulatory inspector may often cause the owner/operator to quickly and
 vastly improve wetting procedures. However, inspectors can determine typical wetting
 procedures by evaluating the contents of waste containers found both inside containment and
 in other waste storage areas. The following protocol should be followed:

        •      Randomly select bags or other containers for inspection.
        •      Lift the bag or container to assess its overall weight. A bag of dry ACWM
               can generally be lifted easily with one hand whereas a bag filled with well-
               wetted material is substantially heavier.

 If waste material is contained in a transparent bag:

        •       Visually inspect the contents of the unopened bag for evidence of moisture
               (e.g., water droplets, water in the bottom of the bag, change in cdlor of the
               material due to the presence of water, etc.).
        •       Without opening the bag, squeeze chunks of debris to ascertain whether
               moisture droplets are emitted.
               Note:  Squeezing cannot be used to determine adequate wetting of materials
               (such as ceiling tiles, floor tiles, or premolded TSI, etc.) which do not readily
               absorb a wetting agent. For these materials, determine whether exposed
               surfaces have been adequately wetted, document information and take
               samples as needed.

        •      If the material appears dry or not penetrated with water or a wetting agent,
              open the bag using steps described below and collect a bulk sample (using the
              procedures specified in Section 8) of each type of suspect material in the bag.
              Note, and document in the log book, variations in size, patterns, colors, and
              textures of adequately and inadequately wetted materials seen.

 If the waste material is contained in an opaque bag or other container, or if the material in
 a transparent bag appears to be inadequately wetted:

        •      Carefully open the bag or other container (in the containment area, if
              possible). If there is no containment area, a glove bag may be used to enclose
              the container prior to opening it. This will minimize the risk of fiber release.
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       •      Examine the contents of the container as noted above for evidence of moisture,
             document findings, take samples as needed, and carefully reseal the opened
             container.
       •      If inadequately wetted ACM stored outside is discovered upon arrival at a
             worksite, don protective gear and take samples before continuing the on-site
             inspection.

Evidence Collection

The following specific evidence should be collected by an inspector during an active removal
inspection:

       •      Measurements of area, linear footage or volume of suspect ACM to accurately
             document that 260/160/35 is exceeded. (Document technique of
             measurement - tape measure, premeasured pace, etc.)
       *      Samples of material which were stated in the notification to be ACM.

Collect these samples using techniques described in Section 8 and document (using sketches
and photographs) their specific locations within the facility.                           >

If the owner/operator later states that the notification was misrepresentative (i.e., that the
material removed did not contain asbestos), these samples may provide legal evidence to
the contrary.

       •      Samples of suspect ACM (collected using techniques described in Section 8)
             to document violations of the work practice standards.  Document specific
           ,  sample location using photographs and sketches.
       •      Samples of suspect ACM (friable, nonfriable which has become friable during
             the demolition or renovation operation, and nonfriable ACM that the inspector
             feels will be disturbed during the demolition or renovation) which were not
             listed by the owner/operator in the notification.

Collect these samples using techniques described in Section 8 and document (using sketches
and photographs) their specific locations within the facility.

Disposal Techniques (61.150)

Although several waste disposal options are delineated by the asbestos NESHAP, most
owner/operators choose to remove ACM and package it for off-site transport. During an
active removal inspection inspectors should determine whether:

       •      There are visible emissions to the outside air during the collection, packaging,
             or on-site transport of any ACWM (The inspector must determine the source
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              of the visible emission and sample the source to verify that the emission
              contains asbestos material. It is not necessary to be a, certified visible
              emission observer to legally document whether a visible emission exists. The
              presence of asbestos in such dust constitutes a violation of 61.150.);
        •      ACWM is being adequately wetted;
        •      ACWM generated during ordered demolitions or demolitions where ACM is
              not required to be removed is kept adequately wet at all times after demolition
              and kept wet during handling and loading for transport to a disposal site.
              (Sealing in leak-tight containers or wrapping is not required - may be
              transported and disposed of in bulk)
        •      Leak-tight containers or wrapping are being used to package removed ACM;
        •      Containers or wrappings exhibit the required OSHA warning label;
        •      Containerized ACM destined for off-site transport is labeled with the name of
              the waste generator and the location at which the waste was generated;
        •      Vehicles used to transport ACWM are appropriately marked during loading
              and unloading; and

        •      The ACWM will be deposited at an appropriate waste disposal site as soon
              as is practical (excluding removed or stripped Category I ACWM in good
              condition). Inspectors should verify ACWM destination information reported
              in the notification. This information can provide the inspector with an
              opportunity to visit a disposal site and conduct an inspection while deposition
              of ACWM is taking place.

Waste Shipment Records [61.150 (d)]

Asbestos inspectors should examine whatever on-site records exist to ensure that the
owner/operator is complying with the waste shipment recordkeeping requirements of the
asbestos NESHAP.

TSCA Compliance

During the inspection, the inspector can also check for any evidence of apparent violations of
the AHERA and WPR regulations. The appropriate asbestos program personnel should be
contacted and informed about the possible violations noted.  AHERA regulations apply to
asbestos abatement work conducted at schools. WPR regulations apply to State and local
government employees who take part in asbestos abatement work and are not covered by
the OSHA asbestos standard. Abbreviated checklists for the AHERA and WPR regulations
are included in Appendix  C.

Exiting the Removal Area

The inspector will leave the active removal area when satisfied that the operation complies
with the requirements of the asbestos NESHAP or has collected sufficient evidence
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 (observations, samples, photographs, owner/operator admissions) if potential violations
 exist.  It is essential that the inspector properly decontaminate himself/herself and any items
 taken into the active removal area that will not be disposed of as asbestos contaminated
 waste. The following procedures summarize the detailed decontamination steps listed in
 Section 3.

       •      If a 3-stage decontamination unit is available, enter the dirty room, remove
              disposable clothes (keeping the respirator on), move into the shower area,
              quickly rinse head region and remove respirator. Dispose of filter cartridges.
              Finish showering and dry off using disposable towels. Move to clean room to
              dress in street clothes (see Section 3 for more specific decontamination
              procedures).

       •      If there is no three-stage decontamination unit, spray with water and then
              remove the outer layer of the doubled disposable coveralls just prior to
              exiting. Spray and remove the second layer just after exiting. Wet wipes can
              be used to clean potential asbestos fibers from the respirator and face area
              before removing the respirator and disposing of cartridges (see Section 3 for
              more specific decontamination procedures).

Inspectors should record observations and fill out chain-of-custody forms immediately upon
departing from the contaminated area.

POST-REMOVAL INSPECTION

Inspection of a facility after asbestos removal has been completed is the least preferred
option; any improper removal would already have released fibers to the ambient air.
However, an inspector arriving onsite after removal is complete can still gather useful
information.

Decisions regarding protective clothing and respiratory protection will be left to the
discretion of the inspector.  As a general rule, if an inspector has any doubt concerning
whether the area is cleared for reoccupancy, he/she should treat the inspection as an active
removal situation and follow the suit-up procedures in Section 3.

The following inspection procedures apply to most post-removal inspections relative to
enforceable paragraphs of the asbestos NESHAP.

Applicability [61.145(a)]

             Interview the owner/operator to ascertain where ACM was removed from the
             facility and establish (measure or pace off) that the minimum quantity of
             260/160/35 was exceeded.
             Verify that the site meets the definition  of a facility under 61.141 "any
             institutional, commercial or industrial structure, installation, or building
             (excluding apartment buildings having no more than four dwelling units)."
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             Determine whether the activity was classified as a demolition or renovation
             based on the definitions under 61.141.
Notification [61.145(b)]
             Verify that a notification was submitted and that the information conveyed
             verbally during the inspection agrees with the information provided in the
             notification.
Emission Controls [61.145 (c)]

              Verify that all ACM [excluding ACM described 61.145 (c)(l)(i-iv)] has been
              removed from a facility scheduled for complete demolition. Take samples as
              needed.
              Verify that all ACM, including Category I and Category II nonfriable ACM,
              has been removed from a facility scheduled to be demolished by intentional
              burning. Take samples as needed.
       •      Visually inspect all areas from which ACM is said to have been removed to
              verify that it has been done. No dust or debris should be left behind.  Take
              samples as needed.
       •      Visually inspect other areas of the facility that will be disturbed during the
              impending demolition or renovation to determine if any other suspect ACM
              exists. Determine if 260/160/35 is exceeded and take samples as necessary,
              in accordance with procedures described in Section 8.


Waste Disposal (61.150)

If waste is still stored onsite at the time of a post-removal inspection, the inspector should
inspect the containers to determine compliance with the 61.150. Use safety equipment and
procedures detailed in Section 3 for active removal situations.

       •      Inspect for leaking or ripped bags, or other evidence of asbestos contamination.
       •      Lift bags or containers to assess their overall weight. A bag of dry ACWM
              can generally be lifted easily with one hand whereas a bag filled with well-
              wetted material is substantially heavier.

If waste material is contained in a transparent bag:

       •      Visually inspect the contents of the unopened bag for evidence of moisture
              (e.g., water droplets, water in the bottom of the bag, change in color of the
              material due to the presence of water, etc.).
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       •      Without opening the bag, squeeze chunks of debris to ascertain whether
              moisture droplets are emitted.
              Note:  Squeezing cannot be used to determine adequate wetting of materials
              (such as ceiling tiles, floor tiles, or premolded TSI, etc.) which do not readily
              absorb a wetting agent. For these materials, determine whether exposed
              surfaces have been adequately wetted, document information and take
              samples as needed.

       •      If the material appears dry or not penetrated with water or a wetting agent,
              open the bag using steps described below and collect a bulk sample (using the
              procedures specified in Section 8) of each type of suspect material in the bag.
              Note, and document in the log book, variations is size, patterns, colors, and
              textures of adequately and inadequately wetted materials seen.

If the waste material is contained in an opaque bag or other container, or if the material in
a transparent bag appears to be inadequately wetted:

       •      Carefully open the bag or other container (in the containment area,  if
              possible). If there is no containment area, a glove bag may be used to enclose
              the container prior to opening it. This will minimize the risk of fiber release.
       •      Examine the contents of the container (as noted above) for evidence of
              moisture, document findings, take samples as needed, and carefully reseal the
              opened container.

Evidence Collection

In addition to the general information conveyed by the owner/operator, the following specific
evidence should be collected by an inspector during a post-removal inspection:
       •      Samples of any suspect ACM left behind as dust, debris or residue;
       •      Measurements of area, length, or volume  where ACM was removed, in order
              to establish that the facility met the applicability requirements; and
       •      Samples of any dry ACM from the storage area if still available.  Sketches and
              photographs are advisable to illustrate specific locations of samples.

POST-INSPECTION INTERVIEW

When the inspection is complete, the asbestos NESHAP inspector should conduct  a quick,
concise wrap-up interview to obtain any additional information necessary to complete the
checklist and to convey to the owner/operator the findings  of the inspection. However,
conclusive compliance determinations cannot be made by the inspector in the field. In
situations where potential violations are identified, it is important to document any response
actions of the owner/operator observed or verbally communicated. This information becomes
strong evidence in situations where a follow-up inspection is conducted and similar
violations are identified.
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 If the inspection is of a school and subject to the AHERA regulations, the inspector should
 ask if the workers are accredited and check the accreditation certificate of the supervisory
 personnel onsite. If the workers are covered by the WPR, the inspector can ask if the
 environmental monitoring records have been maintained and if the workers' medical records
 have been maintained.  Any apparent violations of AHERA or the WPR should be referred to
 the appropriate Federal or state agency.

 EXIT OBSERVATIONS

 As the inspector departs a site^ he/she should resurvey the site and complete any site
 drawings not completed prior to or during the inspection. If possible, the inspector should
 observe the waste storage area and other areas to determine if any significant changes
 occurred since the inspection began.  Any changes should be noted as they help to assess ,
 whether the inspection observations are representative of operations when a regulatory
 inspector is not present. Finally, chain-of-custody forms for any samples collected should be
 completed.                                                •                    .     .
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                                     SECTION 6
                               POST-INSPECTION
No matter how blatant a violation or how thorough an inspection, a case cannot be supported
Without proper records and documentation. It is imperative that each delegated program
office set up and implement a system whereby supporting documentation is properly taken,
controlled, and maintained. Generated reports, checklists and sample analysis results must
be clear and concise and accurately support the dbservations of the inspector. Finally, all
records must be organized, properly maintained, and readily available for future access. The
purpose of this section is to outline inspection followup procedures and general guidance to
aid in the process of document control, report preparation, and record maintenance and
storage.

INSPECTION FOLLOWUP

Once an inspection is completed, a decision will be made regarding how many and how
quickly samples should be analyzed.  When there are serious violations it may be necessary
to have analysis completed within a day or less. Arrangements should be made ahead of
time with an in-house laboratory or a commercial laboratory to facilitate such a request.
Those samples which will provide the greatest proof of asbestos NESHAP violations should
be analyzed; other samples taken need not be.  However, samples should not be destroyed;
they should be stored in a  locked facility pending future litigation.

When violations are suspected (Remember, a violation cannot be confirmed until samples
are analyzed.), the inspector should brief his/her supervisor and/or attorney to initiate the
decision-making process concerning the (1) need for reinspection; (2) need for information
request under Section 114 of the CAA; (3) enforcement options available, etc.

Another facility inspection followup item to be considered is a landfill inspection. Because
the asbestos NESHAP regulates friable ACM from "cradle to grave", an inspector may
consider inspecting a landfill to determine whether the waste from a facility was properly
disposed of as indicated in the notification. Inspection of landfills may also be conducted
independently of tracking  waste from a specific facility.  This will be discussed in Section 7.

DOCUMENTATION

Checklists and reports generated by an inspector may be the basis of affidavits for civil or
criminal enforcement actions. They must be precise and legible. NESHAP inspections
                                                                                   6-1

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 ultimately involve the actions of several people: one or more inspectors, laboratory
 personnel, administrative, legal and clerical staff. Information must be collected and
 maintained within a system that allows for processing and expedient access.  Additionally,
 this system must protect all records or potential evidence that may be required for
 enforcement actions. It is imperative that a comprehensive document control system be
 implemented during all phases of an investigation.

 Document Control

 The purpose of document control is to make certain that all project documents issued or
 generated during a NESHAP investigation are accounted for when the project is complete. A
 system which accounts for all investigation documents should include serialized document
 numbering, document inventory procedures, and an evidentiary filing system. Examples of
 accountable documents include:

       •      inspection checklists;
       •    . field logbooks;              •   .  .      ..
       •   •  sample data sheets;
       •      sample tags;
       •      chain-of-custody records and seals;
       •      laboratory notebook and reports;                    ,
       •      internal memoranda;
       •      phone memoranda;
       •      external written communications;
       ••'•     photographs, drawings, maps; and
       •      quality assurance plans;.

Under ideal circumstances, each document is given a serialized number which is listed in a
Document Inventory Logbook.

Corrections to Documentation

All documents generated during the course of an inspection are considered part of the
permanent evidentiary file and should not be destroyed or thrown away> even if they become
illegible or if inaccuracies are discovered. This is particularly important if serialized
documents are used, for any gaps in the numbering system will be noted by legal staff.
Errors in documents should be noted. If a document requires replacement, it should be noted
or corrections made to the original document. Corrections may be made by simply crossing a
line through the error, entering the correct information, and initialing and dating it.
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 If documents are lost or missing (a sample tag lost in shipment, or a chain-of-custody record
 improperly prepared), a written statement should be prepared detailing the circumstances.
"The statement should include all pertinent available information that may be used to support
 an observation or sample.  This statement becomes part of the permanent case file.

 RECORDS MAINTENANCE

 Records need to be properly filed and maintained to allow for quick and easy access of all
 case documents. Records also need to be retained under storage conditions which minimize
 deterioration or loss of data files. With the current widespread use of micro-and personal
 computers, data management capabilities have improved handling, tracking, and manipulation
 of large quantities of information.  However, these systems do not replace physical evidence
 such as tags, forms, and checklists. They do alleviate tedious record searching and sorting
 tasks and can provide quick and easy retrieval of information and cross-referencing capability.

 Regardless of whether computer-based data management systems or manual procedures are
 used, responsible individuals within a program office must be able to access and trace the
 destination of project files.  The inspector must be familiar with and use all filing procedures.
 Files should be signed out in such a manner as to indicate to others that the file is in the
 possession of an inspector.  When returning the file to storage, the inspector should take
 care to return it to its proper place for future easy access.

 INSPECTION REPORTS

 Inspection reports and checklists clearly and concisely document observations and physical
 evidence from the inspection. A comprehensive and properly completed checklist can serve
 as the inspection report. A recommended inspection checklist that serves this purpose is
 included as Appendix C. An inspector may supplement the checklist with additional
 information such as:

       •      Inspector observations;
       •      Owner/operator admissions;
       •      Description of evidence collected (including techniques used); and
       •      Owner/operator response actions.

 In cases where violations are observed an inspector should supplement the inspection
 checklist with an inspection report containing the above information. It may take several
 years before a lawsuit is filed so a detailed narrative of the inspection will prove beneficial in
 refreshing the inspector's memory and will provide strong evidence for the case.
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                                     SECTION 7

                            LANDFILL INSPECTIONS
The asbestos NESHAP provides emission control and work practice requirements from the
time the asbestos is disturbed (potentially releasing airborne fibers) until it is interred in a
landfill or converted into asbestos-free materials.  However, since no conversion operations
are currently licensed, demolition/renovation ACWM typically is transported to landfills for
disposal. Regulatory agents should be prepared to conduct inspections of such sites and
should follow the personal protective equipment and bulk sampling procedure
recommendations found in the EHSD Health and Safety Guidelines for EPA Asbestos
Inspectors and in Sections 3 and 8 of this manual.

It is important to recognize that both the owner or operator of a demolition or renovation
operation and the owner or operator of the active waste disposal site where ACWM is
brought are required to meet waste disposal provisions of the asbestos NESHAP.

Regulatory agents conducting inspections at demolition or renovation sites will determine
generator compliance with the Standard for waste disposal for..., demolition, renovation,
...operations, 61.150. These inspection activities have already been described in Section 5.

This section details the procedures an inspector should use to ascertain whether a landfill
owner or operator is in compliance with 61.154, Standard for active waste disposal sites. A
sample inspection form for landfills is included in Appendix C.

REVIEW PERMIT CONDITIONS

Upon entering the site, contact the site operator to determine whether the landfill has a
State-required permit to operate. If it does, check the expiration date of the permit and
record pertinent information on the inspection form. (Although permits are not specifically
required under NESHAP, most States have a permitting process for landfills.)

Verify that the  landfill meets one of the following requirements of 61.154:

       •      No visible emissions are produced. Warning signs must be posted and fencing
             is required unless a natural barrier adequately deters access by the public.
             A 6-inch cover of compacted, non-asbestos material is provided within 24
             hours of the time the waste is deposited. No sign posting or fencing is
             required.

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       •      An effective resinous or petroleum-based (other than waste oil) dust
              suppressant is provided within 24 hours of the time the waste was deposited.
              Warning signs must be posted and fencing is required unless a natural barrier
              adequately deters access by the public.
       •      An alternative method previously approved by the Administrator is used.
              Warning signs must be posted and fencing is required unless a natural barrier
              adequately deters access by the public.

EVALUATE WASTE SHIPMENT RECORDS

For all ACWM received, the owner or operator of the active waste disposal site must
comply with the following waste shipment recordkeeping provisions of 61. 154 (e) of the
asbestos NESHAP:

       •      Record and maintain the following information on forms similar to that noted in
              the regulation [61.154 (e)(l)]:


                   waste generator's name, address and telephone number;
                   transporter's name, address and telephone number;
                   quantity of ACWM received (cubic yards or meters);
                   presence of improperly enclosed or uncovered waste, or any ACWM not
                   sealed in leak-tight containers; and
                   date of receipt

       •      Send a copy of the signed waste shipment record to the waste generator as
              soon  as possible but no longer than 30 days after receipt of the waste [61. 154
       •      Attempt to reconcile differences in the amounts of ACWM received and that
             recorded on the waste manifest form brought by the transporter. If the
             discrepancy is not resolved within 15 days after receiving the waste,
             immediately submit a discrepancy report which details the discrepancy and
             attempts made to reconcile it to the governmental agency responsible for
             administering the asbestos NESHAP program for the waste generator
             (identified in the waste shipment record), and, if different, the governmental
             agency responsible for administering the asbestos NESHAP program for the
             disposal site [61.154 (e)(3)].
       •      Retain a copy of all records and reports required by this paragraph for at least
             2 years [61.154 (e)(4)].


OTHER ACTIVE WASTE DISPOSAL SITE REQUIREMENTS

Landfill owners or operators must also comply with the following provisions of 61 . 154:

       •      Maintain, until closure, a map or diagram which contains the location, depth,
             area, and quantity of ACWM interred in the waste disposal site.

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       •      Obtain written approval from the Administrator prior to conducting any activity
             that disturbs deposited ACWM.
       •      Furnish, upon request, and make available during normal business hours for
             inspection by the Administrator, all records required in 61.154.

SURVEILLANCE

In addition to determining landfill owner/operator compliance with the requirements of 61.154,
Standard for active waste disposal sites, while at the site inspectors may note a number of
other potential violations of the asbestos NESHAP.  By asking the right questions and
documenting appropriate information (photographs, samples, etc.) inspectors may be able to
identify non-notifiers or determine other generator non-compliance with certain provisions of
the NESHAP regulation.

Off-loading of Suspect ACWM Unaccompanied by a Waste Manifest

Inspectors should question the origin and determine the amount of any suspect ACWM
material being offloaded which is not accompanied by a waste manifest. Document all
information obtained from the transporter and landfill owner or operator and take photographs
and samples as needed.

Attempt to determine the following:

       •      Has the suspect ACWM come from one or multiple sites? (For the NESHAP
             regulation to be applicable, ACWM must be generated at a site, which meets
             the definition of a "facility" and meets the 260/160/35 quantity requirements.)
       •      Is the vehicle properly marked with an asbestos hazard warning sign?
       •.     Is the suspect ACWM in properly labeled leak-tight containers?
       •      Is the suspect ACWM adequately wet?
       •      If the suspect ACWM is not wrapped or contained in leak-tight containers,
             has it come from a facility ordered demolished by a governmental agency?

Landfill Inspection

An inspector may notice improperly containerized, inadequately wetted or unlabeled suspect
ACWM at the landfill. If a regulated amount of ACWM (260/160/35) is present, an inspector
should attempt to determine the material's origin.  Inspectors should note that the asbestos
NESHAP is applicable only if the materials were generated at a "facility", as defined in the
NESHAP asbestos standard. For example, if the ACWM seen had been removed from a
residential structure involving four or fewer dwelling units, the asbestos NESHAP would not
apply.  However, the disposal site may be in violation of local or state asbestos waste
disposal regulations, so the inspector should notify the appropriate authority. Inspectors
should question the landfill operator, examine records, take photographs and samples as
needed and document all information obtained.
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                                    SECTION 8
               ASBESTOS BULK SAMPLING AND ANALYSIS
The purpose of bulk sampling is to determine and document if friable material contains
regulated amounts of asbestos. Samples should be collected whenever a violation is
suspected or an enforcement action is anticipated for the results obtained serve as critical
evidence that the material in question contains asbestos and is subject to regulation.

PROTECTIVE EQUIPMENT

The EHSD Health and Safety Guidelines for EPA Asbestos Inspectors specifies personal
protective equipment to be used by EPA inspectors required to collect bulk samples under
the Asbestos In Schools rule and the NESHAP. These recommendations are summarized
below. For further details, refer to earlier sections regarding Inspector Safety.

             Protective Clothing—Inspection personnel should wear the following
             protective clothing when collecting bulk samples in active abatement
             environments.

                  bathing suit;
                  disposable, full-body, hooded coverall (e.g., Tyvek® or equivalent);
                  disposable inner and outer booties;
                  disposable gloves; and
                  hard hat, safety glasses, safety shoes, and ear protection, as needed.

Inspectors collecting bulk samples in non-contaminated areas should use their professional
judgment in determining whether or not to wear protective clothing. Inspectors may choose
not to wear protective clothing when samples can be taken without any significant chance of
releasing fibers or may decide to wear disposable coveralls and shoe coverings over their
street clothes.

       •     Respiratory Protection—At a minimum, inspectors collecting bulk samples
             should wear full-face, air-purifying respirators with HEP A filter cartridges.
             These include NIOSH-approved, tight-fitting PAPRs equipped with HEPA
             filters.  Cartridges must be NIOSH-approved for asbestos environments.
             More stringent protection should be used if necessary.
       •     Disposable Towels—For use after showering.
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  SAMPLING EQUIPMENT

  The following items are recommended for use by asbestos NESHAP inspectors:


              Lightweight Carrying Case—for storage and transport of sampling materials.
              Sample Containers—any dry, scalable and clean container such as a 35mm
              film canister, plastic vial, or whirlpak bag.
        •     Water Spray Bottle—for wetting a surface prior to sampling to prevent
              generation of dust (may use a surfactant).
              Adhesive (Duct) Tape—to temporarily repair a sampled area, such as pipe
              wrap.

              Postal Tape—to seal sample containers; can be written on to identify sample.
              Tools—metal tweezers, pen knife, coring device, scissors, etc.
        •      Wet Wipes—to clean tools between samples as well as to decontaminate
              equipment, sample containers, etc., when leaving the sampling area.
        •      Plastic Bags—to store contaminated waste generated during the sampling
              exercise. The bags should be properly sealed and disposed of as ACM. Zip-
              lock bags are useful for packaging sample containers for delivery or shipment
              to the laboratory.
        •      Documentation Material—notebook or clipboard, inspection checklist, sample
              labels, chain-of-custody forms, waterproof pens, plastic sheets (overhead
              transparencies).
        •      Spray Paint—for identification of sample sites on photographs.

 The above items are considered essential and should be included in every sampling kit.
 Other items such as specialty corers, hammer and chisel, and vinyl tile knives may be helpful
 during the inspection. Appendix C provides a comprehensive inspection equipment checklist.

 COLLECTION TECHNIQUES

 The asbestos NESHAP regulation does not provide any specific recommendations for
 collecting bulk samples. Procedural guidelines for sample collection can be found in the
 EHSD Health and Safety Guidelines for EPA Asbestos Inspectors and in the TSCA
 publications entitled Guidance for Controlling Asbestos-Containing Materials in Buildings
 (purple book) and Asbestos in Buildings:  Simplified Sampling Scheme for Friable Surfacing
 Material (pink book). The TSCA guidelines are geared towards environments which are
 neither contaminated nor disturbed, such as those encountered during asbestos school
 inspections, pre-abatement inspections, and pre-demolition inspections. Asbestos
 NESHAP inspectors will inspect both non-abatement situations and abatement inspections.
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Non-Abatement Inspections

Non-abatement inspections are conducted less frequently than abatement inspections,
Extensive guidance is available through the TSCA Asbestos-in-Schools program.  The most
direct sources of information on non-abatement inspections are the two references cited
above.

Abatement Inspections

The samples collected during active abatement inspections usually include materials which
have been stripped, removed or still in place. The environments in which these samples are
collected are usually not conducive to formal random sampling approaches such as those
used during pre-abatement and TSCA inspections. The representativeness of bulk samples
is usually based on the judgment of the inspector. Because the goal of collecting bulk
samples is to determine and document whether materials associated with a violation contain
greater than 1 percent asbestos, this subjective approach is warranted and appropriate. This
approach does not exempt the inspector from following some general rules when collecting
samples, including:                                             .          ,

       •      Identify homogeneous thermal system insulation, surfacing and miscellaneous
              materials.
       •      Wear proper safety equipment, including disposable coveralls, overshoe boots,
              gloves and a properly selected respirator. A hard hat, safety shoes, protective
              glasses and ear protection may also be necessary.
       •      Collect samples of materials where a violation or suspected violation is
              observed.
              Understand that different types of friable ACM may be removed at the same
              abatement project.  Collect representative samples of each different type of
              suspect material associated with a violation or suspected violation.
       •      Collect multiple samples if possible.  A minimum of three samples should be
              taken from each homogeneous area of suspect material encountered.
       •      Collect a complete core or cross-section of the material.
       •      Spray the area to be sampled with a water mist or encapsulant mist to
              minimize fiber release. This is done primarily to reduce inspector exposure,
              (If the material is dry and the inspector believes there is a wetting violation,
              the field notes should reflect the dry sample and the inspector should note that
              he/she wet the sample prior to collecting it).
              Use sampling equipment listed in Appendix C checklist.
              After sampling is completed, wipe the outside of the container with a wet wipe
              or damp cloth. Wipe tools between sampling points.
        •      Record a unique I.D. number on a label and affix to the container. Tape the
              label to prevent it from peeling off and tape the lid shut.
                                                                                     8-3

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        •      Never reuse sample containers.
        •      Photograph the sampling location(s). If necessary, take a second photograph
               with a reference point. The inspector can also use bright spray paint to
               indicate the sampling point.             .      ,
        •      Make a drawing of the inspection site, noting where samples and photographs
               were taken. Indicate angles of photographs and written descriptions of
               materials sampled.

        •      Complete all documentation including checklist entries and chain-of-rcustody
               form. A sample chain-of-custody form is shown in Figure  8-1. Samples must
               be secured if more than one inspection is planned.

        •      Dispose of all sampling waste as asbestos-containing material.
        •      Not all samples must be analyzed. It is advisable to collect extra samples and
               only analyze enough to satisfy the evidence requirements.  Samples may be
               analyzed at a later time if necessary.

 BULK SAMPLE ANALYSIS

 Bulk sample analysis determines the quantity (percent by area/volume), as well as the
 specific type of asbestos for each sampled area. The NESHAP standard contains no specific
 method for the analysis of bulk samples for asbestos.  However, in no case should asbestos
 field test kits be used to confirm the presence or absence of asbestos. The  solutions
 deteriorate with age and may indicate false negative results.

 EPA's policy has been to adopt the procedure published in 40 CFR Part 763 Appendix A to
 Subpart F entitled Interim Method for the Determination of Asbestos in Bulk Insulation
 Samples. In this document polarized light microscope (PLM) is recommended for the
 analysis of bulk samples.  Based on optical crystallographic properties, the PLM method
 must be performed by a microscopist with formal training in optical mineralogy.  PLM gives a
 qualitative differentiation between asbestos and non-asbestos fibers along with a
 quantitative estimate of percent asbestos by area/volume.

 Results from PLM analysis are interpreted as follows:

       •      If one or more samples from a homogeneous suspect ACM  contains greater
              than 1 percent asbestos, the entire material is considered to contain asbestos.
       •      If a  doubt exists, or if further information is needed, samples should be
              reanalyzed or additional samples collected.
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QUALITY ASSURANCE

Sample I.D. Numbers

Assign a unique sample I.D. number to each sample. A non-systematic (random) numbering
scheme is recommended, for this helps eliminate a microscopist's potential bias.. For
example, if a numbering system indicates that seven samples are from the same room, a
microscopist may not be objective about each individual sample.

Chain-of-Custody Forms

In order to ensure that the samples are properly identified and tracked from the point of
sample collection through receipt by the analytical laboratory, EPA requires that a chain-of-
custody (COC) form be completed and accompany the samples. Figure 17-1 is a sample
chain-of-custody form. It contains essential items such as identification number, date, name
of sampler and signature of recipient.  Some laboratories request that COC forms they supply
be used. These forms must be completed in the field and accompany the samples when they
leave possession of the inspector.  Inspectors should fill in a new COC form if mistakes have
been made  (i.e., incorrect information transferred from sample containers to GOC form).

Quality Control (QC) Samples

Collection of side-by-side duplicates are recommended at the rate of 1 QC sample/building  :
or 1 QC sample/20 samples, whichever is larger.  The laboratory should analyze duplicates -
without knowing which are the QC samples.  The results of duplicates are compared to
determine sampling and analytical precision.  For additional QC, split side-by-side
duplicates with a second laboratory to confirm the results of the first analyses. Any
disagreements generated by the QC effort must be investigated; samples should be
reanalyzed, or additional samples collected.

Accredited Laboratories

To diminish the likelihood of challenges to the accuracy of laboratory results during litigation,
it is suggested that only accredited laboratories be used for  the analysis of bulk samples (per
AHERA 40 CFR Part 763, Subpart E). A listing of accredited laboratories published by EPA
twice a year is available through the EPA Regional Asbestos Coordinator or the TSCA
Hotline (202)-554-1404.
                                                                                   8-5

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  u.
                                                                                                                       oo

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                APPENDIX A

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR
                POLLUTANTS

  (SUBPART M - NATIONAL EMISSION STANDARD FOR
                ASBESTOS)
                    A-l

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Tuesday
November 20, 1990
Part III



Environmental

Protection  Agency

40 CFR Part 61
National Emission Standards for
Hazardous Air Pollutants; Asbestos
NESHAP Revision; Final Rule

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  48406
Federal  Register / Vol. 55.  No. 224  /  Tuesday. [ November20^1990 /Rules and Regulations
   ENVIRONMENTAL PROTECTION
   AGENCY

   40 CFR Part 61

   IAD-FRL-3814-7]
   RIN 2060-AC57

   National Emission Standards for
   Hazardous Air Pollutants; Asbestos
   NESHAP Revision

   AGENCY: Environmental Protection
   Agency.
  ACTION: Final rule.    	

  SUMMARY: This Federal Register notice
  promulgates rules under section 112 of
  the Clean Air Act (CAA) for asbestos
  emissions and is based on the
  Administrator's determination that
  asbestos presents a significant risk to
  human health as a result of air
  emissions from one or more source
  categories and is therefore a hazardous
  air pollutant (see 36 FR 3031, March 31,
  1971). The purpose of the revisions
  promulgated today is to enhance
  enforcement and promote compliance
  with the current standard without
  altering the stringency of existing
  controls. On January 10,1989 the
  Environmental Protection Agency (EPA
  or the Agency) proposed amendments to
  the asbestos National Emission
  Standard for Hazardous Air Pollutants
  (NESHAP) that would require control
  device and fugitive emission monitoring,
 recordkeeping. and reporting for
 asbestos milling, manufacturing, and
 fabricating operations. For planned
 demolitions and renovations, revisions
 to the notification requirements were
 proposed, and safety was added as a
 reason for exemption from the use of
 wet removal methods. Recordkeeping
 requirements were proposed for
 asbestos waste disposal. Clarifying
 revisions to several definitions and
 provisions were also proposed.
 Numerous comments were received on
 the proposed revisions, and today's
 notice responds to those comments, and
 incorporates changes as a result of those
 comments.
 EFFECTIVE DATE: November 20,1990.
 Under section 307(b)(l) of the  Clean Air
 Act, judicial review of the actions taken
 by this notice is available only by filing
 a petition for review in the United States
 Court of Appeals for the District of
 Columbia Circuit within 60 Days of
 today's publication of these rules. Under
 section 307(b)(2) of the Clean Air Act,
 the requirements that are the subject of
 today's notice may not be challenged
 later in civil or criminal proceedings
 brought by EPA to enforce these
requirements.
                             ADDRESSES: Background information
                             document The background information
                             document (BID) for the promulgated
                             revisions may be obtained from the U.S.
                             EPA Library (MD-35), Research Triangle
                             Park, North Carolina, 27711, telephone
                             no. (919) 541-2777. Please refer to
                             "Background Information for
                             Promulgated Asbestos NESHAP
                             Revisions," (Publication No. EPA 450/3-
                             90/017). The BID contains a summary of
                             all the public comments made on the
                             proposed revisions and the
                             Administrator's responses to the
                             comments.
                               Dockets. Docket No. A-88-28 contains
                             supporting information used in
                             developing the final revisions to the
                             asbestos NESHAP and is available for
                             public inspection and copying between
                             8:30 a.m. and 3:30 p.m., Monday through
                             Friday, at EPA's Air Docket (LE-131),
                             Room M-1500,1st Floor, Waterside
                             Mall, 401 M Street, SW., Washington,
                             DC 20460. A reasonable fee may be
                             charged for copying.
                             FOR FURTHER INFORMATION CONTACT:
                             For further information and official
                             interpretations of applicability,
                             compliance requirements, and reporting
                             aspects of the promulgated revisions,
                             contact the appropriate Regional, State
                             or local office contact as listed in 40
                             CFR 61.04. For further information on
                             the background of the regulatory
                             decisions in the promulated revisions,
                             contact Mr. Sims Roy, Standards
                             Development Branch, Emission
                             Standards Division (MD-13),  U.S.
                            Environmental Protection Agency,
                            Research Triangle Park, North Carolina
                            27711. telephone no. (919) 541-5283. For
                            further information on the technical
                            aspects of the promulgated revisions,
                            contact Mr. Ronald Myers, Industrial
                            Studies Branch, U.S. Environmental
                            Protection Agency, Research Triangle
                            Park, North Carolina 27711, telephone
                            no. (919) 541-5407.
                            SUPPLEMENTARY INFORMATION:

                            I. The Standards

                             The promulgated revisions implement
                            section 112 of the Clean Air Act (CAA)
                            and are based on the Administrator's
                            determination that asbestos presents a
                            significant risk to human health u •
                            result of air emissions from one or more
                            source categories and is therefore a
                            hazardous air pollutant (see 36 FR 3031
                            (March 31,1971)). The revisions
                            promulgated today amend the asbestos
                            NESHAP to enhance enforcement and
                            promote compliance with the current
                            standard without altering the stringency
                            of existing controls.
  MiUing. Manufacturing and Fabricating '
    The revisions to the standards require j
  asbestos milling, manufacturing and
  fabricating sources to conduct daily
  monitoring for visible emissions. While
  the absence of visible emissions does
  not mean there are no asbestos fibers
  being emitted, the presence of visible
  emissions does indicate a serious
  control device malfunction. Because
  visible emissions monitoring is intended
  primarily to detect serious control
  device malfunctions, weekly inspections
  of air cleaning devices are also required.
  In addition, the revisions promulgated
  require these sources to maintain
  records of the results of visible
  emissions monitoring and control device
  inspections, and to submit quarterly a
  copy of visible emissions monitoring
  records of visible emissions occurred
  during the quarter. The  revision requires
  owners or operators who install fabric
  filters after the effective date of this rule
  to provide for easy inspection of the
  bags.

 Demolition and Renovation
   The revisions require the owner or
 operator of a demolition or renovation
 activity to provide additional
 information in notifications, and  to
 renotify EPA if the start date of a
 demolition or renovation changes from
 that given in the original notification.
 Another revision requires owners or
 operators to give a 10-day notice for
 renovations. A person trained in  the
• provisions of this rule and the means of
 complying with them is required to be
 on site when asbestos-containing
 material (ACM)  is stripped, removed or
 disturbed. When wetting is suspended
 due to freezing temperatures, owners or
 operators are required to measure air
 temperature in the work area three
 times during the workday and keep
 daily temperature records for at least 2
 years. The revisions also clarify EPA's
 position regarding the handling and
 treatment of nonfriable asbestos
materials such as resilient floor
covering, including vinyl asbestos floor
tile, and roofing material.
 Waste Disposal
  The revisions require vehicles used to
transport asbestos-containing waste
material to be marked with the sign
prescribed by the Occupational Safety
and Health Administration during
loading and unloading to warn people of
the presence of asbestos. For all
asbestos-containing waste material
transported offsite, the revisions require
that a waste shipment record (WSR) be
provided to the waste site owner or
operator at the time that the waste is

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         Federal  Register  / Vol. 5S.  No. 224 / Tuesday. November 20. 1990 / Rules and Regulations   4S407
delivered to the waste disposal site. If a
copy of the WSR signed by the waste
Bite owner or operator is not received
within 35 days of the date the waste was
accepted by the initial transporter, the
revisions direct the waste generator to
contact the transporter and/or disposal
site owner or operator to determine the
status of the  waste shipment. The
revisions further direct the waste
generator to submit an exception report
to EPA if a signed  copy of the WSR is
not received  within 45 days of the date
the waste was accepted by the initial
transporter. Labels are required on
containers of asbestos-containing waste
material from manufacturing,
fabricating, demolition and renovation
activities indicating the name of the
waste generator and the location where
the waste was generated.
Inactive Waste Disposal Sites
  The revisions require the owner or
operator of an inactive waste disposal
site for a milling, manufacturing or
fabricating operation to notify the
Administrator in writing prior to
excavating or otherwise disturbing
asbestos-containing waste material that
has been deposited at the disposal site
and to record on the deed to the
property a notation that will inform
future purchasers  of the property that it
has been used for the disposal of
asbestos-containing waste material and
that the survey plot and record of the
location and quantity of such waste
material are on file with the
Administrator.
Active Waste Disposal Sites
  The revisions require the owner or
operator of an active waste disposal site
to maintain WSRs and report in writing
the receipt of a significant amount of
improperly enclosed or uncovered Waste
to EPA by the following working day.
The owner or operator of an active
waste disposal site is required by the
revisions promulgated today to send a
signed copy of the WSR back to the
waste generator no more than 30 days
after receipt of the waste, to attempt to
reconcile any  discrepancy between the
quantity given on the WSR and the
quantity actually  received and, failing to
do so within 15 days after receiving the
waste, to report the discrepancy- and
any attempts to reconcile it to the
Administrator. The revisions
promulgated today also require the
owner or operator of an active disposal
site to maintain records of the location,
 depth and area, and volume of asbestos-
 containing waste material within the
disposal site on a map or diagram of the
 disposal area. Upon closure, the owner
 or operator  must  comply with all the
rules promulgated for inactive waste
disposal sites. A revision requires the
owner or operator of an active waste
disposal site to notify the Administrator
in writing prior to excavating or
otherwise disturbing asbestos-
containing waste material that has been
deposited at the disposal site and
covered.
Asbestos Conversion Processes

  A section is promulgated to clarify
that operations  that convert asbestos-
containing waste material into
nonasbestos (asbestos-free) material are
covered by the NESHAP. The provisions
promulgated require the owner or
operator of such an operation to obtain
prior written approval of the
Administrator to construct the facility,
and conduct a start-up performance test
using specified  analytical methods and
procedures. Requirements for
continuous monitoring during and after
the initial 90 days of operation,
emissions control, maintenance of
records of test results on site, and
reports to the Administrator are also
promulgated today.

II. Environmental, Energy and Economic
Impacts

  The environmental, energy, and
economic impacts of the revisions for
demolition and renovation, including
waste disposal, were estimated from
two baselines. One is full compliance
with the NESHAP, and the other is
current use of engineering controls and
work practices. Enforcement experience
indicates that many asbestos removal
operations related to demolition and the
subsequent waste disposal operations
are performed out of compliance with
the NESHAP. The lack of compliance
with the NESHAP removal provisions
leads to  the improper disposal of some
waste, especially demolition waste, with
 the result that emissions from the
 disposal of demolition waste greatly
 exceed other emissions, including
 process emissions from milling,
 manufacturing, and fabricating. Liability
 and other considerations generally tead
 the owners of buildings being renovated
 to follow or even exceed the
 requirements of the NESHAP. Thus, the
 appropriate baseline for demolition is
 current use of work practices rather
 than full compliance. At asbestos
 milling, manufacturing, and fabricating
 facilities, the required air pollution
 control devices are generally in place.
 Thus, for milling, manufacturing, and
 fabricating, full compliance with the
 NESHAP, including the waste disposal
 requirements, is assumed for the
 baseline.
  Few emission .measurement data exit
for asbestos sources. Thus, emissions
were estimated using engineering
methods and assumptions, which  ;.
resulted in substantial uncertainty. A
detailed description of the approaches
used to estimate emissions is found,in
"Asbestos Emission Estimates for
Milling, Manufacturing, Fabricating,
Demolition, Renovation, and Waste
Disposal," which is contained in Docket
A-88-28. Estimated process emissions
under the current NESHAP at full
compliance for milling, manufacturing,
and fabricating are approximately 7,400
kg/yr. Based on current practices,
estimated emissions from the removal
activities associated with demolition
and renovation are approximately 1,300
kg/yr and estimated waste disposal
emissions from all sources are 227,000
kg/yr. If demolition and renovation were
in full compliance, estimated emissions
from asbestos removal activities''
associated with demolition and
renovation would be about 700 kg/yr.
Estimated emissions from waste
disposal, assuming full compliance with
the NESHAP by all sources, would be
about 600 kg/yr..
   The costs of the revisions are
expected to be small relative to normal
operating costs for these industries. The
revisions are intended to promote  .
compliance and enhance enforceability.
Small additional costs are associated
with the recordkeeping and reporting
requirements of the, revisions. Economic
 impacts of the promulgated alternatives
 are expected to be minimal. Adverse
 impacts of the promulgated revisions on
 water, noise, and energy were
 considered. Due to the nature of the;
 revisions, no significant adveVse'impacts
 on water, noise, or energy are
 anticipated.   .      ,
 m. Public Participation

   The revisions were proposed and
 published in the Federal Register on
 January 10.1989 (54 FR 912). The
 preamble to the proposed standards
 revisions,noted the availability in the
 docket of the supporting information
 used in developing the proposed,,
 revisions. Public comments were
 solicited at the time of proposal.
    To provide interested persons  the
 opportunity for oral presentation of
 data, views,'or arguments concerning
 the proposed revisions,  a public hearing
 was held on February 8,1989, at,
 Research Triangle Park, North Carolina.
 The hearing was open to the public, and
 6 persons  presented comments.
    The public comment period specified
 in the Federal Register notice was from
 January 10,1989 to March 7,1939, Qne

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 48408    Federal Register / Vol. 55. No. 224 / Tuesday. November 20. 1990 / Rules and  Regulations
 hundred comment letters were received
 in response to the Federal Register
 proposal. The comments have been
 carefully considered and, where
 determined to be appropriate by the
 Administrator, changes have been made
 to the proposed revisions.

 IV. Significant Comments and Changes
 to the Proposed Revisions
   Comments on the proposed revisions
 were received from industry, trade
 associations and  regulatory agencies. A
 detailed discussion of these comments
 and responses can be found in the
 promulgation BID, which is referred to in
 the ADDRESSES  section of this
 preamble. The comments and responses
 summarized in the BID serve as the
 basis for the changes that have been
 made to the revisions between proposal
 and promulgation. The  major comments
 and responses are summarized in this
 preamble. Most of the comment letters
 contained multiple comments.
 Significant comments have been divided
 into the following areas: demolition and
 renovation, and waste disposal.

 Demolition and Renovation

 Nonfriable ACM
   Comment: Several commenters argued
 that the rule should be modified to
 clarify that certain products are
 nonfriable and. therefore, not regulated.
 Asbestos cement (A/C) products,
 including transits  and exterior shingles,
 should be included among nonfriable
 products according to commenters IV-
 D-49. IV-D-72. and IV-D-93. Asbestos-
 containing flooring products, such as tile
 and sheet vinyl flooring, were
 considered by several commenters (IV-
 D-15. IV-D-47. IV-D-48. IV-D-55, IV-
 D-84. and IV-D-95) to always be
 nonfriable and exempt from the rule,
 with the exception of flooring that was
 being sanded (IV-D-47, IV-D-48).
 Another commenter, IV-D-48, in
 reference to asbestos roofing products,
 argued that there is no basis in  the
 record for saying that severely
 weathered asphaltic material could
 become brittle. Commenters IV-D-21,
 IV-D-3I. IV-D-48. IV-D-49. and IV-D-
 93 recommended that the rule be
 clarified to exempt all nonfriable
 materials as the rule is currently
 understood. Commenter IV-D-93 argued
 that in present day ACM, the asbestos
 fibers are locked in cement or
 bituminous or resinous binders  and that
 the materials can be removed and
 disposed of without any significant
release to the environment.
  Response: In 1973 when the asbestos
NESHAP rules were first promulgated
for the demolition  of buildings. EPA's
 intention was to distinguish between
 materials that would readily release
 asbestos Fibers when damaged or
 disturbed and those materials that were
 unlikely to result in the release of
 significant  amounts of asbestos fibers.
 To accomplish this, EPA labeled as
 "friable" those materials that were
 likely to readily release fibers. Friable
 materials, when dry, could easily be
 crumbled, pulverized, or reduced to
 powder using hand pressure. The term
 "reduced to powder" is readily
 understood to mean that the affected
 material is changed to a dust or powder
 that can become airborne. "Pulverized"
 indicates that the resulting material will .
 include dust as well as a large number
 of small  pieces of the original material.
 The term "crumbled" indicates that the
 affected material is easily (i.e., using
 hand pressure) broken into a large
 number of small pieces. Although dust is
 likely to be produced as a result of
 crumbling,  it is possible that there are
 some types of materials that can be
 crumbled without producing dust. It is
 also understood that crumbling refers to
 an action that occurs essentially in one
 effort and not to repeated attempts to
 crumble  the material. For example, floor
 tile in good condition can be broken by
 hand into a few large pieces, but it is not
 easily broken in one effort into many
 small pieces.  On the other hand, floor
 tile that has lost its structural matrix is
 in poor condition and can be broken into
 many small pieces  in one effort.
  Later, EPA  realized that, in some
 instances, nonfriable materials that
 were subjected to intense forces, such
 as the intense mechanical forces
 encountered during demolition, could be
 crumbled, pulverized, or reduced to
 powder. In  these instances, certain
 materials which had been considered
 nonfriable appeared capable of
 releasing significant amounts of
 asbestos fibers to the atmosphere.
 Examples of practices that were
 observed by EPA to reduce otherwise
 nonfriable asbestos material to dust
 capable of becoming airborne included
 the breaking of nonfriable insulation
 from steel beams by repeatedly running
 over the beams with a crawler tractor.
 In view of the damage done to these
 otherwise nonfriable materials and the
 resulting increased potential for fiber
 release, these and other similar
 practices involving nonfriable asbestos
material were considered to render
nonfriable ACM into dust capable of
becoming airborne.
  As a result, EPA issued a policy
determination in 1985 regarding the
removal of nonfriable asbestos material
that was consistent with EPA's intent to
distinguish-between material that could
release significant amounts of asbestos
fibers during demolition and renovation
operations and those that would not.
This policy determination stated in
essence that any ACM, whether
originally friable or nonfriable that
become (or are likely to become)
crumbled, pulverized, or reduced to
powder are covered by the NESHAP.
Specifically, the determination stated
that
* ° * even though the regulations address
only material that is presently friable, it does
not limit itself to material that is friable at the
time of notification. Rather, if at any point
during the renovation or demolition,
additional friable asbestos material
is * * * created from nonfriable forms, then
this additional friable material becomes
subject to the regulations from the time of
creation * * *

The issuance of this determination did
not alter the intent of the NESHAP, but
was consistent with the intent of the
standard that was written to prevent
significant emissions of asbestos fibers,
The intent of the policy determination
was that it apply narrowly to specific
instances where otherwise nonfriable
materials would be damaged during
demolition or renovation to the extent
that significant amounts of asbestos
fibers would be released to the
atmosphere. A statement in the
determination to the effect that some
nonfriable materials may remain
nonfriable throughout demolition and
renovation is evidence that this
determination was intended to be
narrowly interpreted and not used to
require removal of all nonfriable
materials. For example, materials such
as resilient floor covering, asphalt
roofing products, packings, and gaskets
would rarely, if ever, need to be
removed because, even when broken or
damaged, they would not release
significant amounts of asbestos fibers.
But, just as it is important to recognize
that some nonfriable materials do not
have to be removed prior to demolition,
it is also important to recognize that
some nonfriable materials should be
removed prior to demolition if, as a
result of the forces of demolition,
nonfriable material is likely to become
crumbled, pulverized, or otherwise
reduced to powder. For example, the
A/C siding on a building that is to be
demolished using a wrecking ball is very
likely to be crumbled or pulverized with
increased potential for the release of
significant levels of asbestos fibers.
Such material in this instance should be
removed prior to demolition.
  Since this policy determination was
made, there has been some confusion in

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          Federal Register / Vol. 55, No. 224  /  Tuesday.  November 20.*g90 / jfejg3_ °nj^
 its application. As a result, contractors
 operating in more than one enforcement
 jurisdiction have encountered different
 •interpretations for similar demolition
 operations. For example, theie havs
 been instances in which contractors are
 required, prior to demolition, to remove
 floor tiie in one enforcement jurisdiction
 but not in another. Contractors and/or
 building owners and operators are
 unsure as to what materials must be
 removed and what materials can be left
 in place and are often hesitant to
 proceed without,a ruling from EPA,
 which can involve significant delays.
   As a consequence, EPA received a
 number of requests from State and
 regional enforcement agencies to clarify
 what is required under the NESHAP in
 dealing with nonfriabie materials since
 the 1985 policy determination was
 issued. In response to these requests, a
 darification of the nonfriabie issue was
 included in the revisions proposed on
 January 10,1989. These revisions were
 intended to clarify the intent of the
 original rule. Basically, EPA stated  in
 the January 10,1989, Federal Register
 notice that certain nonfriabie materials,
 such cs floor tiie, roofing products,  and
 packings and gaskets that are in good
 condition, can be left in buildings being
 demolished because fiber release from
 these materials, even if the materials are
 damaged, is relatively small compared
 to the fiber release from friable
 materials. Other nonfriabie products
 such as A/C products have e greater
 potential to release asbestos fibers
 when heavily damaged and may have to
 be removed prior to demolition.
   In response to the revisions proposed
 on January 10,1989, numerous .
 comments were submitted to EPA, Many
 of the commenters argued that EPA was
 attempting to regulate nonfriabie
 materials, which were explicitly
 exempted in previous asbestos NESHAP
 rulemakings. Many comments stated
 that the proposed revisions did not help
 to clarify EPA's position on nonfriabie
 material and may  have made matters
 more confusing.
   In responding to the comments, a
 literature survey was conducted to
 determine if it was possible to quantify
 the fiber release potential of nonfriabie
"materials when they are damaged
 during demolition. All of the available
 'data on fiber release from floor tile,
 roofing products, gaskets, packings, and
 A/C products was reviewed. In some
• instances,.the fiber release data were
 measured during actual removal
 operations, while other data were from
 simulated removal activities in
 laboratory settings. For the materials
 evaluated, the potential for fiber release
appeared minimal and substantially
lower than for friable materials. These
findings, while uncertain, support EPA's
original argument that there is a basis
for making a distinction between
materials that readily release fibers and
those that do not.
  As a result of the comments received
on this issue and the additional
information gathered in response to
comments, EPA has been able to
compile a list of nonfriabie ACM that,
under normal conditions, do not have to
be removed prior to demolition
operations. These ACM are not
expected to release significant amounts
of asbestos fibers to the outside air
during demolition and, consistent with
the intent of the existing standards, are
not being regulated. A definition of
"category I nonfriabie ACM" is added to
the final rule, which lists resilient Door
covering, roofing products, gaskets, and
packings. However, if these materials
are in poor condition and are friable  or
they are subjected to sanding, grinding,
cutting, or abrading, they are to be
treated as friable asbestos material.
Category I nonfriabie ACM that is  in
poor condition,  but is not friable and
will not be subjected to sanding,
grinding, cutting, or abrading, is not
subject to the NESHAP. "In poor
condition" has been defined to mean
that the binding of the material is losing
its integrity as indicated by peeling,
cracking, or  crumbling of the material.
Other nonfriabie materials are identified
as Category II nonfriabie ACM and have
to be evaluated on a case-by-case  basis.
Category II materials that become
crumbled, pulverized, or reduced to
powder during removal or during
demolition are covered by the NESHAP.
Broken ACM
   Comment- Commenters IV-D-47, IV-
D-69, IV-4J-S3, and IV-D-SS explained
that use of the term "broken" to
describe materials that are subject to
the rule is inconsistent with the current
NESHAP and expands coverage of the
NESHAP. These commenters stated  that
merely breaking nonfriabie material
does not equate to fiber release. One
commenter, IV-D-TO, noted that
noncompliance may increase where
nonfriabie material is broken during
demolition or renovation, but Is not
controlled or reported according to the
NESHAP.
   Response: After considering this issue,
EPA agrees  with commenters that
retaining the word "broken" could be
interpreted as substantially increasing
the scope of the standard and. therefore,
has removed it from the definition. Most
nonfriabie materials can be broken
without releasing significant quantities
of airborne asbestos fibers. It is only
when the material is extensively
damaged, /.e., crumbled, pulverized, or
reduced to powder, that the potential for
significant fiber release is greatly
increased. Also, in the definitions of
"asbestos-containing waste material."
"friable asbestos material," and
elsewhere, the word "broken" is
deleted. The EPA is planning to issue
additional information in the future on
this and other aspects of the NESHAP to
help enforcement officials and the
regulated community interpret and
apply the NESHAP provisions.

Inspections
  Comment Three commenters argued
that EPA should include mandatory
asbestos surveys in the rule. Commenter
IV-D-4 stated that EPA should require
surveys for all buildings prior to and
separate from any demolition or
renovation activity. Commenter IV-D-4
stated that such building surveys could
become part of a public record, making
the absence of a survey a violation.
Commenter IV-D-4 noted that, if the
survey indicated that a structure was
asbestos free, all notification and
enforcement costs would be eliminated.
Also, commenter IV-D-4 explained that
a demolition without proper notification
could be easily established later.
  Commenters IV-D-57 and IV-D-84
stated that EPA's requirement to survey
buildings prior to demolition and
renovation is implicit and should be
made explicit and require that surveys
be performed by an accredited asbestos
inspector. Commenter IV-D-57 also
noted that OSHA requires a building
survey by a competent person and
stated that EPA should similarly require
a she-specific survey before demolition,
with details on how the building will be
demolished and how the asbestos will
be controlled.
  Response: The EPA currently requires
that« facility be inspected for asbestos
prior to demolition or renovation. As a
result of the survey, information on the
asbestos material present, the nature of
 the  demolition or renovation, and
measures that will be taken to control
emissions of asbestos must be reported
 to EPA. Commenters IV-D-57 and IV-
D-84 are correct in saying that it is an
 implicit requirement am} that it is not
 stated explicitly in the rule. The final
role expressly requires a facility survey
 for asbestos prior to demolition or
 renovation. Although previously
 implied, this revision clarifies EPA's
 position on the requirement to perform
 building surveys.
   The EPA also considered the
 suggestion to require that surveys be

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   performed by an "accredited" inspector
   or by a "competent" person as required
   by OSHA. OSHA's requirement to have
   a competent person perform an
   engineering survey prior to demolition
   (29 CFR 1926.850} is to ensure that the
   structural integrity of a structure is
   sufficient to prevent worker injury
   caused by the unplanned collapse of any
   portion of the structure; a search for
   asbestos is not required. An accredited
   inspector or competent person can
   perform the survey although using such
   individuals is not required. Using  an
   accredited inspector and following the
  AHERA requirements for building
  inspections would help ensure a
  thorough inspection of the facility as
  required by the NESHAP. However, EPA
  has not had this requirement before and
  did not propose  such a requirement. The
  EPA will consider a requirement to use
  accredited inspectors in future
  amendments to the rule.
    Commenter IV-D-4's suggestion to
  require the survey of all buildings in
  advance of demolition or renovation
  would increase the stringency of the
  regulation by requiring all owners  and
  operators to survey their fa'cilities for
  asbestos even when no demolition or
  renovation operations were planned.
  The revisions proposed on January 10,
  1989, are intended to clarify the rule and
 promote compliance. The need for  a
 revision that would affect stringency
 may be considered at a later date.
 However, such a requirement would
 require a substantial commitment of
 resources to perform surveys  of all
 existing buildings. In addition, it is  not
 clear that it would always negate the
 need for pre-demolition inspections in
 the future.

 Friable Asbestos Material—Analytical
 Method
   Comment: Commenters IV-D-17, IV-
 D-35. and IV-D-70 supported the
 proposed changes to the definition of
 "friable asbestos  material," specifically
 the change to percent by area.
 Commenter IV-D-69 argued that to go
 from percent weight to percent area may
 ha\*e a major impact on coverage
 because there may be wide
 discrepancies in the results reported by
 the two methods.  Commenter IV-D-69
 provided an example of this, stating that
 a cement-based fireproofing that
 contained 30 percent asbestos by area
 contained less than 1 percent by weight.
 Commenter IV-D-70 felt that the
 definition of "friable asbestos material"
was appropriate; however, the method
referenced should not be limited to point
counting in view of 47 FR 1982, p. 38535,
which clarifies the acceptability of "an
equivalent estimation method."
  Commenter IV-D-78 stated that the
  definition would require asbestos
  content to be determined by
  transmission electron microscopy (TEM)
  analysis, and that the high cost of TEM
  should be considered. Commenter IV-D-
  78 recommended that the current
  method continue to be accepted with
  TEM specified over other methods.
    Response: The revisions to the
  asbestos NESHAP proposed on January
  10,1989 would have changed the
  definition of "friable asbestos material"
  from "greater than 1 percent weight" to
  "greater than 1 percent area" and
  referenced a method for the analysis.
  Because the method referenced actually
  contains two analytical methods—
  polarized light microscopy (PLM) which
  currently measures area, and x-ray
  diffraction (XRD) which measures
  weight—EPA has modified the definition
  to specify the PLM method to avoid
  possible confusion as to which method
  is referenced. Because the PLM point
  counting method measures percent area,
  the phrase  "by area" is not necessary
  and has been taken out of the definition.
  The difference between percent area
  and percent weight depends on the
  density and volume of materials in the
  sample. These relationships are
  described in Asbestos Content  in Bulk
  Insulation Samples: Visual Estimates
  and Weight Composition (EPA-560/5-
 88-011, September 1988). However, the
 fact remains that the PLM procedure
 used to determine the amount of
 asbestos in building materials (Interim
 Method for the Determination of
 Asbestos in Bulk Insulation Samples
 (EPA-600/M4-82-020, December 1982)
 measures percent area and not percent
 weight. PLM laboratories polled at
 meetings of the National Asbestos
 Council admitted that percent area is
 what they measure and report.
 Accordingly, there should be no impact
 on the standard from the proposed
 change.
  Point counting is not required for the
 PLM procedure. An equivalent visual
 estimation technique may be used.
 Visual estimation may be made during
 macroscopic examination with a
 stereobinocular microscope, resulting in
 a volumetric estimation of components.
 For most samples, quantitation by
 macroscopic examination is preferred.
 Visual estimation may also be made
 during polarized light microscopy (PLM)
 examination, resulting in a projected
 area estimation of components.
However, if the asbestos content is
estimated  to be less than 10 percent by a
method other than point counting, such
as visual estimation, EPA has revised
the definition to require that the
  determination be repeated using the
  point counting technique with PLM.
  Point counting, a systematic technique
  for estimating concentration, may also
  be useful in quality assurance activities. ]
  especially in establishing a relationship
  between point counts and visual
  estimation procedures.
    The accuracy of quantitative data
  from either technique of estimation is
  dependent upon several factors,
  including: sample homogeneity, asbestos
  content, asbestos fiber size, the
  presence of interfering matrix/binder
  material, and the skill of the
  microsccpist. It is suggested that the
  quantitation skill of the microscopis!
  may be improved and concurrently
  verified through the use of calibration
  standards. These standards may include
  well-characterized bulk materials or in-
  house calibration standards formulated
  by mixing known weights of commonly
  available fibrous (asbestos, cellulose,
  glass, etc.) and nonfibrous (plaster, clay,
  vermiculite, calcium carbonate, etc.)
  materials.
   For some materials, experience has
  shown that gravimetry (gravimetric
  sample reduction) is a viable technique
  to aid in the determination of asbestos
  content. The technique involves the
  systematic removal (and determination
  of the resulting weight loss) of
  interfering components, and the
  concentration of asbestos in a residue,
  the components of which are identified
  by PLM. EPA is currently conducting
 research to develop procedures that will
 help determine the appropriate
 analytical procedure to use based on the
 type of material, the level of asbestos
 present in the material, as well as other
 factors.
   TEM is not recommended for routine
 analysis of bulk samples. TEM may be
 useful in the analysis of special
 materials containing finely divided
 asbestos particles. The EPA is currently
 reviewing procedures for analyzing bulk
 samples for asbestos. Under
 investigation are procedures that would
 determine what analytical techniques
 are appropriate for bulk samples of
 different materials and different
 asbestos contents. For example, a •
 simple visual estimation technique may
 be appropriate for the initial screening
 of bulk samples of friable material. If the
 visual estimation technique indicates
 that the asbestos content is less than 10
 percent, additional quantitation by point
 counting would be required. If the
 material to be analyzed contains
asbestos  fibers below the limit of
resolution for PLM, which is often true
of floor tile, then analysis by TEM is
appropriate.

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         Federal Register / Vol. 55, No. 224 / Tuesday. November 20. 1990 / Rules and Regulations    48411
Method of Notification
  Comment: Several comments were
received on the requirement to use
certified mail for notifying EPA. Most of
the commenters objected to the use of
certified mail to the exclusion of other
methods.
  Commenters IV-D-23, IV-D-24, IV-D-
25, IV-D-42, IV-D-78, IV-D-59, and IV-
D-65 considered the certified mail
requirement to be unnecessary for EPA
to achieve the intended purpose of the
notification process. It was stated that
certified mail would require a trip to a
post office, which is a deterrent to
timely notification. Commenters IV-D-
23, IV-D-24, IV-D-41. and IV-D-78
argued that notification by telefax
machine may be more practical than
certified mail. Commenters FV-D-25, IV-
D-65. and IV-D-63 suggested that
notification by telephone or telefax be
allowed, followed by a written
notification. Commenters IV-D-24, IV-
D-25, IV-D-42, and IV-D-65 observed
that regular mailing of notices works
satisfactorily and should be allowed.
Commenters IV-D-28 and IV-D-66
favored allowing the use of overnight
mail.
   Commenter IV-D-59 argued that, if a
State agency has jurisdiction, the
method of notification should be left up
to the State agency.
   Commenter IV-D-32 argued that all
notifications should be in writing
because telephone notification does not
result in a legally enforceable written
record. Also, commenter IV-D-32 stated
that allowing the use of telephones
would promote schedule changes for
minor reasons that would not otherwise
be considered.
   Response: Several of the commenters
objected to the required use of certified
mail even though EPA proposed the use
of certified mail as  a way of ensuring
that owners/operators had proof of
notification. In view of the negative
comments and after reconsidering the
issue, the EPA has decided not to
require certified mail although its use
would be allowed. The use of the regular
mail system, i.e., U.S. Postal Service, has
worked satisfactorily in the past and
will continue  to be  allowed. Also.
because the rule specifies postmark
"* *  * or deliver *  *  *," private
overnight mail delivery  is permitted.
   Regarding the use of telephone
facsimile (fax) machines to transmit
notices, EPA does not consider these
systems to be sufficiently reliable, at
this time, to allow their use. Often, it is
difficult to know whether a transmission
was successful. Disadvantages
associated with their use include
occasional incomplete transmissions
and transmissions of poor quality
requiring faxed messages to be followed
by telephone contact to confirm proper
transmission. More than one
transmission may be required. In some
instances, quality cannot be improved.
Also, because of competing messages, it
often requires a long time before a fax
can be properly transmitted and
verified. The EPA may consider the use
of facsimile machines in the future when
their reliability has been improved.
  The EPA does not consider it
necessary to allow the use of the
telephone for the original notification of
a demolition or renovation activity
covered by this standard. The
notification must be in writing.
  Where States or local authorities
enforce their own asbestos regulations,
they may choose the notification
procedures. But if a State is delegated
authority for enforcing the NESHAP,
then they must adhere to the NESHAFs
requirements.
.  The EPA is in agreement with the
commenter who favors written
notifications over telephone
notifications and the final rule continues
to require the former.
  It should be noted that OSHA has
recently proposed notification
requirements (55 FR 29712, July 20,1990)
similar to those in the NESHAP. The
EPA is coordinating with OSHA during
their rulemaking to determine the most
efficient mechanism to avoid duplication
and ensure that both EPA and OSHA
receive adequate notice without unduly
burdening industry.
Renotification
  Comment: Numerous comments were
received on the proposed renotification
requirements. Although a few favored
 the requirements as proposed and a few
 thought the requirements should be
 more stringent, most of the commenters
 favored the use of telephone
 renotification. The comments were as
 follows:
   Commenter IV-D-28 disagreed with
 the  NADC comment in the proposal
 preamble that renotification by
 telephone should be allowed;
 commenter IV-D-28 recommended a 10-
 day written notice for all projects.    ;-
   Commenter IV-D-21 suggested that
 the renotification provisions be made
 more flexible by allowing the actual
 start date to vary by a couple of days for
 projects lasting longer than 5 days
 before requiring the owner/operator to
 renotify.
   Commenters IV-D-21, IV-D-25, IV-D-
 26, FV-D-36, FV-D-37, IV-D-41, IV-D-
 42, IV-D-45, FV-D-46, rV-D-49, IV-D-
 50, IV-D-58, IV-D-59, IV-D-60. IV-D-
 61, FV-D-82, IV-D-65, IV-D-69, FV-D-
71, IV-D-73. IV-D-74, IV-D-76, IV-D-
87. IV-D-88. and IV-D-94 suggested that
EPA allow the use of some other means
besides certified mail for renotification,
such as same day telephone or telefax
messages, when a 5-day written notice
would further delay the project. This
would be simpler and less time-
consuming. Commenter IV-D-41 also
suggested that, when it is feasible to
provide a 5-day written notice, i.e.,
delays are known at least 5 days in
advance, then such notice would be
provided. Also, as commenters IV-D-46,
IV-D-49, IV-D-50, IV-D-58, IV-D-60,
FV-D-62, IV-D-69, and IV-D-73
suggested, a telephone notice could be
followed by a written notice.
  According to commenters IV-D-23,
IV-D-24, FV-D-36. IV-D-37, IV-D-41,
IV-D-42, IV-D-43, IV-D-45, IV-D-46,
IV-D-49. IV-D-50, IV-D-51, IV-D-58,
IV-D-59, IV-D-63, IV-D-64, IV-D-73,
IV-D-75, IV-D-76, IV-D-78, IV-D-87,
IV-D-88, and IV-D-94, there are
numerous unforeseen factors, such as
equipment mobilization problems,
personnel availability, weather, or other
project difficulties, that can cause a
removal project to start on a date other
than the one submitted in the original
notification. These commenters
explained that the proposed
renotification requirements, with their
additional waiting requirements, could
result in unreasonable project delays
and significantly increased project costs.
Several of these commenters and
commenter IV-D-84 suggested that EPA
allow a project to start within some
reasonable period of time, such as a
 couple of days, of the original start date
without having to renotify EPA in
writing. The EPA should provide for
 some flexibility in predicting the exact
 start date. In the experience of one of
 the commenters, jobs usually start
 within a day or two of the scheduled
 date.
   Response: The EPA agrees that a 10-
 day advance notice is appropriate for
 demolitions and renovations that can be
planned for and scheduled. In some
 situations, however, such as emergency
 renovations or government-ordered
 demolition of buildings that are in
 danger of imminent collapse, EPA
 considers shorter notification periods
 appropriate. For renotification, a 10-day
 additional waiting period would be
- excessively burdensome.
   The EPA has considered the
 suggestion that telephone renotification
 be permitted and has determined that
 providing  for the use of the telephone,
 followed by a written notice, would
 provide the necessary flexibility and
 would be in the best interests of both

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  48412
Federal Register / Vol. 55. N^. 224 / Tuesday, November 20, 1990 / Rules and Regulations
  the regulated community and EPA. The
  EPA does not want to interfere with
  commerce by requiring a 5-day waiting
  period for a written renotification when
  a telephone call followed by a written
  renotification would suffice. Nor does
  EPA wish to make useless visits to jobs
  that have been rescheduled because a
  written renotification of a change in
  start date was not received in time.

  Emergency Renovation
   Comment: Commenters IV-D-Q, IV-D-
  14. IV-D-41. IV-D-42. and IV-D-49
  stated that the scope of the term
  "emergency renovation operation"
  should not be limited to events resulting
  in "unsafe conditions." but should
  include events such as fires, ruptured
  pipes, boiler failures, and other
  situations that could present potential
  public health or safety hazards if not
  immediately attended to. Commenter
 IV-D-18 asked if the definition would
 include the release of asbestos into the
 air. Commenter IV-D-63 recommended
 that the definition include operations
 necessary to protect equipment from
 significant damage.
   Response: Events that would
 necessitate an emergency renovation
 include those that may produce
 immediately unsafe conditions as well
 as those that, if not quickly remedied,
 could reasonably be foreseen to result in
 an unsafe or detrimental effect on
 health. For example, a boiler in an
 apartment building that suddenly
 malfunctions during the winter would
 need to be repaired immediately. To
 protect equipment from significant
 damage and to avoid imposing an
 unreasonable financial burden by
 requiring sources that experience a
 sudden unexpected equipment failure to
 wait 10 days, the final rule includes
 equipment damage and financial burden
 as additional reasons for emergency
 renovations, and the definition of
 emergency renovation is revised
 accordingly.

 Definition of Facility
  Comment: Several commenters argued
 that the exclusion of residential
 facilities having four or fewer dwelling
 units should be eliminated. Commenter
 IV-D-89 asserted that residential
 demolition and renovation and
 associated waste disposal involve
 significant quantities of asbestos and
 should be regulated. Commenter IV-D-
54 argued that residential buildings
having four or fewer units  should not be
exempt from the work practices
provisions even if they are exempt from
the notification requirements.
Commenter tV-D-94 recommended that
only  facilities with one dwelling unit be
                             excluded because renters of apartments
                             are frequently exposed as a result of
                             asbestos work performed by untrained
                             workers.
                               Response: The recommendation to
                             remove the exemption for residential
                             facilities having four or fewer dwelling
                             units would expand the scope of the
                             rule. Revisions that alter stringency may
                             be considered during a later rulemaking.
                             However, EPA does not consider
                             residential structures that are
                             demolished or renovated as part of a
                             commercial or public project to be
                             exempt from this rule. For example, the
                             demolition of one or more houses as part
                             of an urban renewal project a highway
                             construction project or a project to
                             develop a shopping mall, industrial
                             facility, or other private development,
                             would be subject to the NESHAP. Nor
                             would the conversion of a hotel or large
                             apartment building to a condominium, a
                             cooperative, or a loft exempt the
                             structure from the NESHAP. To clarify
                             that condominiums, cooperatives, and
                            -lofts which exceed four dwelling units
                             are subject to the NESHAP, the
                            definition of facility has been modified
                             accordingly. The owner of a home that
                            renovates his house or  demolishes it to
                            construct another house is not to be
                            •ubject to the NESHAP.

                            Definition of Installation
                              Comment: Commenter IV-D-83
                            argued that the definition of
                            "installation" needs clarification and
                            asks whether a group of residential
                            buildings would be excluded. The
                            commenter argued that a group of
                            residential buildings at one location
                            being demolished or renovated by one
                            developer should be covered.
                              Response: A group of residential
                            buildings under the control of the same
                            owner or operator is considered an
                            installation according to the definition
                            of "installation" and is, therefore,
                            covered by the rule. As  an example,
                            several houses located on highway
                            right-of-way that are all demolished as
                            part of the same highway project would
                            be considered an "testaHathm,*' even
                            when the houses are not proximate to
                            each other. In this example, the houses
                            are under the control of the same owner
                            or operator, i*., the highway agency
                           responsible for the highway project
                           Training

                              Comment: Commenters IV-D-18 and
                           IV-D-68 recommended that a refresher
                           course be attended every 2 years.
                             Response: Regarding the commenters
                           who recommended that  refresher
                           courses be taken every 2 years, EPA
                           agrees and has modified the rule to
                           require refresher courses. The EPA
 considers such additional training
 important to maintain familiarity with
 the NESHAP as well as to keep abreast
 of any changes in the standards.

 Sanding. Grinding, or Abrading
 Nonfriable ACM

   Comment- Commenters IV-D-15, IV-
 D-47, IV-D-48, IV-D-55, IV-D-84, and
 IV-D-95 considered asbestos-containing |
 flooring products, such as tile and sheet
 vinyl flooring, to always be nonfriable
 and exempt from the rule, with the
 exception of flooring that was being
 sanded (Commenters IV-O-47 and IV-
 D-ML)
   Response: The EPA considers the
 deliberate sanding, grinding, or abrading
 (including drilling, cutting, and chipping)
 •of all nonfriable materials, including
 resilient floor covering, asphalt roofing
 material, packings, and gaskets to be
 sources of asbestos emissions and the
 revisions require otherwise nonfriable
 ACM to be treated as if it were friable
 when it is sanded, ground or abraded.
   Also, a definition of "grinding" is
 added to clarify the types of activities,
 especially those involving nonfriable
 asbestos materials, that are subject to
 the regulation. For example, typical floor
 tile removal methods, such as
 mechanical chipping, result in the floor
 tile being broken up into numerous small
 fragments. This removal method is
 subject to the NESHAP provisions.
 Other floor tile removal methods are
 available that do not result in the
 material being so severely damaged.
 Such methods include the use of heat
 from heat guns or electric heat
 machines, the use of infrared machines,
 flooding with water or amended water,
 and the use of dry ice or liquid nitrogen.
 These methods when properly utilized
 aliovr the tiles to be removed with a
 minimum of damage to the tiles and
 would not be subject to the NESHAP.

 Definition of Nonfriable Asbestos
 Material

  Comment Commenters IV-D-15 and
IV-D-89 asserted that the meaning of
"nonfrisble" is unclear because it was
not defined in the revisions proposed on
January 18,1989. A problem may result
if it is considered the opposite of friable.
Commenter IV-O-39 also argued for a
definition of "nonfriable" and asserted
that likefriaWe," the threshold of at
least 1 percent by area should apply.
  .Response.-The EPA agrees that the
meaning of "nonfriable" needs to be
clarified. A definition of "nonfriable
asbestos material" has been added to
the final rule. The EPA considers
nonfriable asbestos material to be
material containing more than 1 percent

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           IFederal Register /Vol. 55,  No. 224 / Tuesday, November 20, 1990 / Rules  and Regulations
  asbestos by area that cannot be
  crumbled, pulverized, or reduced to
  power by hand pressure. However, some
  nonfriable asbestos materials can be
  crumbled, pulverized, etc., in the course
  of demolition/renovation operations
  leading to asbestos emissions and are,
  therefore, subject to control under the
  NESHAP.

  Waste Disposal

  Marking
   Comment: Cbmmenters IV-D-61 and
  IV-D-S8 asserted that the term
  "placard" is inappropriate because it
  has a specific application under DOT
  regulations for hazardous waste
  transport, and that the proposal should
  be revised to maintain the distinction
  between "marking" and "placarding" as
  was done in RCRA and TSCA
  rulemakings.
   Response: The EPA has modified the
  final rule to replace the term "placard,"
  a term used by the DOT in its regulation
 • of the transportation of hazardous
  materials, with the term "mark" as
  suggested by the commenters. This
  should help avoid confusing DOT
 requirements with requirements under
 the NESHAP.
 Labeling

   Comment: Commenters IV-D-18, IV-
 D-28, IV-D-11, and FV-D-84
 recommended that EPA in Section
 61.150, and perhaps elsewhere, cite only
 OSHA labels and delete references to
 other labels because OSHA requires the
 use of their labels in all cases.
   Response: The EPA  agrees with the
 commenters who suggest that only
, OSHA labels be required on containers
 and has revised the final rule
 accordingly.

 Offsite Disposal
   Comment: Two commenters were
 concerned with placarding and other
 requirements of § 61.149(d). Commenter
 FV-D-22 stated that his company moves
 tailings from the mill by dump truck or
 earth-moving equipment to a disposal
 site on company property and would
 like the requirements for placards, etc.,
 in § 61.149(d) changed so that they
 would apply only to transport to an
 offsite disposal facility.
   Commenter IV-D-93 also suggested
 that the requirements of § 61.149{d)
 should apply only to vehicles
 transferring waste offsite.
   Response: Although company
 personnel may not require a warning
 that asbestos waste is being
 transported, others who are on site and
 who are not company employees, e.g.,
 vendor and construction personnel,
 clearly do. Further, OSHA requires that
 workers be informed of hazards to
 which they are exposed. Accordingly,
 EPA believes the provisions of
 § 61.149(d) are appropriate as proposed
 and should not be changed as suggested.
 EPA Identification Number
  Comment: Several comments
 addressed the proposal to assign
 identification numbers to generators of
 asbestos waste. Most of the commenters
 found the  requirement confusing.
 Commenters IV-D-9 and IV-D-49 stated
 that the system of using EPA
 identification numbers is confusing and
 misleading and should be subject to
 public comment rather than tacked onto
 the final version of the amendments.
 Commenter IV-D-25 wondered how the
 system is to operate and whether they
 would use the number they already have
 for hazardous waste. Commenter IV-D-
 26 was unclear as to who the generator
 would be and suggested that the
 abatement contractor be considered the
 generator. Commenter IV-D-28 thought
 that this requirement would generate a
 list of one-time generators, and that it
 should be  deferred for further study.
 Commenter IV-D-41 asked if RCRA
 hazardous waste identification numbers
 were going to be assigned to asbestos
 waste generators. As explained by
 commenter IV-D-81, not all generators
 will have an EPA identification number
 as required in § 61.150(d) fl)(i) and (4)(i).
 Commenters IV-D-62 and IV-D-63
 expressed confusion over the proposed
 identification number and urged that a
 single number be assigned to an entire
 company,  rather than to each building or
 facility. Commenter IV-D-18 asked how
 the identification numbers are to be
 determined and assigned; is it to be
 done now; and, if the program is
 delegated  to a State or local program,
 would this require a State identification
 number?
  Response: Because of the confusion
 expressed by all the commenters over
 how a system of assigning identification
 numbers to asbestos waste generators
would work, EPA has reconsidered this
revision and has decided to delete the
 requirement for an identification
number. The EPA is confident that, even
 without such a unique numbering
 system, it will be possible to track waste
 shipments for the purpose of pursuing
 enforcement actions.
 Semiannual Reports
  Comment: Commenter IV-D-4
opposed semiannual reporting by
generators or disposal sites but
recommended exception reporting by
both. Commenter IV-D-9 noted that
semiannual reporting is also redundant
in view of the Superfund Amendments
and Reauthorization Act (SARA) Title
HI regulations. Commenters IV-D-28,
IV-D-39, IV-D-41. IV-D-75, and IV-D-
83 asserted that EPA should delete the
semiannual reporting requirement in
I 61.150(d)(4) because it is redundant
since the information is also provided
on the waste tracking form and will just
add more paperwork. Commenter IV-D-
84 was concerned that small, rural
landfills will use the proposed
recordkeeping requirements as an
excuse to refuse to accept asbestos
waste, which could increase illegal
dumping. Commenter FV-D-Q4 stated
that the regulation in effect prior to the
January 10,1989, proposal should be
retained.
  Commenters IV-D-24, IV-D-61, and
IV-D-62 noted that most waste
shipment reporting now occurs on an
annual basis and that they preferred
annual to semiannual reporting.
Commenter IV-D-41 recommended that
EPA adopt the biennial reporting used
by EPA's Office of Solid Waste (OSW).
Commenter FV-D-65 stated that, if
necessary, EPA should supplement the
existing biennial RCRA report.
  Commenter IV-D-63 asserted that it is
unnecessary for the generator to submit
semiannual waste disposal reports.
Commenter IV-D-81 stated that the
proposal imposes redundant reporting
requirements on owners/operators due
to § 61.150(c)(4).
  Commenter IV-D-51 argued that
industrial landfills on site that are
subject to RCRA and State statutes
should be exempt from the reporting and
recordkeeping requirements of
§ 61.150(d). Commenter FV-D-55 stated
that § 61.150(d) does not define
adequately who keeps disposal records
•and who  submits semiannual reports.
Commenter FV-D-55 felt that building
owners are unfamiliar with the report
called for in § 61.150(d)(4).
  Response: Upon additional
consideration of this provision, EPA has
decided to omit the requirement for
semiannual reporting from today's rule.
This decision is based in part on several
comments opposing semiannual
reporting as unnecessary. In addition,
because of the large commitment of
enforcement resources that would be
required for such a system to properly
function, EPA believes that the proposal
is overly ambitious at this time. The
EPA believes, however, that
enforcement can use the available
information and adequately identify
violators by comparing the waste
records that are required to be kept by
waste generators and waste disposal
siter.. At this time, a more workable

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  48414   F«^eral 3^egfter / Vo1- 55' No- 224  / Tuesday.  November 20, 1990 /Rules  and Regulations
  solution will be to require disposal sites
  to report to EPA whenever there is a
  discrepancy between the amount of
  waste received and the amount reported
  on the waste shipment papers. The
  discrepancy report should be submitted
  to the same agency that was notified of
  the demolition or renovation and. if
  different, to the agency responsible for
  administering the NESHAP program for
  the disposal site. In addition, new and
  existing disposal sites will be required
  to comply with the general reporting
  provisions of 40 CFR part 61.
  Specifically, new disposal sites will be
  required to comply with the requirement
  to apply for approval to construct
  (§ 61.07), and the requirements to notify
  EPA of startup dates (§ 61.09). Existing
  disposal sites that will accept asbestos
  waste after the effective date of the rule
  will be required to supply EPA with
  certain information concerning their
  operations (§ 61.10). This information
  will assist enforcement in tracking
  asbestos waste.
  Excepled Waste Shipment Report
   The proposed revisions included a
 requirement for waste generators to
 indicate, as part of a semiannual report
 to the Administrator, waste shipments
 for which 35 days or more have elapsed
 since the waste was snipped without the
 waste generator having received a copy
 of the WSR signed and dated by the
 disposal site owner or operator. While
 EPA has determined that semiannual
 reports are not necessary, it considers
 this requirement a vital part of the
 asbestos waste tracking system and a
 provisions for excepted waste shipment
 reports is included in the final rule.
 Waste Conversion Processes
   Comment: Commenter IV-D-21 asked
 that procedures for sample preparation
 for TEM be clarified; that comminution
 size of particle reduction be specified;
 that the standard or interim method of
 analysis that is acceptable be identified;
 and that laboratory qualifications
 meeting requirements of the National
 Institute of Standards and Technology
 (MIST) and AHERA be identified.
  Response: Currently EPA has no
 protocol for TEM analysis of output
 materials. The final rule requires the
 owner or operator of waste conversion
 processes to submit a protocol for
 sampling and analysis by TEM  for
 approval by EPA.
 V. Administrative

  The docket is an organized and
 complete file of all the information
 considered by EPA in the development
 of this rulemaking. The docket is a
 dynamic file, since material is added
 throughout the rulemaking development
The docketing system is intended to
  allow members of the public and
  industries involved to readily identify
  and locate documents so that they can
  effectively participate in the rulemaking
  process. Along with die statement of
  basis and purpose of the proposed and
  promulgated revisions and EPA
  responses to significant comments, the
  contents of the docket, except for
  interagency review materials, will serve
  as the record in case of judicial review
  (section 307(d)(7)(A)).
   The effective date of this regulation is
  November 20,1990. Section 112 of the
  Clean Air Act provides that  standards of
  performance or revisions thereof
  become effective upon promulgation
  except that in the case of an existing
  source, the standard shall not apply
  until 90 days after its effective date.
   As prescribed by section 112, the
  promulgation of these standards was
  preceded by the Administrator's
  determination that asbestos  presents a
 significant risk to human health as a
 result of air emissions from one or more
 source categories and is therefore a
 hazardous air pollutant (36 FR 3031,
 dated March 31,1971). In accordance
 with section 117 of the Act, publication
 of these promulgated standards was
 preceded by consultation with
 appropriate advisory committees,
 independent experts, and Federal
 departments and agencies.
   Section 317 of the Clean Air Act
 requires  the Administrator to prepare an
 economic impact assessment for any
 new standard promulgated under
 section 112 of the Act. Since  the costs of
 the revision will be small, an economic
 impact assessment was not considered
 necessary for this regulation.
   Information collection requirements
 associated with this regulation (those
 included in 40 CFR part 60, subpart A
 and subpart XXX) have been approved
 by the Office of Management and
 Budget (OMB) under the provisions of
 the Paperwork Reduction Act of 1980, 44
 U.S.C. 3501 et eeq. and have been
 assigned OMB control number (2060-
 0101).
  Under Executive Order 12291, EPA is
 required to judge whether a regulation is
 a "major role" and therefore lubject to
 the requirements of * regulatory impact
 analysis (RIA). The Agency has
 determined that this regulation would
 result in none of the adverse economic
 effects set forth in section 1 of the Order
 as grounds for finding a regulation  to be
 a "major rule." The Agency has,
 therefore, concluded that this regulation
 is not a "major rule" under Executive
 Order 12291.
  The Regulatory Flexibility Act of 1980
requires the identification of potentially
adverse impacts of Federal regulations
upon small  business °ntities. The Act
  specifically requires the completion of al
  Regulatory Flexibility Analysis in those |
  instances where small business impacts \
  are possible. Because these standards
  impose no adverse economic impacts, a '
  Regulatory Flexibility Analysis has not
  been conducted.
   Pursuant to the provisions of 5 U.S.C.
  605(b), I hereby certify that this rule will |
  not have a significant economic impact
  on a substantial number of small
  entities.

  List of Subjects in 40  CFR Part 61

   Asbestos, Beryllium, Benzene,
  Hazardous substances, Mercury,
  Reporting and recordkeeping
  requirements. Vinyl chloride, Blast
  furnaces, Steel mills.
   Dated: October 29,1990.
  William K. Reilly,
  Administrator.
   40 CFR part 61 is amended as follows:

  PART SI—[AMENDED]

   1. The authority citation for 40 CFR
  part 61, subpart M, is  revised to read as
  follows:
   Authority: 42 U.S.C 7401, 7412. 7414. 7416.
  7601.

   2.-3. Section 61.140 is revised to read
  as follows:

  §61.140 Applicability.
   The provisions of this subpart are
  applicable to those sources specified in
  § 61.142 through 61.151, 61.154, and
  61.155.
   4. In i 61.141, the following definitions
 are revised: "Asbestos-containing waste
 materials," "Commercial asbestos,"
 "Demolition," "Emergency renovation
 operation," "Fabricating," "Facility,"
 "Facility component," "Friable asbestos
 materials," "Inactive waste disposal
 site," "Manufacturing." "Outside air,"
 "Particulate asbestos  material,"
 "Planned renovation operation,"
 "Remove," "Renovation," "Roadways;1
 "Strip," and "Visible emissions."
   The following definitions are added:
 "Adequately wet" "Category I
 nonfriabJe ACM." "Cutting," "Category
 II nonfriable ACM," "Fugitive sources,"
 "Glove bag," "Grinding," "In poor
•condition," "Installation," "Leak-tight,"
 "Malfunction," "Natural barrier,"
 "Nonfriable asbestos-containing
 material," "Nonscheduled renovation
 operation," "Owner or operator of a
 demolition or a renovation activity,"
 "Regulated asbestos-containing
 material," "Resilient floor covering,"
 "Waste generator," "Waste shipment
 record," and "Working day."
   The definitions, "Adequately wetted"
 and "Asbestos material," are removed.

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         Federal Register / Vol. 55, No. 224 / Tuesday, November 20.  1990 / Rules and Regulations   48415
§61.141  Definitions.
*****
  Adequately wet means sufficiently
mix or penetrate with liquid to prevent
the release of particulates. If visible
emissions are observed coming from
asbestos-containing material, then that
material has not been adequately
wetted. However, the absence of visible
emissions is not sufficient evidence of
being adequately wet.
*****
  Asbestos-containing waste materials
means mill tailings or any waste that
contains commercial asbestos and is
generated by a source subject to the
provisions of this subpart. This term
includes filters from control devices,
friable asbestos waste material, and
bags or other similar packaging
contaminated with commercial
asbestos. As applied to demolition and
renovations operations, this term also
includes regulated asbestos-containing
material waste  and materials
contaminated with asbestos including
disposable equipment and clothing.
*****
  Category I nor,friable asbestos-
containing material (ACM) means
asbestos-containing packings, gaskets.
resilient floor covering, and asphalt
roofing products containing more than 1
percent asbestos as determined using
the method specified in appendix A,
subpart F, 4O CFR part 763, section 1.
Polarized Light Microscopy.
  Category II nonfriable ACM means
any material, excluding Category 1
nonfriable ACM, containing more than 1
percent asbestos as determined using
the methods specified in appendix A,
subpart F, 40 CFR part 763, section 1,
Polarized Light Microscopy that, when
dry, cannot  be crumbled, pulverized, or
reduced to powder by hand pressure.
  Commercial asbestos means any
material containing asbestos that is
extracted from ore and has value
because  of its asbestos content.
   Cutting means to penetrate with a
sharp-edged instrument and includes
sawing, but does not include shearing,
slicing, or punching.
   Demolition means the wrecking or
taking out of any load-supporting
structural member of a facility together
with any related handling operations or
the intentional burning of any facility.
   Emergency renovation operation
means a renovation operation that was
not planned but results from a sudden,
unexpected event that, if not
immediately attended to, presents a
safety or public health hazard, is
necessary to protect equipment from
damage, or  is necessary to avoid
imposing an unreasonable financial
burden. This term includes operations
necessitated by nonrourine failures of
equipment.
  Fabricating means any processing
(e.g., cutting, sawing, drilling) of a
manufactured product that contains
commercial asbestos, with the exception
of processing at temporary sites (field
fabricating) for the construction or
restoration of facilities. In the case of
friction products, fabricating includes
bonding, debonding, grinding, sawing.
drilling, or other similar operations
performed as part of fabricating.
  Facility means any institutional,
commercial, public, industrial, or
residential structure, installation, or
building (including any structure,
installation, or building containing
condominiums or individual dwelling
units operated as a residential
cooperative, but excluding residential
buildings having four or fewer dwelling
units); any ship; and any active or
inactive waste disposal site. For
purposes of this definition, any building,
structure, or installation that contains a
loft used as a dwelling is not considered
a residential structure, installation, or
building. Any  structure, installation or
building that was previously subject to
this subpart is not excluded, regardless
of its current use or function.
  Facility component means any part of
a facility including equipment.
  Friable asbestos material means any
material containing more than 1 percent
asbestos as determined using the
method specified in appendix A, subpart
F, 40 CFR part 763 section 1, Polarized
Light Microscopy, that, when dry, can  be
crumbled, pulverized, or reduced to
powder by hand pressure. If the
asbestos content is less than 10 percent
as determined by a method other than
point counting by polarized light
microscopy [PLM), verify the asbestos
content by point counting using PLM.
   Fugitive source means any source of
emissions not controlled by an air
pollution control device.
   Glove bag means a sealed
compartment with attached inner gloves
used for the handling of asbestos-
containing materials, properly installed
 and used, glove bags provide a small
work area enclosure typically used for
 small-scale asbestos stripping
 operations. Information on glove-bag
 installation, equipment and supplies,
 and work practices is contained in the
 Occupational Safety and Health
 Administration's (OSHA's) final rule on
 occupational  exposure to asbestos
 (appendix G to 29 CFR 1926.58).
   Grinding means to reduce to powder
 or small fragments and includes
 mechanical chipping or drilling.
  In poor condition means the binding
of the material is losing its integrity as
indicated by peeling, cracking, or
crumbling of the material.
  Inactive waste disposal site means
any disposal site or portion of it where
additional asbestos-containing waste
material has not been deposited within
the past year.
  Installation means any building or
structure or any group of buildings or
structures at a single demolition or
renovation site that are under the
control of the same owner or operator
(or owner or operator under common
control).
  Leak-tight means that  solids or liquids
cannot escape or spill out It also means
dust-tight.
  Malfunction means  any sudden and
unavoidable failure of air pollution
control equipment or process equipment
or of a process to operate in a normal or
usual manner so that emissions of
asbestos are increased. Failures of
equipment shall not be considered
malfunctions if they are  caused in any
way by poor maintenance, careless
operation, or any other preventable
upset conditions, equipment breakdown,
or process failure.
  Manufacturing means the combining
of commercial asbestos—or, in the case
of woven friction products, the
combining of textiles containing
commercial asbestos—with any other
material(s). including commercial
asbestos, and the processing of this
combination into a product. Chlorine
production is considered a part of
manufacturing.
   Natural barrier means a natural
object that effectively precludes or
 deters access. Natural barriers include
physical obstacles such as cliffs, lakes
 or other large bodies of water, deep and
 wide ravines, and mountains.
Remoteness by itself is not a natural
 barrier.
   Nonfriable asbestos-containing
material means any material containing
 more than 1 percent asbestos as
 determined using the method specified
. in appendix A, subpart  F, 40 CFR part
 763, section 1, Polarized Light
 Microscopy, that, when dry, cannot be
crumbled, pulverized, or reduced to
 powder by hand pressure.
   Nonscheduled renovation operation
 means a renovation operation
 necessitated by the routine failure of
 equipment, which is expected to occur
 within a given period based on past
 operating experience, but for which an
 exact date cannot be predicted.
    Outside air means  the air outside
 buildings and structures, including, but

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 48416    Federal Register / Vol.  55,, No. 224 / Tuesday,.November' 20. '1990 / Rules  and Regulations
 not limited to, the air under a bridgs or
 in an open air ferry dock.
   Owner or operator of a demolition or
 renovation activity means any person
 who owns, leases, operates, controls, or
 supervises the facility being demolished
 or renovated or any person who owns,
 leases, operates, controls, or supervises
 the demolition or renovation operation,
 or both.
   Particulate asbestos material means
 finely divided particles of asbestos or
 material containing asbestos.
   Planned renovation operations means
 a renovation operation, or a number of
 such operations, in which some RACM
 will be removed or stripped within a
 given period of time and that can be
 predicted. Individual nonscheduled
 operations are included if a number of
 such operations can be predicted to
 occur during a given period of time
 based on operating experience.
   Regulated asbestos-containing
 material (RACM) means (a) Friable
 asbestos material, (b) Category I
 nonfriable ACM that has  become
 friable, (c) Category I nonfriable ACM
 that will be or has been subjected to
 sanding, grinding, cutting, or abrading,
 or (d) Category II nonfriabla ACM that
 has a high probability of becoming or
 has become crumbled, pulverized, or
 reduced to powder by the forces
 expected to act on the material in the
 course of demolition or renovation
 operations regulated by this subpart.
  Remove means to take out RACM or
 facility components  that contain or are
 covered with RACM from any facility.
  Renovation means altering a facility
 or one or more facility components in
 any way, including the stripping or
 removal of RACM from a  facility
 component. Operations in which load-
 supporting structural members are
 wrecked or taken out are demolitions.
  Resilient floor covering means
 asbestos-containing floor tile, including
 asphalt  and vinyl floor tile, and sheet
vinyl floor covering containing more
 than 1 percent asbestos as determined
using polarized light microscopy
according to the method specified in
appendix A, subpart F, 40 CFR part 763,
Section  1, Polarized Light Microscopy.
   Roadways means surfaces on which
 vehicles travel. This term includes
 public and private highways, roads,
 streets, parking areas, and driveways.
   Strip means to take off RACM from
 any part of a facility or facility
 components.
 *****
   Visible emissions means any
 emissions, which are visually detectable
 without the aid of instruments, coming
 from RACM or asbestos-containing
 waste material, or from any asbestos
 milling, manufacturing, or fabricating
 operation. This does not include
 condensed, uncombined water vapor.
   Waste generator means any owner or
 operator of a source covered by this
 subpart whose act or process produces
 asbestos-containing waste material.
   Waste shipment record means the
 shipping document, required to be
 originated and signed by the waste
 generator, used to track and
 substantiate the disposition of asbestos-
 containing waste material.
   Working day means Monday through
 Friday and includes holidays that fall on
 any of the days Monday through Friday.
   5. Section 61.142 is revised to read as
 follows:

 §61.142  Standard for asbestos mills.
   (a) Each owner or operator of an
 asbestos mill shall either discharge no
 visible emissions to the outside air from
 that asbestos mill, including fugitive
 sources, or use the methods specified by
 § 61.152 to clean emissions containing
 particulate asbestos material before
 they escape to, or are vented to, the
 outside air.
   (b) Each owner or operator of an
 asbestos mill shall  meet the following
 requirements:
   (1) Monitor each potential source of
 asbestos emissions from any part of the
 mill facility, including air cleaning
 devices, process equipment, and
 buildings that house equipment for
material processing and handling, at
least once each day, during daylight
hours, for visible emissions to the
outside air during periods of operation.
The monitoring shall be by visual
 observation of at least 15 seconds
 duration per source of emissions.

   (2} Inspect each air cleaning device at j
 least once each week for proper
 operation and for changes that signal
 the potential for malfunction, including,
 to the maximum extent possible without |
 dismantling other than opening the
 device, the presence of tears, holes, and
 abrasions in filter bags and for dust
 deposits on the clean side of bags. For
 air cleaning devices that cannot be
 inspected on a weekly basis according
 to this paragraph, submit to the
 Administrator, and revise as necessary,
 a written maintenance plan to include,
 at a minimum, the following:

  (i) Maintenance schedule.
  (ii) Recordkeeping plan.
  (3) Maintain records of the results of
 visible emissions monitoring and air
 cleaning device inspections using a
 format similar to that shown in Figures 1
 and 2 and include the following:
  (i) Date and time of each inspection.
  (ii) Presence or absence of visible
 emissions.
  (iii) Condition of fabric filters,
 including presence of any tears,  holes,
 and abrasions.
  (iv) Presence  of dust deposits on clean
 side of fabric filters.
  (v) Brief description of corrective
 actions taken, including date and time.
  (vi) Daily hours of operation for each
 air cleaning device.
  (4) Furnish upon request, and make
 available at the affected facility during
 normal business hours for inspection by
 the Administrator, all records required
 under this section.
  (5) Retain a copy of all monitoring and
 inspection records for at least 2 years.
  (6) Submit quarterly a copy of visible
emission monitoring records to the
Administrator if visible emissions
occurred during the report period.
Quarterly reports shall be postmarked
by the 30th  day  following the end of the
calendar quarter.

BfLUNO CODE CS60-60-M

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Federal Register / Vol. 55, No. 224 / Tuesday, November 20,1990 / Rules and Regulations     48417
Date of
inspection
(mo/day/yr)







Time of
inspection
(a.m. /p.m. )







Air
cleaning
device or
fugitive
source
designation
or number







Visible
emissions
observed
(yes/no),
corrective
action
taken







Daily
operating
hours







•|
i
Inspector's
initials







           Figure 1.   Record of Visible Emission Monitoring

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48418    Federal Register / Vol. 55. No. 224 / Tuesday. November 20,1990 / Rules and Regulations
    1.   Air cleaning aevice designation or number

    2.   Date of inspection          	   	

    3.   Time of inspection
    4.   Is  air cleaning device operating
        properly (yes/no)
    5.   Tears,  holes,  or abrasions
        in  fabric filter (yes/no)
    6.   Dust  on clean side of fabric filters
        (yes/no)                     	

    7.   Other signs of malfunctions or
        potential  malfunctions (yes/no)
   8.  Describe  other malfunctions or signs of potential malfunctions.
   9.  Describe  corrective action(s) taken.
  10.  Date and time  corrective
       action taken

  11.  Inspected by
         (Print/Type Name)
(Title)
(Signature)
(Date)
         (Print/Type Name)
(Title)-
(Signature)
(Date)
                Figure 2.  Air Cleaning  Device Inspection Checklist
Biuma CODE tsso-so-c

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          Federal Register /  Vol.  55.  No. 224  / Tuesday. November 20,  1990 / Rules and Regulations   4&41S
   6. Section 61.143 is revised to read as
 follows:

 §61.143  Standard for roadways.
   No person may construct or maintain
 a roadway with asbestos tailings or
 asbestos-containing waste material on
 that roadway, unless, for asbestos
 tailings.
   (a) It is a temporary roadway on an
 area of asbestos ore deposits (asbestos
 mine):.or
   (b) It is a temporary roadway at an
 active asbestos  mill site and is
 encapsulated with a resinous or
 bituminous binder. The encapsulated
 road surface must be maintained at a
 minimum frequency of one per year to
 prevent dust emissions; or
   (c) It is encapsulated in asphalt
 concrete meeting the specifications
 contained in section 401 of Standard
 Specifications for Construction of Roads
 and Bridges on Federal Highway
 Projects. FP-85,1985. or their equivalent.
   7. In § 61.144, paragraph (a)(9) and
 paragraphs (b) (1) and (2) are revised.
 and paragraphs  (b)(3) through (b}(8j are
 added to read as follows:

 § 61.144  Standards for manufacturing.
   (a)
   (9) The manufacture of chlorine
 utilizing asbestos diaphragm technology.
 *****
   (b)
   (1) Discharge no visible emissions to
 the outside air from these operations or
 from any building or structure in which
 they are conducted or from any other
 fugitive sources; or
   (2) Use the methods specified by
 § 61.152 to clean emissions from these
 operations containing particulate
 asbestos material before they escape to,
 or are vented to, the outside air.
   (3) Monitor each potential source of
 asbestos emissions from any part of the
 manufacturing facility, including air
 cleaning devices, process equipment,
 and buildings housing material
 processing and handling equipment, at
 least once each day during daylight
 hours for visible emissions to the
 outside air during periods of operation.
 The monitoring shall be visual
 observation of at least 15 seconds
 duration per source of emissions.
   (4) Inspect each air cleaning device at
 least once each week for proper
 operation and for changes that signal
 the potential for  malfunctions, including,
 to the maximum extent possible without
 dismantling other than opening the
 device, the presence of tears, holes, and
 abrasions in filter bags and for dust
 deposits on the clean side of bags. For
air cleaning devices that cannot be
inspected on a weekly basis according
 to this paragraph, submit to the
 Administrator, and revise as necessary,
 a written maintenance plan to include,
 at a minimum, the following:
  (i) Maintenance schedule.
  (ii) Recordkeeping plan.
  (5)  Maintain records of the results of
 visible emission monitoring and air
 cleaning device inspections using a
 format similar to that shown in Figures 1
 and 2 and include the following.
  (i) Date and time of each inspection.
  (ii) Presence or absence of visible
 emissions.
  (iii) Condition of fabric filters,
 including presence of any tears, holes
 and abrasions.
  (iv) Presence of dust deposits on clean
 side of fabric filters.
  (v)  Brief description of corrective
 actions taken, including date and time.
  (vi) Daily hours of operation for each
 air cleaning device.
  (6)  Furnish upon request, and make
 available at the affected facility during
 normal business hours  for inspection by
 the Administrator, all records required
 under this section.
  (7) Retain a copy of all monitoring and
 inspection records for at least 2 years.
  (8) Submit quarterly a copy of the
 visible emission monitoring records to
 the Administrator if visible emissions
 occurred during the report period.
 Quarterly reports shall be postmarked
 by the 30th day following the end of the
 calendar quarter.
  8. Sections 61.146 and 61.147 are
 removed, and § 61.145 is revised to read
 as follows:

 §61.145  Standard for demolition and
 renovation.
  (a) Applicability. To determine which
 requirements of paragraphs (a), (b), and
 (c) of this section apply to the owner or
 operator of a  demolition or renovation
 activity and prior to the commencement
 of the demolition or renovation,
 thoroughly inspect the affected facility
 or part of the facility where the
 demolition or renovation operation will
 occur for the presence of asbestos,
 including Category I and Category n
nonfnable ACM. The requirements of
 paragraphs (b) and (c) of this section
 apply to each owner or operator of a. .
 demolition or renovation activity,
 including the removal of RACM as
follows:
  (1) In a facility being demolished, all
 the requirements of paragraphs (b) and
 (c) of  this section apply, except as
provided in paragraph (a)(3) of this
section, if the combined amount of
RACM is
  (i) At least 80 linear meters (260 linear
feet) on pipes or at least 15 square
meters (160 square feet) on other facility
components, or
  (ii) At least 1 cubic meter (35 cubic
feet) off facility components where the
length or area  could not be measured
previously.
  (2) In a facility being demolished, or.ly
the notification requirements of
paragraphs (b)(l), (2), (3)(i) and (iv), and
(4)(i) through (viij and (4)(ix) and (xvi) oi
this section apply, if the combined
amount of RACM is
  (i) Less than 80 linear meters (260
linear feet) on pipes less than 15 square?
meters (160 square feet) on other facility
components, and
  (ii) Less than one cubic meter (35
cubic feet)  off facility components
where the length or area could not be
measured previously or there is no
asbestos.
  (3) If the facility is being demolished
under an order of a State or local
government agency, issued because the
facility is structurally unsound and in
danger of imminent collapse, only the
requirements of paragraphs (b)(l), (b)(2).
(b)(3)(iii), (b)(4) (except (b)(4)(viii)),
(b)(5), and  (c)(4) through (c)(9) of this
section  apply.
  (4) In a facility being renovated,
including any individual nonscheduled
renovation operation, all the
requirements of paragraphs (b) and (c)
of this section apply if the combined
amount of RACM to be stripped,
removed, dislodged, cut, drilled, or
similarly disturbed is
  (i) At least 80 linear meters (260 linear
feet) on pipes or at least 15 square
meters (160 square feet) on other facility
components, or
  (ii) At least I cubic meter (35 cubic
feet) off facility components where the
length or area  could not be measured
previously.
  (iii) To determine whether paragraph
(a)(4) of this section applies to planned
renovation operations involving
individual nonscheduled operations,  *
predict the combined additive amount of
RACM to be removed or stripped during
a calendar  year of January 1 through
December 31.
  (iv) To determine whether paragraph
(a)(4) of this section applies to
emergency renovation operations,
estimate the combined amount of RACM
to be removed or stripped as a result of
the  sudden, unexpected event that
necessitated the renovation.
  (5)'Ownere or operators of demolition
and renovation operations are exempt
from the requirements of §§ 61.05(a),
61.07, and 61.09.
  (b) Notification requirements. Each
owner or operator of a demolition or

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 48420    Federal Register  /  Vol. 55. No. 224  /  Tuesday. November 20, 1990 / Rules and Regulations
 renovation activity to which this section
 applies shall:
   (1) Provide the Administrator with
 written notice of intention to demolish
 or renovate. Delivery of the notice by
 U.S. Postal Service, commercial delivery
 service, or hand delivery is acceptable.
   (2) Update notice, as necessary,
 including when the amount of asbestos
 affected changes by at least 20 percent.
   (3} Postmark or deliver the notice as
 follows:
   (i) At least 10 working da>s before
 asbestos stripping or removal work or
 any other activity begins (such as site
 preparation that would break up,
 dislodge or similarly disturb asbestos
 material), if the operation is described in
 paragraphs (a) (1) and (4j (except
 (a)(4)(iii) and (a)(4)(iv)} of this section. If
 the operation is as described in
 paragraph (a)(2) of this section,
 notification is required 10 working days
 before demolition begins.
   (ii) At least 10 working days before
 the end of the calendar year preceding
 the year for which notice is being given
 for renovations described in paragraph
 (a)(4)(iii) of this section.
   (iii) As early as possible before, but
 not later tnan. the following working
 day  if the operation is a demolition
 ordered according to paragraph (e)(3) of
 this section or, if the operation is a
 re-novation described in paragraph
 (a)(4)(iv) of this section.
   (iv) For asbestos stripping or removal
 work in a demolition or renovation
 operation, described in paragraphs (a)
 (1) and (4) {except (a)(4}(iii} and
 (a)(4}{iv)} of this section, and for a
 demolition described in paragraph (a)(2)
 of this section, that will begin on a date
 other than the one contained in the
 original notice, notice of the new start
 date must be provided to the
 Administrator as follows:
  (A) When the asbestos stripping or
 removal operation or demolition
 operation covered by this paragraph will
 begin after the date contained in the
 notice,
  (7) Notify the Administrator of the
 new start date by telephone as soon as
 possible before the original start date,
 and
  (2) Provide the Administrator with a
 written notice of the new start date as
 soon as possible before, and no later
 than, the original start date. Delivery of
 the updated notice by the U.S. Postal
 Service, commercial delivery service, or
hand delivery is acceptable.
  (B) When the asbestos stripping or
removal operation or demolition
operation covered by this paragraph will
begin on a date earlier than the original
start date,
   (j) Provide the Administrator with a
 written notice of the new start date at
 least 10 working days before asbestos
 stripping or removal work begins.
   (2) For demolitions covered by
 paragraph (a)(2) of this section,  provide
 the Administrator written notice of a
 new start date at least 10 working days
 before commencement of demolition.
 Delivery of updated notice by U.S.
 Postal Service, commercial delivery
. service, or hand delivery is acceptable.
   (C) In no event shall an operation
 covered by this paragraph begin on a
 date other than the date contained in the
 written notice of the new start date.
   (4) Include the following in the notice:
   (i) An indication of whether the notice
 is the original or a revised notification.
   (ii) Name, address, and telephone
 number of both the facility owner and
 operator and the asbestos removal
 contractor owner or operator.
   (iii) Type of operation: demolition or
 renovation.
   (iv) Description of the facility or
 affected part of the facility including the
 size (square meters [square feet] and
 number of floors), age, and present and
 prior use of the facility.
   (v) Procedure, including analytical
 methods, employed to detect the
 presence of RACM and Category 1 and
 Category II nonfriable ACM.
   (vi) Estimate of the approximate
 amount of RACM to be removed from
 the facility in terms of length of pipe in
linear meters (linear feet), surface area
in square meters (square feet) on other
facility components, or volume in cubic
meters (cubic feet) if off the facility
components. Also, estimate the
approximate amount of Category I and
Category II ncnfriable ACM in die
affected part of the facility that will not
be removed before demolition.
   {vi)) Location and street address
(including building number or name and
floor or room number, if appropriate),
city, county, and state, of the facility
being demolished or renovated
   (viii) Scheduled starting and
completion dates of asbestos removal
work (or any other activity, such as site
preparation that would break up,
dislodge, or similarly disturb asbestos
material) in a demolition or renovation;'
planned renovation operations involving
individual nonscheduled operations
shall only include the beginning  and
ending dates of the report period as
described in paragraph (a)(4)(iii) of this
section.
  (ix) Scheduled starting and
completion dates of demolition or
renovation.
  (x) Description of planned demolition
or renovation work to be performed and
method(s) to be employee! including
demolition or renovation techniques to
be used and description of affected
facility components.
   (xi) Description of work practices'and
engineering controls to be used to
comply with the requirements of this
subpart, including asbestos removal and
waste-handling emission control
procedures.
   (xii) Name and location of the waste
disposal site where the asbestos-
containing waste material will be
deposited.
   (xiii) A certification that at least one
person trained as required by paragraph
(c)(8) of this section will supervise the
stripping and removal described by this
notification. This requirement shall
become effective 1 year after
promulgation of this regulation.
   (xiv) For facilities described in
paragraph (a)(3) of this section, the
name, title, and authority of the State or
local government representative who
has ordered the demolition, the date that
the order was issued, and the date on •
which the demolition was ordered to
begin. A copy of the order shall be
attached to the notification.
   (xv) For emergency renovations
described in paragraph (a)(4)(iv) of this
section, the date and hour that the
emergency occurred, a description of the
sudden, unexpected event, and an
explanation of how the event caused an
unsafe condition, or would cause
equipment damage or an unreasonable
financial burden.
   (xvi) Description of procedures to be
followed in the event that unexpected
RACM is found or Category II nonfriable
ACM becomes crumbled, pulverized, or
reduced to powder.
   (xvii) Name, address, and telephone
number of the waste transporter.
   (5) The information required in
paragraph (b)(4) of this section must be
reported using a form similiar to that
shown in Figure 3.
  (c) Procedures for asbestos emission
control. Each owner or operator of a
demolition or renovation activity to
whom this paragraph applies, according
to paragraph (a) of this section, shall
comply with die following procedures:
  (1) Remove all RACM from a facility
being demolished or renovated before
any activity begins that would break up,
dislodge, or similarly disturb the
material or preclude access to the
material for subsequent removal. RACM
need not be removed before demolition
if:                        .    '  ..  '
  (i) It is Category I nonfriable ACM
that is not in poor condition and is not
friable.
  (ii) It is on a facility component that is
encased in concrete or other similarly

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          Federal Register / Vol. 55, No.  224 / Tuesday. November 20,  1990 / Rules and Regulations    48421
 hard material and is adequately wet
 whenever exposed during demolition; or
   (iii) It was not accessible for testing
 and was, therefore, not discovered until
 after demolition began and, as a result
 of the demolition, the material cannot be
 safely removed. If not removed for
 safety reasons, the exposed RACM and
 any asbestos-contaminated debris must
 be treated as asbestos-containing waste
 material and adequately wet at all times
 until disposed of.
   (iv) They are Category II nonfriable
 ACM and the probability is low that the
 materials will become crumbled,
 pulverized, or reduced to powder during
 demolition.
   (2) When a facility component that
 contains, is covered with, or is coated
 with RACM is~being taken out of the
 facility  as a unit or in sections:
   (i) Adequately wet all RACM exposed
 during cutting or disjoining operations;
 and
   (ii) Carefully lower each unit or
 section  to the floor and to ground level,
 not dropping, throwing, sliding, or
 otherwise damaging or disturbing the
 RACM.
   (3) When RACM is stripped from a
 facility  component while it remains in
 place in the facility, adequately wet the
 RACM during the stripping operation.
   (i) In renovation operations, wetting is
 not required if:
   (A) The owner or operator has
 obtained prior written approval from the
 Administrator based on a written
 application that wetting to comply with
 this paragraph would unavoidably
 damage equipment or present a safety
 hazard;  and
   (B) The owner or operator uses of the
 following emission control methods:   '
   (1) A local exhaust ventilation and
 collection system designed and operated
 to capture the particulate asbestos
 material produced  by the stripping and
 removal of the asbestos materials. The
 system must exhibit no visible emissions
 to the outside air or be designed and
 operated in accordance with the
 requirements in § 61.152.
   (2) A glove-bag system designed and
 operated to contain the particulate  .
 asbestos material produced by the
 stripping of the asbestos materials.
   (3) Leak-tight wrapping to contain all
RACM prior to dismantlement.
   (ii) In  renovation operations where
wetting  would result in equipment
damage or a safety hazard, and the
methods allowed in paragraph (c)(3)(i)
of this section cannot be used, another
method  may be used after obtaining
written approval from the Administrator
 based upon a determination that it is
 equivalent to wetting in controlling
 emissions or to the methods allowed in
 paragraph (c)(3)(i) of this section.
   {iii) A copy of the Administrator's
 written approval shall be kept at the
 worksite and made available for
 inspection.
   (4) After a facility component covered
 with, coated with, or containing RACM
 has been taken out of the facility as a
 unit or in sections pursuant to paragraph
 (c)(2) of this section, it shall be stripped
 or contained in leak-tight wrapping,
 except as described in paragraph (c)(5)
 of this section. If stripped, either:
   (i) Adequately wet the RACM during
 stripping; or
   (ii) Use a local exhaust ventilation
 and collection system designed and
 operated to capture the particulate
 asbestos material produced by the
 stripping. The system must exhibit no
 visible emissions to the outside air or be
 designed and operated in accordance
 with the requirements in 5 61.152.
   (5) For large facility components such
 as reactor vessels, large tanks, and
 steam generators, but not beams (which
 must be handled in accordance with
 paragraphs (c)(2), (3), and (4) of this
 section), the RACM is not required to be
 stripped if the following requirements
 are met:
   (i) The component is removed,
 transported, stored, disposed of, or
 reused without disturbing or damaging
 the RACM.
   (ii) The component is encased in a
 leak-tight wrapping.
   (iii) The leak-tight wrapping is labeled
 according to § 61.149(d)(l)(i), (ii), and
 (iii) during all loading and unloading
 operations  and during storage.
   (6) For all RACM, including material
 that has been removed or stripped:
   (i) Adequately wet the material and
 ensure that it remains wet until
 collected and contained or treated in
 preparation for disposal in accordance
 with § 61.150; and
   (ii) Carefully lower the material to the
 ground and floor, not dropping,
 throwing, sliding, or otherwise damaging
 or disturbing the material.
   (iii) Transport the material to the
 ground via leak-tight chutes or
 containers if it has been removed or
 stripped more than 50 feet above ground
 level and was not removed as units or in
 sections.
   (iv) RACM contained in leak-tight
wrapping that has been removed in
 accordance with paragraphs (c)(4)  and
 (c)(3)(i)(B)(3) of this section  need not be
wetted.
  (7) When the temperature at the point
of wetting is below 0 °C (32 °F):
  (i) The owner or operator need not
comply with paragraph (c)(2)(i) and the
wetting provisions of paragraph (c)(3) of
this section.
  (ii) The owner or operator shall
remove facility components containing.
coated with, or covered with RACM as
units or in sections to the maximum
extent possible.
  (iii) During periods when wetting
operations are suspended due to
freezing temperatures, the owner or
operator must record the temperature in
the area containing the facility
components at the beginning, middle,
and end of each workday and keep daily
temperature records available for
inspection by the Administrator during
normal business hours at the demolition
or renovation site. The owner or
operator shall retain  the temperature
records for at least 2  years.
  (8) Effective 1 year after promulgation
of this regulation, no  RACM shall be
stripped, removed, or otherwise handled
or disturbed at a facility regulated by
this section unless at least one on-site
representative,  such as a foreman or
management-level person or other
authorized representative, trained in the
provisions of this regulation and the
means of complying with them, is
present. Every 2 years, the trained on-
site individual shall receive refresher
training in the provisions of this
regulation. The required training shall
include as a minimum: applicability;
notifications; material identification:
control procedures for removals
including, at least, wetting, local exhausl
ventilation, negative pressure
enclosures, glove-bag procedures, and
High Efficiency Particulate Air (HEPA)
filters; waste disposal work practices;
reporting and recordkeeping; and
asbestos hazards and worker protection.
Evidence that the required training has
been completed shall be posted and
made available for inspection by the
Administrator at the demolition or
renovation site.
  (9) For facilities described in
paragraph (a)(3) of this section,
adequately wet the portion of the
facility that contains RACM during the
wrecking operation.
  (10) If a facility is demolished by
intentional burning, all RACM including
Category I and Category II nonfriable
ACM must be removed  in accordance
with the NESHAP before burning.
BILLING CODE 6560-50-M

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48422      Federal Register / Vol. 55, No. 224 / Tuesday, November 20,1990 / Rules and Regulations
                              HOTIFICATION OF DEMOLITION AND  RENOVATION
  Operator  Project *
Postmark
                                                         Date Received
                                                                                   Notification  t
       TYPE  OF NOTIFICATION <  O-Originsi  ft-Revised  C-Cancelled
  II.  FACILITY INFORMATION  ( Identify owner, removal contractor,  and other operator
   OWNER NAME:
    Addressi
    Cityi
                                                    Statet
                                                                      Zip i
    Contact t
                                                                      Tell
   REMOVAL CONTRACTOR:
    AOdrecsi
    City:
                                                    Statet
    Cor, t art.
                                                                      Zipi
                                                                     Tell
   OTHER OPERATOR:
    Addressi
    CitV!
                                                    Statei
    Com act i
                                                                      Zipi
                                                                     Tell
  III. TYPE OF OPERATION c  D-D-iao  0-Crdered Demo  R-Renovation  B-Kroer.Renovation  li
  IV. IS ASBESTOS PRESENT?  ( ¥es/Ho
 V.   FACILITY DESCRIPTION  ( Include building name, number and floor or TOOK muter )
    Bldg Has*:
    Addresci
    City i
                                                    Statei
                                                                     Countyi
    Site Locationi
    Building S^zei
                                     t of  Floorsi
                                                                     Age in Yearni
    Present Usei
                                                    Prior Usei
 VI*
                   INCI
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              Federal Register / Vol. 55. No. 224 / Tuesday, November 20,1990 / Rules and Regulations      48423
                     <~mm"^m~m        l~~m~~malmm~~l~*~*-—™*->*-*B-~m^mi^^m^mmmMm^^mmmi^mllailmls,

                          NOTIFICATION OF DEMOLITIOH AMD  HEMOVATION 
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48424    Federal Register / Vol.  55, No. 224  /  Tuesday. November 20. 1990  / Rules and Regulations
   9. Section 61.148 is redesignated as
 § 61.146 and is amended by revising
 paragraphs (a), the introductory text of
 (b), paragraph (b)(2), and paragraph (d)
 to read as follows:

 §61.146  Standard for spraying.
 *****

   (a) For spray-on application on
 buildings, structures, pipes, and
 conduits, do not use material containing
 more than 1 percent asbestos as
 determined using the method specified
 in appendix A, subpart F, 40 CFR part
 763, section 1, Polarized Light
 Microscopy, except as provided in
 paragraph (c) of this section.
   (b) For spray-on application of
 materials that contain more than 1
 percent asbestos as determined using
 the method specified in appendix A,
 subpart F, 40 CFR part 763, section 1,
 Polarized Light Microscopy, on
 equipment and machinery, except as
 provided in paragraph (c) of this  section:
 *****
  (2) Discharge no visible emissions to
 the outside air from spray-on
 application of the asbestos-containing
 material or use the methods specified by
 § 61.152 to clean emissions containing
 particulate asbestos material before
 they escape to, or are vented to, the
 outside air.
 «    *    *    *    * L  ..

  (d] Owners or operators of sources
 subject to this paragraph are exempt
 from the requirements of §§ 61.05(a),
 61.07 and 61.09.
  10. Section 61.149 is redesignated as
 § 61,147, paragraphs (b)  (1) and (2) are
 revised, and paragraphs (b)(3) through
 (b)(8) are added  to read  as follows:

 §61.147 Standard for fabricating.
 •***•*

  (b) *  * *
  (1] Discharge no visible emissions to
 the outside air from any of the
 operations or from any building or
 structure in which they are conducted or
 from any other fugitive sources; or
  (2) Use the methods specified by
 § 61.152 to clean emissions containing
 particulate asbestos material before
 they escape to, or are vented to, the
 outside air.
  (3) Monitor each potential source of
 asbestos emissions from any part of the
fabricating facility, including air
 cleaning devices, process equipment,
 and buildings that house equipment for
material processing and handling, at
 least once each day, during daylight
hours, for visible emissions to the
 outside air during periods of operation.
The monitoring shall be  by visual
observation of at least 15 seconds-
duration per source of emissions.
  (4) Inspect each air cleaning device at
least once each week for proper
operation and for changes that signal
the potential for malfunctions, including,
to the maximum extent possible without
dismantling other than opening the
device, the presence of tears, holes, and
abrasions in filter bags and for dust
deposits on the clean side of bags. For
air cleaning devices that cannot be
inspected on a weekly basis according
to this paragraph, submit to the
Administrator, and revise as necessary,
a written maintenance plan to include,
at a minimum, the following:
  (i) Maintenance schedule.
  (ii) Recordkeeping plan.
  (5) Maintain records of the results of
visible emission monitoring and air
cleaning device inspections using a
format similar to that shown in Figures 1
and 2 and include the following:
  (i) Date and time of each inspection.
  (ii) Presence or absence of visible
emissions.      .
  (iii) Condition of fabric filters,
including presence of any tears, holes,
and abrasions.'
  (iv) Presence of dust deposits on clean
side of fabric filters.
  (v) Brief description of corrective
actions taken, including date and time.
  (vi) Daily hours of operation for each
air cleaning device.
  (6) Furnish upon request and make
available at the affected facility during
normal business hours for inspection by
the Administrator,  all records required
under this section.
  (7) Retain a copy of all monitoring and
inspection records  for at least 2 years.
  (8) Submit quarterly a copy of the
visible emission monitoring records to
the Administrator if visible emissions
occurred during the report period.
Quarterly reports shall be postmarked
by the 30th day following the end of the
calendar quarter.
  11. Section 61.150 is redesignated as
§ 61.148 and revised to read as follows:

§61.148  Standard for Insulating materials.
  No owner or operator of a facility 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 section do not
apply to spray-applied insulating
materials regulated under § 61,146.
  12. Section 61.151 is redesignated as
§ 61.149 and is amended by revising
paragraphs (a), (b), introductory text of
(c), (c)(l) (ii) and (iii), and (c)(2), and
 adding new paragraphs (d) through (f) to
 read as follows:
 {61.149  Standard for waste disposal for
 asbestos mills.
 *    *    *    . *    *   \. •
   (a) Deposit all asbestos-containing
 waste material at a waste disposal site
 operated in accordance with the
 provisions of ,§ 61.154; and     ,  .  •.
   (b) Discharge no visible emissions to
 the outside air from the transfer of
 control device asbestos waste to the
 tailings conveyor, or use the methods
 specified by § 61.152 to clean emissions
 containing particulate asbestos material
 before they escape  to, or are vented to,
 the outside air. Dispose of the asbestos
 waste from control  devices in
 accordance with § 61.150(a) or
 paragraph (c) of this section; and
   (c) Discharge no visible emissions to
 the outside air during the collection,
 processing, packaging, or on-site
 transporting of any asbe'stos-containing
 waste material, or use one of the
 disposal methods specified in
 paragraphs (c) (1) or (2) of this section,
 as follows:
   (I)*''
   (ii) Discharge no  visible emissions,to
 the outside air from the wetting
 operation or use the methods specified
 by § 61.152 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),
 as determined by an appropriate
 measurement method with an accuracy
 of ± 1*C (± 2 *F). During periods when
 wetting operations  are suspended, the
 temperature must be recorded at least at
 hourly intervals, and records must be
 retained for at least 2 years in a form
 suitable for inspection.
   (2) Use an alternative emission
 control and waste treatment method
 that has received prior written approval
 by the Administrator. To obtain
 approval for an alternative method, a
 written application must be submitted to
 the Administrator demonstrating that
 the following criteria are met:
   (i) The alternative method will control
 asbestos emissions equivalent to
 currently required methods.
   (ii) The suitability of the alternative
 method for the intended application.
   (iii) The alternative method will not
 violate other regulations.
   (iv) The alternative method will not
 result in increased  water pollution, land
 pollution, or occupational hazards.
   (d) When waste is transported by
 vehicle to  a disposal site:

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           Federal  Register / Vol. 55, No. 224  / Tuesday. November  20. 1990 / Rules and Regulations   4S425
   {1} Mark vehicles used to transport
 asbestos-containing waste material
 during the loading and unloading of the
 waste so that the signs are visible. The
 markings must:
   (i) Be displayed in such a manner and
 location that a person can easily read
 the legend.
   (ii) Conform to the requirements  for 51
 cm X 36 cm (20 in X 14 in) 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
               DANGER
        ASBESTOS DUST HAZARD
  CANCER AND LUNG DISEASE HAZARD
        Authorized Personnel Only
                Notation
  2.5 cm  (1 inch) Sans Serif, Gothic or Block
  2.5 cm  (1 inch) Sans Serif, Gothic or Block
 1.9 cm (% inch) Sans Serif. Gothic or Block
            14 Point Gothic
  Spacing between any two lines must
be a least equal to the height of the
upper of the two lines,
  (2) For off-site disposal, provide a
copy of the waste shipment record.
described in paragraph (e){l) of this
section, to the disposal site owner or
operator at the same time as the
 asbestos-containing waste material is
 delivered to the disposal site.
   (e) For all asbestos-containing waste
 material transported off the facility site:
   (1) Maintain asbestos waste shipment
 records, using a form similar to that
 shown in Figure 4, and include the
 following information:
   (i) The name, address, and telephone
 number of the waste generator.
   (ii) The name and address of the local.
 State, or EPA Regional agency
 responsible for administering the
 asbestos NESHAP program.
   (iii) The quantity of the asbestos-
 containing waste material in cubic
 meters (cubic yards).
   (iv) The name and telephone number
 of the disposal site operator.
   (v) The name and physical site
 location of the disposal  site.
   (vi) The date transported.
   (vii) The name, address, and
 telephone number of the transporterfsj.
   (viii) A certification that the contents
 of this consignment are fully and
 accurately described by proper shipping
 name and are classified, packed,
 marked, and labeled, and are in all
 respects in proper condition for
 transport by highway according to
 applicable international and government
 regulations.
  (2) For waste shipments where a copy
of the waste shipment record, signed by
the owner or operator of the designated
disposal site, is not received by the
 waste generator within 35 days of the
 date the waste was accepted by the
 initial transporter, contact the
 transporter and/or the owner or
 operator of the designated disposal site
 to determine the status of the waste
 shipment.
   (3) Report in writing to the local.
 State, or EPA Regional office
 responsible for administering the
 asbestos NESHAP program for the
 waste generator if a copy of the waste
 shipment record, signed by the owner or
 operator of the designated waste
 disposal site, is not received by the
 waste generator within 45 days of the
 date the waste was accepted by the
 initial transporter. Include in the report
 the following information:
   (i) A copy of the waste shipment
 record for which a confirmation of
 delivery was not received, and
   (ii) A cover letter signed by the waste
 generator explaining the efforts taken to
 locate the asbestos waste shipment and
 the results of those efforts.
  (4) Retain a copy of all  waste
 shipment records, including a copy of
 the waste shipment record signed by the
 owner or operator of the designated
 waste disposal site, for at least 2 years.
  (f) Furnish upon request, and make
available for inspection fay the
Administrator, all records required
under this section.
WLUNG CODE CMfr-SMI

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48426     Federal Register / Vol. 55, No. 224 / Tuesday, November 20. 1990 / Rules and Regulations


Generator
Transporter |
O)
*->
•r*
I/O
to
to
0
Q.
(O
o
1. WorK site name ana mailing address Owner's name
2. Operator's name and address
3. Waste disposal site (WDS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
Owner's
telephone no*
Operator's
telephone no.
• • WDS
phone no.
agency
6. Containers
No. Type


7. Total quantity
m3 (yd3)


8. Special handling instructions and additional information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are in all
respects in proper condition for transport by highway according to
applicable international and government regulations.
Printed/typed name & title
10. Transporter 1 .(Acknowledgment of
printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/typeo name & title
Address and telephone no.
12. Discrepancy Indication space
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
- Signature
Month Day Year

13. Waste disposal site
owner or operator: Certification of receipt of asbestos materials
covered bv this manifest exceot as noted 1n item 12.
Printed/typed name & title

Signature
Month Day Year
(Continued)
                                Figure  4.   Waste  Shipment  Record

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     Federal Register /Vol. 55, No. 224 / Tuesday, November 20,1990 / Rules and Regulations    &64Z7
                                   INSTRUCTIONS

Waste Generator Section (Items 1-9)                   '•'"...

 1.   Enter the name of the facility at which asbestos waste is generated and
      the address where the facility is located.   In the appropriate spaces,
      also enter the name of the owner of the facility and the owner's phone
      number.

 2.   If a demolition or renovation, enter the name and address of the company
      and authorized agent responsible for performing the asbestos removal.
      In the appropriate spaces, also enter the phone number of the operator.

 3.   Enter the name, address, and physical site location of the waste
      disposal site (WDS) that will be receiving the asbestos materials.   In
      the appropriate spaces,  also enter the phone number of the WDS.  Enter   j
      "on-site" if the waste will be disposed of on the generator's property.

 4.   Provide the name and address of the local,  State, or EPA Regional office
      responsible for administering the asbestos NESHAP program.

•5.   Indicate the types of asbestos waste materials generated.  If from a
      demolition or renovation, Indicate the amount of asbestos that is

           -  Friable asbestos material
           -  Nonfriable asbestos material

 6.   Enter the number of containers used to transport the asbestos materials
      listed in item 5.  Also enter one of the following container codes used
      in transporting each type of asbestos material (specify any other type
      of container used if not listed below):

           DM - Metal drums, barrels
           DP - Plastic drums, barrels
           BA - 6 mil plastic bags or wrapping                           .

 7.   Enter the quantities of each type of asbestos material removed .in-units
      of cubic meters (cubic yards).

 8.   Use this space to indicate special transportation, treatment, storage
      or disposal or Bill of Lading information.  If an alternate waste
      disposal site is designated, note it here.  Emergency response
      telephone numbers or similar information may be included here.

 9.   The authorized agent of the waste generator must read and then sign
      and date this certification.  The date is the date of receipt by
      transporter.

NOTE:  The waste generator must retain a copy of this form.
                                                                   -(continued)
                        Figure 4.  Waste Shipment Record

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48428    Federal Register / Vol. 55. No. 224 / Tuesday, November 20,1990 / Rules and Regulations
        	—	—•	———__^_^^___^^^_^^^^^ff^ff^M^^m^m^^^^lffm^lmm^^^^^^
 I     Transporter Section (Items 10 & 11)
 I
      10.  & 11.   Enter name, address, and telephone number of each  transporter
                 used, if applicable.  Print or type the full name  and  title of
                 person accepting responsibility and acknowledging  receipt  of
                 materials as listed on this waste shipment  record  for  transport.
                 Enter date of receipt and signature.

      NOTE:  The transporter must retain a copy of this form.

      Disposal  Site Section {Items 12 & 13)

      12.   The authorized representative of the WOS must note  in  this space any
           discrepancy between waste described on this manifest and waste actually
           received as well as any improperly enclosed or contained waste,   Any
           rejected materials should be listed and destination of those materials
           provided.  A site that converts asbestos-containing waste material  to
           nonasbestos material is considered a WDS.

      13.  .The signature (by hand) of the authorized WOS agent  indicates
           acceptance and agreement with statements on this  manifest except as
           noted in Item 12.  The date is the date of signature  and receipt of
           shipment.

      NOTE:  The WDS must retain a completed copy of  this  forra.   The WDS ir.jst
      also send a completed copy to the operator  listed  in  itera 2.
                            Figure  4.   Waste Shipment Record
 BIUJNQ CODE «5*0-50-C

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          Federal Register  /  Vol. 55.  No. 224 / Tuesday. November 20. 1990  /  Rules and Regulations
                                                                       4842G
   13. Section 61.152 is redesignated as
 § 61.150 and is revised to read as
 follows:

 § 61.150  Standard for waste disposal for
 manufacturing, fabricating, demolition,
 renovation, and spraying operations.
   Each owner or operator of any source
 covered under the provisions .of
 §§61.144, 61.145, 61.146, and 61.147 shall
 comply with the following provisions:
   (a) Discharge no visible emissions to
 the outside air during the collection,
 processing (in'cluding incineration),
 packaging, or transporting of any
 asbestos-containing waste material
 generated by the source, or use one of
 the emission control and waste
 treatment methods specified in
 paragraphs (a) (!) through (4) of this
 section.
   (1) Adequately wet asbestos-
 containing waste material as follows:
   (i) Mix control device asbestos waste
 to form a slurry; adequately wet other
 asbestos-containing waste material; and
   (ii) Discharge no visible emissions to
 the outside air from collection, mixing,
 wetting, and handling operations, or use
 the methods specified by § 61.152 to
 clean emissions containing particulate
 asbestos 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;  or, for materials
 that will not fit into containers without
 additional breaking, put materials into
 leak-tight wrapping: and
   (iv) Label the containers or wrapped
 materials specified in  paragraph
 (a)(l)(iii) of this section using 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 (j){2) or 1926.58(k)(2)(iii).
 The labels shall be printed in letters of
 sufficient size and contrast so as to be
 readily visible and legible.
  (v) For asbestos-containing waste
 material to be transported off the facility
 site, label containers or wrapped
 materials with the name of the waste
generator and the location at which the
 waste was generated.
  (2) Process asbestos-containing waste
material into nonfriable forms as
 follows:
  (i) Form all asbestos-containing waste
 material into nonfriable pellets or other
 shapes;
  (ii) Discharge no visible emissions to
 the outside air from collection and
processing operations, including
incineration, or use the method specified
by § 61.152 to clean  emissions
containing particulate  asbestos material
 before they escape to, or are vented to,
 the outside air.
   (3) For facilities demolished where the
 RACM is not removed prior to
 demolition according to §§ 61.145(c)(l)
 (i), (ii), (iii), and (iv) or for facilities
 demolished according to § 61.145(c){9),
 adequately wet asbestos-containing
 waste material at all times after      '
 demolition and keep wet during
 handling and loading for transport to a
 disposal site. Asbestos-containing waste
 materials covered by this paragraph do
 not have to be sealed in leak-tight
 containers or wrapping but may be
 transported and disposed of in bulk.
   (4) Use an alternative emission
 control and waste treatment method
 that has received prior approval by the
 Administrator according to the
 procedure described in § 61.149(c)(2).
   (5) As applied to demolition and
 renovation, the requirements of
 paragraph (a) of this section do not
 apply to Category I nonfriable ACM
 waste and Category n nonfriable ACM
 waste that did not become crumbled,
 pulverized, or reduced to powder.
   (b) All asbestos-containing waste
 material shall be desposited as soon as
 is practical by the waste generator at:
   (1) A waste disposal site operated in
 accordance with the provisions of
 § 61.154, or
   (2) An EPA-approved site that
 converts RACM and asbestos-
 containing waste  material into
 nonasbestos (asbestos-free) material
 according to the provisions of § 61.155.
   (3) The requirements of paragraph (b)
 of this section do not apply to Category I
 nonfriable ACM that is not RACM.
   (c) Mark vehicles used to transport
 asbestos-containing waste material
 during the loading and unloading of
 waste so that the  signs are visible. The
 markings must conform to the
 requirements of f § 61.149(d)(l) (i), (ii), ,
 and  (iii).
   (d) For all asbestos-containing waste
 material transported off the facility site:
   (1) Maintain waste shipment records,
 using a form similar to that shown hi
 Figure 4, and include the following
 information:
   (i) The name, address, and telephone
 number of the waste generator.
  (ii) The name and address of the local,
 State, or EPA Regional office
 responsible for administering the
 asbestos NESHAP program.
  (iii) The approximate quantity in cubic
meters (cubic yards).
  (iv) The name and telephone number
of the disposal site operator.
  (v) The name and physical site
location of the disposal site.
  (vi) The date transported.
   (vii) The name, address, and
 telephone number of the transporter(s).
   (viii) A certification that the contents
 of this consignment are fully and
 accurately described by proper shipping
 name and are classified, packed,
 marked, and labeled, and are in all
 respects in proper condition for
 transport by highway according to
 applicable international and government
 regulations.
   (2) Provide a copy of the waste
 shipment record, described in paragraph
 (d)(l) of this section, to the disposal site
 owners or operators at ,the same time as
 the asbestos-containing waste material
 is delivered to the disposal site.
   (3) For waste shipments where a copy
• of the waste shipment record, signed by
 the owner or operator of the designated
 disposal site, is not received by the
 waste genera tor'within 35 days of the
 date the waste-was accepted by the
 initial transporter, contact the
 transporter and/or the owner or
 operator of the designated disposal site
 to determine the status of the waste
 shipment.
   (4) Report in writing  to the local,.
 State, or EPA Regional office
 responsible for administering the
 asbestos NESHAP program for the
 waste generator if a copy of the waste
 shipment record, signed by the owner or
 operator of the designated waste
 disposal site, is not received by the
 waste generator within 45 days of the
 date the waste was accepted by the
.initial transporter. Include in  the report
 the following information:
   (i) A copy of the waste shipment
 record for which a confirmation of
 delivery was not received, and
   (ii) A cover letter signed by the  waste
 generator explaining the efforts taken to
 locate the asbestos waste shipment and
 the results  of those efforts.
   (5) Retain a copy of all waste
 shipment records, including a copy of
 the waste shipment record signed by the
 owner or operator of the designated
 waste disposal site, for at least 2 years.
   (e) Furnish upon request, and make
 available for inspection by the
 Administrator, all records required
 under this section.
   14. Section 61.153 is redesignated as
 S 61.151 and is amended by revising the
 introductory text, paragraphs (a)(2),
 (a)(4), and (b)(3), and adding paragraphs
 (d) and (e) to read as follows:

 §61.151  Standard for inactive waste
disposal sites for asbestos mills and
 manufacturing and fabricating operations.
   Each owner or operator of any
 inactive waste disposal site that was
 operated by sources covered under

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Federal Register /
     224
                                                                              199° / Rules and Regulations
   §§ 61.142.61.144, or 61.147 and received
   deposits of asbestos-containing waste
   material generated by the sources, shall:
     (a) • •  •
    (2) Cover the asbestos-containing
   waste material with at least IS
   centimeters (6 inches) of compacted
   nonasbestos-containing material, and
   grow and maintain a cover of vegetation
  on the area adequate to prevent
   exposure of the asbestos-containdpg
  waste material In desert areas where
  vegetation would be difficult to
  maintain, at least 6 additional
  centimeters (3 inches) of well-graded,
  nonasbestofi crushed rock may be
  placed on top of the final cover instead
  of vegetation and maintained to prevent
  emissions; or
  *****
    (4) For inactive waste disposal sites
  for asbestos tailings, a resinous or
  petroleum-based duit suppression agent
  that effectively binds dust to control
  surface air emissions may be used
  instead of the methods in  paragraphs (a)
  (1), (2), and (3) of this section. Use the
  agent in the manner and frequency
  recommended for the particular
  asbestos tailings by the manufacturer of
  the dust suppression agent to achieve
  and maintain dust control. Obtain prior
  written approval of the Administrator to
  use other equally effective dust
  suppression agents. For purposes of this
  paragraph, any used, spent, or other
  waste oil is not considered a dust
  suppression agent.
    (b) • • •
    (3) When requesting a determination
  on whether a natural barrier adequately
  deters public access, supply information
  enabling the Administrator to determine
  whether a fence or a natural barrier
 adequately deters access by the general
 public.
  •    •    •    »  :  *
    (d) Notify the Administrator in writing
 at least 45 days prior to excavating or
 otherwise disturbing any asbestos-
 containing waste material that has been
 deposited at a waste disposal site under
 this section, and follow the procedures
 specified in the notification. If the
 excavation will begin on a date  other
 than the one contained in the original
 notice, notice of the new start date must
 be provided to the Administrator at
 least 10 working days before excavation
 begins and in no event shall excavation
 "begin earlier than the date specified in
 the original notification. Include the
 following information in the notice:
   (1) Scheduled starting and completion
 dates.
1   (2) Reason for disturbing the waste.
   (3) Procedures to be nsed to control
 emissions during the excavation.
 storage, transport, and ultimate disposal
 of the excavated asbestos-containing
 waste material. If deemed necessary, the
 Administrator may require changes in
 the emission control procedures to be
 used.
   (4) Location of any temporary storage
 site and the final disposal site.
   (e) Within 60 days of a eke becoming
 inactive and after the effective date of
 this subpart, record, in accordance with
 State law, a notation  on the deed to the
 facility property and on any other
 instrument that would normally be
 examined during a title search; this
 notation will in perpetuity notify any
 potential purchaser of the property that:
   (1) The land has been used for the
 disposal of asbestos-containing waste
 material;
   (2) The survey plot  and record of the
 location and quantity of asbestos-
 containing waste disposed of within the
 disposal site required in  § 61.154(1) have
 been filed with the Administrator; and
   (3} The site is subject to 40 CFR part
 61, fiuhpart M.
   15. Section 61.154 is redeslgnated as
 § 61.152 and amended by removing
 paragraph (a)(l){i), redesignating
 paragraphs (aj(l)[HH»v) as paragraphs
 (a)(l)(iHiii), redesignating paragraph
 (b)(2) as paragraph fb){3), revising the
 introductory text of paragraph (a) and
 paragraphs (b)(l) and (b)[3), and adding
 paragraphs (a)(3) and {bjl2) to read as
 follows:

 §61.152  AJrctearang.
   (a) The owner or operator who uses
 eir cleaning, as specified in §§ 61.142(3),
 61.144fb){2), 81 345(cH3XiXB}(2j,
 61.145{cK4Kii). 61-145(cHllKi).
 61.148(b)(2), 81.147(bM2),
61.150(aX2Hii), and 61J55{e) shall:
*    *    *    *    *
  (3) For fabric filter collection devices
installed after January 10, 1989, provide
for easy inspection for faulty bags.
  {b) - * *                  ^
  (1) After January 10, 1988. if the use of
fabric creates « fire or explosion hazard,
or the Administrator determines thai a
fabric fitter is not feasible, the
Administrator may authorize as e
substitute the use of wet collectors
designed to operate vrith  a unit
contacting energy of at least fl.55
kilopascals (40 inches water gage
pressure).
  (2) Use a HEP A fitter that n certified
to be at least 99.97 percent efficient for
0.3 micron particles.
  (3) The Administrator may authorize
the use of filtering equipment other than
described in paragraphs (a Hi 5 and (b)(l)
and (2) of this section if the owner or
operator demonstrates to the
                                                                      Administrator's satisfaction thai it is
                                                                      equivalent to the described equipment in ]
                                                                      filtering particulate asbestos material.
                                                                        16. Section 61.155 is redesignated as
                                                                      § 61.153 and amended by redesignating
                                                                      paragraphs {a)(3) and (a)(4) as
                                                                      paragraphs (a)[4) and (a)(5),
                                                                      respectively, revising the introductory
                                                                      text of paragraphs (a), (a){4), and (a)(5)
                                                                      and revising paragraphs {a)I2). (a)[4)[ii)
                                                                      and (iii), and (b), and adding paragraph
                                                                      (a)(3j to read as follows:

                                                                      §<51.iS3  flvpfflrting-
                                                                        (a) Any new source to which this
                                                                      subpart applies (with the exception of
                                                                      sources subject to iS 61.143, 61.146, and
                                                                      61.148), which has an initial startup date
                                                                      preceding the effective date of this
                                                                      revision, shall provide the following
                                                                      information to the Administrator
                                                                      postmarked or delivered within 90 days
                                                                      of the effective date. In the  case of a
                                                                      new source that does not have an initial
                                                                      startup date preceding the effective
                                                                      date, the information shall be provided,
                                                                      postmarked or delivered, within 90 days
                                                                      of the initial startup date. Any owner or
                                                                      operator of an existing source shall
                                                                      provide the following information to the
                                                                      Administrator within 90 days of the
                                                                      effective date of this subpart unless the
                                                                      owner or operator of the existing source
                                                                      h&8 previously 'provided this information
                                                                      to the Administrator. Any changes in the
                                                                      information provided by any existing
                                                                      source shall be provided to the
                                                                      Administrator, postmarked or delivered,
                                                                      within 30 days after the change.
                                                                      *****
                                                                       (2) If a fabric filter device is used to
                                                                      control emissions,
                                                                       (i) The airflow permeability in m8/
                                                                     unn/m* (rV/min/ft1) if the fabric filter
                                                                      device uses a woven fabric, and, if the
                                                                     fabric is synthetic, whether the Till yam
                                                                     is span or not spun; and
                                                                       (ii) If the fabric filter device uses a
                                                                     felted fabric, the density in g/m* (oz/
                                                                     yd2), the minimum thickness in
                                                                     millimeters (inches), and the airflow
                                                                     permeability hrm'/min/m2 (tV/min/
                                                                     ft2).
                                                                       f3) If a HEPA filter is used to control
                                                                     emissions, the certified efficiency.
                                                                       {4) For sources subject to  IS 61.149
                                                                     and 61.150:
                                                                     •    *    *    »     *
                                                                       (ii) The average volume of asbestos-
                                                                     coataining waste material disposed of,
                                                                     measured in ms/day (yds/day); and
                                                                       (in) The emission control methods
                                                                     used in all stages of waste disposal; and
                                                                     *    *   *    *     *
                                                                       {5} For sources subject to §§ 61.151
                                                                     and 61.154:

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                   Register  /  Vol.  55, No. 224  /  Tuesday, November 20, 1990  /  Rules and Regulations   4Q431
   (b) The information required by
 paragraph (a) of this section must
 accompany the information required by
 I 61.10. Active waste disposal sites
 subject to § 61.154 shall also comply
 with this provision. Roadways,
 demolition and renovation, spraying,
 end insulating materials are exempted
 fiom the requirements of § 61.10(a). The
 information described in this section
 must be reported using the format of
 Appendix A of this part as a guide.
   17. Section 61.156 is redesignated as
 § 61.154 and amended by revising the
 introductory text of § 61.154. paragraphs
 (r) and (d), and adding paragraphs (e)
 through (j} to read as follows:

 §61.154 Standard for active waste
 disposal sites.
   Each owner or operator of an active
 w aste disposal site that receives
 asbestos-containing waste material from
 a source covered under § § 61.149, 61.150.
 or 61.155 shall meet the requirements of
 thfs section:
 >     *    *    *    *
  {(.•} Rather than meet the no visible
 emission requirement  of paragraph fa) cf
 this section, at the end of each operating
 d<;. cr  at least once even- 24-hcar
 period while the site is in continuous
 opero'.ion. the asbesios-contairjng
 VNaste material that has been deposited
 at the site daring the operating day or
 previous 24-hour period shall:
  (1) Be covered with at least 15
 centimeters (6 inches) of compacted
 nonasbestos-containing material, or
  (2) Be covered with a resinous or
 petroleum-based dust  suppression agent
 that effectively binds dust and controls
 wind erosion. Such an agent shall be
 t.sed in  the manner and frequency
 recommended for the particular dust by
 the dust suppression agenf manufacturer
 to achieve and maintain dust control.
 Other equally effective dust suppression
 pgents may be used upon prior approval
 bv the Administrator. For purposes of
 this paragraph, any used, spent, or other
 waste oil is not considered a dust
 suppression agent.
  (d) Rather than meet the no visible
 emission requirement of paragraph {a} of
 this section, use an alternative
 emissions control method that has
received prior written  approval by the
Administrator according to the
procedures described in § 61.149(c)(2).
  (e) For all asbestos-containing waste
niaterial received, the owner or operator
of the active waste disposal site shall:
  (1) Maintain waste shipment records.
 using a form similar to that shown in
Figure 4, and include the following
information:
  ('} The name, address, and telephone
ruimber  of the waste generator.
   (ii) The name, address, and telephone
 number of the transporters).
   (iii) The quantity of the asbestos-
 containing waste material in cubic
 meters (cubic yards).
   (iv) The presence of improperly
 enclosed or uncovered waste, or any
 asbestos-containing waste material not
 sealed in lead-tight containers. Report in
 writing to the local. State, or EPA
 Regional office responsible for
 administering the asbestos NESHAP
 program for the waste generator
 (identified in the waste shipment
 record}, and, if different, the local. State,
 or EPA Regional office responsible for
 administering the asbestos NESHAP
 program for the disposal site, by the
 following working day, the presence of a
 significant amount of improperly
 enclosed or uncovered waste. Submit a
 copy of the waste shipment record along
 with the report
   (v) The date of the receipt
   (2) As soon as possible and no longer
 than 30 days after receipt of the waste,
 send a copy of the signed waste
 shipment record to the waste generator.
   (3) Upon discovering a discrepancy
 between the quantity of waste
 designated on the waste shipment
 records and the quantity actually
 received, attempt to reconcile the
 discrepancy with the waste generator, if
 the discrepancy is not resolved within
 15 days after receiving the waste,
 immediately report in writing to the
 local State, or EPA Regional office
 responsible for  administering the
 asbestos NESHAP program for the
 waste  generator (identified in the waste
 shipment record), and, if different, the
 local, State, or EPA Regional office
 responsible for  administering the
 asbestos NESHAP program for the
 disposal site. Describe the discrepancy
 and attempts to reconcile it and submit
 a copy of the waste shipment record
 along with the report
   (4) Retain a copy of all records and
 reports required by this paragraph for at
 least 2 years.
   (f) Maintain, until closure, records of
 the location, depth and area, and
 quantity in cubic meters (cubic yards) of
 asbestos-containing waste material
 within the disposal site on a map or
 diagram of the disposal area.
   (g) Upon closure, comply with all the
 provisions of § 61.151.
  (h) Submit to the Administrator, opon
closure of the facility, a copy of records
of asbestos waste disposal locations
and quantities.
  (i) Furnish upon request, and make
available during normal business hours
for inspection by the Administrator, all
records required under this section.
   (j) Notify the Administrator in writing
 at least 45 days prior to excavating or
 otherwise disturbing any asbestos-
 containing waste material that has been
 deposited at a waste disposal site and is
 covered, if the excavation will begin on
 a date other than the one contained in
 the original notice, notice of the new
 start date must be provided to the
 Administrator at least 10 working days
 before excavation begins and in no
 event shall excavation begin earlier than
 the date specified in the original
 notification. Include the following
 information in the notice:
   (1) Scheduled starting and completion
 dates.
   (2) Reason for disturbing the waste.
   (3) Procedures to be used to control
 emissions during the excavation,
 storage, transport, and ultimate disposal
 of the excavated asbestos-containing
 waste material. If deemed necessary, tha
 Administrator may require changes in
 the emission control procedures to be
 used.
   (4) Location of any temporary storage
 site and the final disposal site.
   18. Section 61.155 is added to s-ubpart
 M to read as follows:

 §61.155  Standard for operations thai
 convert asbesto-coniaining waste material
 into nonasbestos (asbestos-free) material.
   Each owner or operator of an
 operation that converts RACM and
 asbestos-containing waste material into
 nonasbestos (asbestos-free) material
 shall:
   (a) Obtain the prior written approval
 of the Administrator to construct the
 facility. To obtain approval, the owner
 or operator shall provide the
 Administrator with  the following
 information:
   (1) Application to construct pursuant
 to f 61.07.
   (2) In addition to the  information
 requirements of 5 61.07(b)(3). a
   (0 Description of waste feed handling
 and temporary storage.
   (ii) Description of process operating
 conditions.
   (iii) Description of the handling and
 temporary storage of the end product.
  (iv) Description of the protocol to be
followed when analyzing output
materials by transmission electron
microscopy.
  (3) Performance test protocol,
including provisions for obtaining
information required under paragraph
(b) of this  section.
  (4) The Administrator may require
that a demonstration of the process be
performed prior to approval of the
application to construct.

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 48432    Federal Register /Vol. 55, No. 224 /Tuesday, November 20,  1990 / Rules and  Regulations
   (b) Conduct a start-up performance
 test. Test results shall include:
   (1) A detailed description of the types
 and quantities of nonasbestos material,
 RACM, and asbestos-containing waste
 material processed, e.g., asbestos
 cement products, friable asbestos
 insulation, plaster, wood, plastic, wire.
 etc. Test feed is to include the full range
 of materials that will be encountered in
 actual operation of the process.
   (2) Results of analyses, using
 polarized light microscopy, that
 document the asbestos content of the
 wastes processed.
   (3) Results of analyses, using
 transmission electron microscopy, that
 document that the output materials are
 free of asbestos. Samples for analysis
 are to be collected as 8-hour composite
 samples (one 200-gram (7-ounce) sample
 per hour), beginning with the initial
 introduction of RACM or asbestos-
 containing waste material and
 continuing until the end of the
 performance test.
   (4) A description of operating
 parameters, such as temperature and
 residence time, defining the full range
 over which the process is expected to
 operate to produce nonasbestos
 (asbestos-free) materials. Specify the
 limits for each operating parameter
 within which the process will produce
 nonasbestos (asbestos-free) materials.
   (S) The length of the test.
   (c) During the initial 90 days of
 operation,
   (1) Continuously monitor and log the
 operating parameters identified during
 start-up performance tests that are
 intended to ensure the production of
 nonasbestos (asbestos-free) output
 material.
   (2) Monitor input materials to ensure
 that they are-consistent with the test
 feed materials described during start-up
 performance tests in paragraph (b)(l) of
 this section.
   (3) Collect and analyze samples, taken
 as 10-day composite samples (one 200-
 gram (7-ounce) sample collected every 8
 hours of operation) of all output material
 for the presence of asbestos. Composite
 samples may be for fewer than 10 days.
Transmission electron microscopy
 (TEM) shall be used to analyze the
output material for the presence of
asbestos. During the initial 90-day
period, all output materials must be
stored on-site until analysis shows the
material to be asbestos-free or disposed
 of as asbestos-containing waste
 material according to § 61.150.
   (d) After the initial 90 days of
 operation,
   (1) Continuously monitor and record
 the operating parameters identified
 during start-up performance testing and
 any subsequent performance testing.
 Any output produced during a period of
 deviation from the range of operating
 conditions established to ensure the
 production of nonasbestos (asbestos-
 free) output materials shall be:
   (i) Disposed of as asbestos-containing
 waste material according to § 61.150, or
   (ii) Recycled as waste feed during
 process operation within the established
 range of operating conditions, or
   (iiij Stored temporarily on-site in a
 leak-tight container until analyzed for
 asbestos content. Any product material
 that is not asbestos-free shall be either
 disposed of as asbestos-containing
 waste material or recycled as waste
 feed to the process.
   (2) Collect and analyze monthly
.composite samples (one 200-gram (7-
 ounce) sample collected every 8 hours of
 operation) of the output material.
 Transmission electron microscopy shall
 be used to analyze the output material
 for the presence of asbestos.
   (e) Discharge no visible emissions to
 the outside air from any part of the
 operation, or use the methods specified
 by § 61.152 to clean emissions
 containing particulate asbestos material
 before they escape to, or are vented to,
 the outside air.
   (f) Maintain records on-site and
 include the following information:
   (1) Results of start-up performance
 testing and all subsequent performance
 testing, including operating parameters,
 feed characteristic, and analyses of
 output materials.
   (2) Results of the composite analyses
 required during the initial 90 days of
 operation under  § 61.155(c).
   (3) Results of the monthly composite
 analyses required under § 61.155(d).
   (4) Results of continuous monitoring
 and logs of process operating
 parameters required under § 61.155 (c)
 and (d).
   (5) The information on waste
 shipments received as required in
 § 61.154(e).
   (6) For output materials where no
 analyses were performed to determine
the presence of asbestos,  record the
 name and location of the purchaser or
 disposal site to which the output
 materials were sold or deposited,, and
 the date of sale or disposal.
   (7) Retain records required by
 paragraph (f) of this section for at least 2
 years.                     •
   (g) Submit the following reports to the
 Administrator:
   (1) A report for each analysis of
 product composite samples performed
 during the initial 90 days of operation.
   (2) A quarterly report, including, the
 following information concerning
 activities during each consecutive 3-
 month period:
   (i) Results of analyses of monthly
 product composite samples.
   (ii) A  description of any deviation
 from the operating parameters
 established during performance testing
 the duration of the deviation, and steps
 taken to correct the deviation.
   (iii) Disposition of any product
 produced during a period  of deviation,
 including whether it was recycled,
 disposed of as  asbestos-containing
 waste material, or stored temporarilj
 on-site until analyzed for asbestos
 content.
   (iv)  The information on  waste
 disposal activities as required in
 § 61.154(f).
   (h) Nonasbestos (asbestos-free) output
 material is not  subject to any of the
 provisions of this subpart. Output
 materials in which asbestos is detected.
 or output materials produced when the
 operating parameters deviated from
 those established during the start-up
 performance testing, unless shown by
 TEM analysis to be asbestos-free, shall
 be considered to be asbestos-containing
 waste and shall be handled and
 disposed of according to §§ 61.150 and
 61.154 or reprocessed while all of the
 established operating parameters are
 being met.  '
  19. Section 61.156 is added to subpart
 M to read as follows:

 §61.156  Crow-reference to other
 ttbmtos regulations.
  In addition to this subpart, the
regulations referenced in Table 1 also
 apply to  asbestos and may be applicable
to those sources specified in §§ 61.142
through 61.151, 61.154, and 61.155 of this
subpart These cross-references  are
presented for the reader's information
and to  promote  compliance with the
cited regulations.

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           Federal  Register /  Vol.  55. No. 224  / Tuesday.  November 20. 1990  / Rules and Regulations    46433
  20. Section 61.157 is added to subpari
M to read as follows:

§ 61.157   Delegation of authority.
  (a) In delegating implementation and
enforcement authority to a State under
section 112(d) of the Act, the authorities
                                    contained in paragraph (b) of this
                                    section shall be retained by the
                                    Administrator and not transferred to a
                                    State.
                                      (b) Authorities that will not be
                                    delegated to States:
                                      (1) Section 61.149(c}(2)
                           (2) Section 6l.150(a)(4)
                           (3) Section 61.151(c)
                           (4) Section 61.152(b}(3)
                           (5) Section 61.154(d)
                           (6) Section 61.155(a).

                         |FR Doc. 90-26835 Filed 11-19-90; 8:45 «m]
                         BILUNO CODE «560-SO-M
                                TABLE 1.—CROSS-REFERENCE TO OTHER ASBESTOS REGULATIONS
 Agency
                                CFR citation
                                                                                                Comment
EPA
OSHA
WSHA
DOT
          40 CFR 763, Subpart E. F..
          40 CFR 427		
          40 CFR 763, Subpart G..
29 CFR 1910.1001	

29 CFR 1926.58		


30 CFR 66, Subpart D..

30 CFR 57, Subpart D..

49 CFR 171 and 172....
Requires schools to inspect lor asbestos and Implement response actions and
  submit asbestos  management plans to States.  Specifies use ot accredited
  inspectors, air sampling methods, and waste disposal procedures.
Effluent standard* (or asbestos manufacturing source categories.
Protects public  employees  performing asbestos abatement work in States not
  covered by OSHA asbestos standard.
Worker protection measures—engineering controls, worker training, labeling, respi-
  ratory protection, bagging of waste, 0.2 f/cc permissible exposure level.
Worker protection measures for all construction work Involving asbestos, Including
  demolition and renovation—work practices, worker training, bagging oi waste, 0.2
  f/cc perraissfcle exposure level.
Specifies exposures limits, engineering controls, and respiratory protection meas-
  ures for workers in surface mines.
Specifies exposure brats, engineering controls, and respiratory protection measutes
  for workers in underground mines.
Regulates the transportation of asbestos-containing waste material. Requires waste
  containment and sWpping papers.

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                 APPENDIX B
RESPIRATORY PROTECTION SELECTION CHECKLIST
                     B-l

-------
B-2

-------
     RESPIRATORY PROTECTION SELECTION CHECKLIST
NO RESPIRATORY PROTECTION REQUIRED:

Outside Containment*

             Inspection is taking place in office areas or other areas outside the
             barrier. All barrier seals are intact and all envelope entrances must
             have at least a double barrier.  No potentially asbestos-containing dust
             or debris is present on any surface in the area.
             Secondary containment is in place when glove-bagging is used. The
             secondary containment enclosure must be complete.
             Materials removed from the envelope have been cleaned and the
             pathway for removal of bags and equipment is clear and clean.
             All ventilation systems in the envelope are off and sealed.
       •     Wet methods are being used.
*If all applicable conditions above are affirmed, inspectors need not use respiratory
protection.

Inside Containment

             The restricted area has already passed an appropriate clearing test
             (minimum of aggressive sampling with a concentration below 0.01 f/cc
             by PCM); or
             No removal work has begun and all ACM is intact, undisturbed,
             undamaged and no debris is present.

 RESPIRATORY PROTECTION REQUIRED

 Air Purifying Respirators (Full-face air-purifying or PAPR) Required

 Outside Containment

             Workers are wearing air-purifying respirators; or
             The barrier is not complete; or
             Asbestos-containing debris is present.
                                     B-3

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Inside Containment

       •      The work operation is in compliance with the OSHA asbestos
             standard; or

       •      No active removal or disturbances have occurred in the previous 24-
             hour and the inspection will not disturb ACM.


Supplied Air Respirators (SCBA operated in the pressure-demand mode)

             The work operation is not in compliance with the OSHA asbestos
             standard; or

      •      Materials being removed cannot be properly wetted or removal
             generates significant amounts of dust; or

             Monitoring data show levels in excess of 2.0 f/cc and the inspection
             may last more than 2-hours; or

             Others at the site are wearing supplied-air respirators.
                                    B-4

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        APPENDIX C
FIELD INSPECTION CHECKLISTS
             C-l

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C-2

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                                  APPENDIX C-l
                                ASBESTOS NESHAP
                        DEMOLITION AND RENOVATION
                     INSPECTION EQUIPMENT CHECKLIST
General Inspection Equipment
             Employee I.D.
             Copy of regulation
             Field notebook
             Pens/pencils
             Inspection checklist
             Camera/flash (preferably waterproof)
             Waterproof flashlight
             Tape measure
             Plastic clipboard
             Duct tape
             Disposable  towels
             Plastic sheets
Safety Equipment
             Full-facepiece air-purifying negative pressure respirator
             PAPR (tight-fitting)
             SCBA (pressure demand type)
             Respirator cartridges
             Disposable full-body coveralls
             Disposable boots
             Hard hat
             Safety glasses
             Safety shoes
             Ear protection
             Asbestos waste bags (preferably 6 mil)
             Bathing suit
             Disposable towels
                                         C-3

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Sampling Equipment
             Sample containers
             Water spray bottle
             Duct tape
             Tamperproof tape
             Tools (locking blade pen knife, slotted screwdriver,
               needle-nose pliers)
             Plastic drop cloths
             Wet wipes
             Reclosable quart- and gallon-size plastic bags
             Sample labels
             Spray paint
             Shipping supplies
             Chain-of-custody forms
             Waterproof markers
             Glove bags
             Surfactant
             Bathroom caulking
                                          C-4

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         APPENDIX C-2
FACILITY INSPECTION CHECKLIST
              C-5

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C-6

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I.
               ASBESTOS DEMOLITION AND RENOVATION (D/R)
                    FIELD DATA COLLECTION CHECKLIST
GENERAL INFORMATION
Site Name:_

Location:
Date of inspection:.
Weather conditions:
Inspector(s):_
                                      Time of inspection:
Notification Received?

Reason for Inspection^
                   Yes (date):_
No:
      Routine Compliance Inspection	     Citizen complaint

      Suspected Non-notifier	    State Oversight/Joint	

      Other (explain	
II.
REMOTE OBSERVATIONS
Using the space provided, draw a sketch of the suspected abatement area. Draw the building
or other source of suspect ACM, waste storage area(s), location(s) of debris, land use
surrounding site, vehicles of importance, etc. Estimate and indicate dimensions and distances
as accurately as possible on the drawing.
                                        C-7

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                         REMOTE OBSERVATION SKETCH
                                                                         Yes    No
1.     Visible emissions to the outside air?

       If yes, describe specific location (e.g., door, window,
       waste storage area, etc.) referring to remote observation
       sketch.
                                                                         Yes    No
2.     Suspect ACM debris observed outside removal area?

       If yes, describe [e.g., location, estimated quantity,
       condition (intact? crushed? wet? dry?)]
                                         C-8

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3.     Are vehicles being used to haul suspect ACWM
       properly marked?  [61.150(c)]

4.     Land use surrounding site (i.e., residential,
       schools,  businesses, etc.):
                                                                            Yes    No
       a.      Distance to the closest residence/public
              building from the D/R site:

       b.      Number of residences or occupied buildings
              on adjacent properties or lots:

       c.      Distance to pedestrian walkway, street, or
              thoroughfare  from site:

       d.      Additional information indicating potential
              public exposure:
5.      Building/Structure Information

              Use (office, retail, industry, school, etc.):
a.
       b.
       Brief physical description of building involved in D/R (number of floors,
       dimensions, etc.):
       c.
       Year constructed:
Year(s) renovated:
                                           C-9

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       PRE-INSPECTION INTERVIEW
1.     Credentials shown:
                                                                      Yes   No
             agency identification

             medical monitoring certification           ,

      Name and position of person being interviewed (include company name):
3.    Establish identity of owner/operator(s):

      a.     Owner name:	
      b.     Main contact person and title:,

      c.     Mailing address:
                   City

      d.     Telephone number:_
State
Zip Code
                                (area code)

4.    Describe any changes/modifications/discrepancies to the information provided in the
      notification:
5.     Prime Contractor (provide the following information for each contractor related to the
      D/R job):
                 i                                            -
      a.     Company name:	
      b.     Main contact person and title:
                                       C-10

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       c.
Mailing address:.
              City

       d.     Telephone number:
       e.
                           State
                     (area code)

Contractor's responsibilities at job:
Zip Code
       f.      Number of employees involved in job: _._
       g-

       h.
Number of on-site employees trained in asbestos removal:

Name of Supervisor (if different from 5b.):
       i.      What type of asbestos training has the supervisor had?_
6.     On-site Representative
       a.
If applicable, name of on-site representative who has had required training in
the provisions of the NESHAP regulation (effective 1 year after promulgation
of the revised NESHAP):
       b.      Is evidence regarding this individual's training posted and available for
              inspection at the demo/reno site? Yes	   No	  N/A	

7.      Subcontractors [Provide the following information for each subcontractor or any other
       party onsite (e.g., hygienist, consultant, etc.) who controls or supervises the D/R
       project.]
       a.

       b.
Company name:
Main contact person and title:
                                          C-ll

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c.      Mailing address:
       City



d.     Telephone number:
                                        State
Zip Code
                           (Area Code)
e.



f.




g-
             Responsibilities at job:
             Number of employees involved in job:
             Number of on-site employees trained in asbestos removal:	




       h.     Name of supervisor:	;	•__




       i.     What type of asbestos training has the supervisor had?	




8.      Activity Description:




                                                                        Yes   No




       a.     Is more than one project occurring at the facility?              	    	;




             (If yes, complete a separate checklist for each or differentiate accordingly.)




       b.     Type of activity:




             Demolition	  Ordered Demolition	  Planned renovation	




             Nonscheduled Operation	   Emergency Renovation	




       c.     Describe the project and indicate its current phase:	
                                  C-12

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       d.     Describe type of abatement occurring (e.g., removal, encapsulation, etc.):
       e.     Abatement starting date:
IV.    SITE INSPECTION OBSERVATIONS

A.     Types of Suspect ACM

       Insulation

       Pipe insulation (felt, air cell, premolded, asbestos cement)
       Block insulation  	
       Surfacing Materials

       Plaster	  Spackling compound
Stucco
       Joint compound	 Sprayed-on (acoustical, decorative or insulative)

       Miscellaneous

       Ceiling tiles	 Acoustical tiles	

       Category I Nonfriable ACM

       Packings	  Gaskets	 Asphalt roofing products	
       Resilient floor coverings (vinyl/asbestos tile, asphalt/asbestos tile, linoleum

       Category II Nonfriable ACM

       Extrusion panels	 Clapboards/shingles	 Millboard	

       Vinyl wallpaper	  Pegboard	 Putties	

       Sealants	 Adhesives (mastics)	  Concrete/asbestos pipe	

       Paints and coatings	
                                        C-13

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B.
       Textiles (fire blankets, laboratory aprons, theater and welding curtains, gloves)	

       Laboratory benchtops	

       Other (Specify)
Quantity Determination [61.145(a)]

Complete Attachment A (Quantification of ACM) and the following:

1.     Linear footage of ACM present on pipes:	
       2.     Square footage of ACM present on other facility components:
       3.     Amount of ACM off facility components where the amount of ACM previously
             on pipes and other facility components is unknown:	

       4.     Method of measuring or estimating amount of ACM present:
                                                                  Yes   No    N/A
C.     Emission Control Procedures [61.145(c)]

       1.     Facility ordered demolished (removal not required):

             If "yes",

             a.     Governmental agency ordering demolition:
             b.     Portion of facility containing ACM adequately wet during
                    wrecking?
                                        C-14

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                                                            Yes   No    N/A
       c.
 Visible dust emissions:
 2.     Category I nonfriable ACM not in poor condition and
       not friable? (removal not required)                      	

 3.     Encased in concrete (removal not required):              	

       If "yes", adequately wetted whenever exposed during
       demolition?                                           	

 4.     ACM not  discovered until after demolition began and
       cannot be  safely removed (removal not required)         	

       If "yes", adequately wet at time of inspection?           	

 5.     Category II nonfriable with low probability of becoming
       crumbled,  pulverized or reduced to a powder during
       demolition? (removal not required)                      	

 6.     Unit/section removal:

       If "yes",

       a.      ACM adequately wet whenever exposed?	

       b.      Lowered to floor and ground level without disturbing
              ACM?                                         _

7.     Stripping in place?
       If "yes",
       a.



       b.

       c.
ACM adequately wet while being stripped and until
collected and contained or treated in preparation for
disposal?

Carefully lowered to floor or ground?            _

Transported to ground via leak-tight chutes or
containers if removed or stripped >50 feet above
ground level and not removed as units or in
sections?
                                  C-15

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                                                     Yes    No    N/A
Temperature at point of wetting below 32°F?            	

If "yes",

a.     Regulated facility components being removed as units
       or sections?                                    ^_

b.     Visible emissions to the outside air?             _

c.     Required records kept regarding cessation of
       wetting?                                       __

d.     Records available for inspection:                 	

Has the owner/operator been granted an exemption
from wetting?                                        	

a.     Reason for exemption    •	    ..
b.     Who granted the exemption?
c.     Is one of the following emission control techniques
       in use?                                         	     .

       Local exhaust ventilation and collection system    	    	

       Glove-bag system                               	    	

       Leak-tight wrapping                             	    	

       Equivalent approved method (with approval kept at
       the worksite)                                   	    	

d.     Are there visible emissions to the outside air?     	    	
                            C-16

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                                                                   Yes   No    N/A
       10.    Is the facility being demolished by intentional
              burning?

              If "yes", has all ACM (including Categories I and II) been
              removed before burning?

       11.    Is Category I nonfriable ACM being sanded, ground or
              abraded?

              If "yes",

              a.     Are visible emissions produced?

              b.     Is the ACM adequately wet?

              c.     Is a local exhaust and ventilation and collection
                    system being used?

       12.    Are large facility components being removed without
              the ACM being stripped?
             If "yes",

             a.
Is the ACM being disturbed or damaged in
any way?
             b.     Is the component encased in a leak-tight
                    wrapping labeled appropriately during all
                    loading and unloading operations and
                    during storage?

D.     Evaluation of Wetting

       1.     Is there a water or wetting agent supply?

       2.     What equipment is used to apply it?	
                                         C-17

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                                                           Yes    No    N/A
       Is water or a wetting agent observed being sprayed on
       suspect ACM during:
       a.
removal of units or sections?
       b.     stripping?

       c.     government-ordered demolitions?

       Is there visible dust (airborne or settled), or dry
       suspect ACM or ACWM debris in the immediate vicinity
       of the operation?

       Upon examination of some removed ACM, does the full
       depth of the ACM appear to have been wetted?

       Describe how the ACM changes when it is wetted (e.g.,
       color, texture, weight, etc.):
7.     Is ACM awaiting containerization adequately wet
       throughout?

       If not, describe:	
       Is ACM in bags or other containers adequately wet? (follow sampling
       procedures detailed in "Asbestos NESHAP Demolition and Renovation
       Inspection Procedures Field Manual")                   	    	

       If not, describe:	
9.     Are there any open or ripped waste bags in the waste
       storage area?

       How many?  	

       Are the contents of these bags adequately wet?

                                  C-18

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                                                                    Yes   No    N/A
E.     Waste Disposal (61.150)

       1.      Are there visible emissions to the outside air?           __    	

       2.      Is there any suspect ACM dust or debris on the
              ground?                                               	    	

              If yes, describe the quantity and location of the material and collect samples
              for analysis (sketch and photograph as necessary):	'  •   .•
       3.     Is the owner/operator choosing an alternative to the
             "no visible emission" standard?

             If yes, which of the following options is in use?

             	    Treat with water and put into leak-tight,
                    labeled containers:

                    Is the ACM adequately wet?

                    Are the containers leak-tight?

                    Are the containers properly labeled?

             	;    Process into nonfriable forms

             .	    Alternative method approved by Administrator

                    Description of alternative method:	
                                          C-19

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                                                           Yes   No    N/A
             Approving agency:
             Name and title of approving official:
6.


7.


8.
Is ACWM being generated during an ordered demolition or
demolition where ACM is not required to be removed?   	

If "yes", is the ACWM kept:

a.     adequately wet after demolition?                 	

b.     wet during handling and loading for transport to a
       disposal site?                                  __

(sealing in leak-tight containers or wrapping not
required - may be transported and disposed of in bulk)

Are containers of ACWM destined for off-site transport
labeled with the name of the waste generator and the
location of its generation?                             _•

Is all ACWM (excluding Category I Nonfriable in good
condition) disposed of properly as soon  as is practical?   	

Are vehicles used in the transport of ACWM marked
appropriately during loading and  unloading?

Waste  Shipment Records

The following information may not be available onsite:

a.     Are appropriate waste shipment records
       maintained?                                   	

b.     Has a signed copy of the waste shipment record
       been received by the generator from the  waste
       disposal facility within 35 days?                  	
                                  C-20

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                                                                 Yes   No    N/A
             c.
             e.
             f.
If such a signed copy has not been receiveds has
the status of the ACWM been determined?       _^

Has the generator notified EPA in writing within 45
days if a signed copy of the waste shipment record
has not been received from the disposal facility?  ^

Are copies of all waste shipment records (including
the signed copy sent by the disposal facility)
maintained for 2 years?                        ^_
Comments:
Whenever a violation of the asbestos NESHAP is suspected, document occurrence in field
notes and with photographs and take samples as needed to prove ACM was involved.  Use
Attachment B for documenting sample information and Attachment C for documenting
photograph information.

V.     OSHA REQUIREMENTS

       Containment Barrier?                                        __    __

       Respiratory Protection?                                      	

       Glove Bag?                                                	    _

       Secondary containment in place where glove bags are used?     	

       Decontamination unit?                                       __     	

       Signs posted?                                               ^_    	

       Estimated size of containment area:
      Number and cfm rating of local exhaust ventilation units:
                                        C-21

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      Hygienist company:
      On-site representative:
VI.   POST INSPECTION INTERVIEW



      Summary of Recommendations/Discussion with Owner/Operator:
VII.   ADDITIONAL COMMENTS
      Inspector Signature
Date
                                    C-22

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         APPENDIX C-3   •••--•




LANDFILL INSPECTION CHECKLIST
             C-23

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C-24

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                           ASBESTOS DISPOSAL LANDFILL
                               INSPECTION CHECKLIST
Site Name:
Site Address:
Inspector(s):
Date of Inspection:	

I.      PRELIMINARY INTERVIEW

1.      Site Contact:	'
                                       Time of Inspection:
2.
3.
Title:
Affiliation:
4.     Telephone number:
                                                                       YES   NO
       Is the landfill approved by the State?

       If yes, Operating Permit No.:	

       Effective date:	
                                             through
       Is the disposal site operated in compliance with one of the following
       site requirements? (61.154)

       a.      No visible emissions [61.154(a)] and

              warning signs and fencing, or natural barrier [61.154(b)]

       b.      6-inch cover within 24 hours [61.154(c)(l)]


       c.      Dust suppressant within 24 hours [61.154(c)(2)] and

              warning signs and fencing, or natural barrier [61.154(b)]
                                           C-25

-------
        d.     Administrator approved alternative method [61.154(c)]

               If yes, explain:	      -   • •   '	
                                                                           YES   NO    N/A
 7.
8.
 Are waste shipment records maintained onsite?  [61.154(e)(l)]

 Do these records contain the following information?

 a.      Waste generator's information [6L154(e)(l)(i)]:

        1)     name
        2)     address
        3)     telephone number

 b.      Transporter's information [61.154(e)'(l)(ii)]:

        1)     name
        2)     address
        3)     telephone number

 c.      Quantity of ACWM (cubic yards or meters)
       d.
       [Has the landfill operator reported to the EPA, in writing,
       by the following day, the presence of a significant
       amount of improperly enclosed or uncovered waste?]

e.     Date of receipt [61.154(e)(l)(v)]r

Have signed copies of waste shipment records been sent to
the waste generator as soon  as possible, but no longer than
30 days after receipt of the waste?  [61.154(e)(2)]
       Presence of improperly enclosed or uncovered waste, or
       any ACWM not sealed in leak-tight containers
                                            C-26

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                                                                          YES   NO   N/A
9.      Has the landfill operator, attempted to reconcile differences
       between the quantity of waste designated on the waste shipment
       record and the quantity actually received? [61.154(e)(3)3
       Explain:
       If the discrepancy is not resolved within 15 days after receiving
       the waste, has a report been filed with the government agency
       responsible for administering the asbestos NESHAP program for
       the waste generator

       and

       if different, the government agency responsible for .  ,
       administering the asbestos NESHAP program for the
       disposal site!

 10.    Are copies of all records and reports retained for 2 years?   -  ,     ,
       [61.154(e)(4)]

 11.    Is a map or diagram of the disposal area being maintained?
       [61.154(f)]

       Does the map or diagram contain the following ACWM information?

                                         location
                                         depth              •    .
                                         area
                                         quantity
                                         cubic yards  or meters

 12.    Are records available for inspection?  [61.154(i)]

 13.    Has written approval from  the Administrator been obtained prior
       to excavating or otherwise  disturbing any ACWM already
       deposited and covered?  [61.154(j)]
                                             C-27

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 14.   When was waste last received?
 15.    What was the method of containerization?
 16.    How was it deposited (e.g., manually off-loaded, dumped semiautomatically)?
 17.    Where was it actually deposited?  (Note on sketch below.)

                      SKETCH OF DISPOSAL SITE (PLAN VIEW)
(Include Site Entrance and Boundaries, Roadways, Active cells, Closed cells, Borrow Areas,
Direction of Prevailing Wind, and Location of Deposited Asbestos-Containing Waste.
                                         C-28

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                                                                         YES  NO
18.    Are there any special provisions for handling ACWM at this
       landfill?                      .....'••-

       If yes, describe:	
III.    VISUAL OBSERVATIONS

       Determine the following at the disposal site. Collect samples and take photographs as
       necessary to document non-compliance with the provisions of the asbestos NESHAP.  Use
       Attachment A for documenting sample information and Attachment B for documenting
       photograph information.

1.     Are there visible emissions?  [61.154(a)]                              	

       If yes, describe location, magnitude and activity causing the
       emissions:	•--
2.     If barriers (fencing, natural) exist, describe them in detail.  [61.154(b)(l)]
       Can the barriers keep out intruders?

       Explain.  	'
3.     Are warning signs posted? [61.154(b)(l)j

4.     Is the waste sufficiently covered?  [61.154(c)(l)]

       Depth of cover material (inches, feet):   :    . ,-
                                           C-29

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                                                                          YES  NO
5.
6.
7.
Is the waste covered daily?  [61.154(c)(l)]

Type of cover material:	
Is a dust suppressant agent used? [61.154(c)(2)]

Type of suppressant used:	'

Is any ACWM exposed?

a.     Was it deposited within the past 24 hours?
       [61.154(c)(2)]                     .

b.     Is it sealed in leak-tight containers?  [61.150(a)(l)(iii)]

c.     Are the containers intact?

       If no, explain:	
       d.      Are the containers or wrapped materials labeled with
              the following?  [61.150(l)(v)]

                                  asbestos hazard warning
                                  name of waste generator
                                  location where waste was generated

              (If not, examine records and attempt to determine who
              generated the ACWM.)

       e.      If ACWM seen is not contained or wrapped, was it generated
              during a governmentaUy-ordered demolition? [61.145(a)(3)]

8.      Are vehicles seen unloading ACWM marked with the following
       information?  [61.150(c)(3)]

                                  easy to read legend
                                  20"  x 14" upright format sign
                                  asbestos  hazard warning
                                            C-30

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                                                                     YES  NO
Does the transporter possess a properly completed waste manifest?

      If not, determine as many of the following as possible:
             transporter company name
             address	
             telephone no.
             generator's name
             address 	
             telephone no.
             location where ACWM is being collected	

IV.   POST INSPECTION INTERVIEW

Summary of Recommendations/Discussions with Site Operator.
V.
ADDITIONAL COMMENTS
                                                               Date
Inspector signature(s):
                                         C-31

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                                        Attachment A

                                    Sample Collection Log
                          1
                          UJ
M

¥
Q.
                  I
                  Q.

                  ra
                HI

                a
                         UJ


                         P
CJ
o


o
UJ
UJ

i

3
                        UJQ


                        D. H
        2   £
        ra
            •a
            •o
                        a. m
                        •ss
                        < •=>
                        CO Z
        o

        £
                                          C-32

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Name/Address of Facility-
                                       Attachment B
                               Photo Identification Log Sheet
Date:
Inspector (photographer):
 Frame No.         Time          Sample No.
                                 Description
Remarks:
                                   Inspector Signature:
                                           C-33

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                                   ATTACHMENT C
                              ASBESTOS D/R CHECKLIST

                              QUANTIFICATION OF ACM
Facility
Component"
     Quantity1"
Area        Length
ft2           ft
Measurement/
Estimation
Technique6
Friable"
Total
"Examples of facility components:  pipe, duct, boiler, I-Beam, ceiling, steel deck, etc.
"Quantity of suspect ACM that will be disturbed during demo/reno.
"Measurement Technique: Measured or estimated - if estimated, explain technique.
dFriable rating: yes, no, or potentially during demolition or renovation.
                                         C-34

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       APPENDIX C-4




AHERA INSPECTION CHECKLIST
           ' C-35

-------
C-36

-------
               ABBREVIATED CHECKLIST FOR AHERA COMPLIANCE
                         FOR USE ON NESHAP INSPECTIONS
Local Education
Agency (LEA)

Address

School

Address

Designated Person

Phone Number
Abatement Project Description (including size of project):
Was Project Supervisor Accredited?

Accreditation Number	._
                              Yes_

                              Date
                   No
Each worker, state/number of accreditation, date of accreditation

Was Air Clearance in progress?                            Yes

Name of Person Conducting Clearance	

Affiliation	
                                            No
Laboratory contracted to analyze samples:
Name

Type of Analysis:
TEM
Address/Phone Number

PCM	
Was the Management Plan available to look at?

Yes	     No	                  Location of Plan    LEA

Was the abatement project included in the Plan?              Yes _


Inspector                                               Date
                                           School

                                            No
                                        C-37

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C-38

-------
           APPENDIX C-5




WORKER PROTECTION RULE CHECKLIST
               C-39

-------
C-40

-------
                     WORKER PROTECTION RULE CHECKLIST


Date of Inspection:	

Inspection Site:      	.	,    	

1.     Is asbestos abatement work being done?  (Abatement means activity involving the removal,
       enclosure or encapsulation of friable asbestos material.)
      Yes
             No
2.
Is abatement work performed by State and local government employees not covered by the
OSHA Rule (29 CFR 1926.58)?
      Yes
             No
3.    Does the work involve more than 3 linear feet or 3 square feet?

      Yes         No
Notes:
Inspector's Signature
                         Telephone Number
Date
                                         C-41

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                        LIST OF AVAILABLE REFERENCES

The following is a list of publications that deal with asbestos. These publications may be
available from the EPA Regional Offices or from the Asbestos and Small Business
Ombudsman, OSDBU A-149-C, Washington, D.C. 20460. Telephone: (800) 368-5888; for
D.C and VA: (703-557-1938). Information may also be obtained by calling the TSCA
Hotline (202) 554-1404.
1.
2.
3.
4.
5.
6.
7.
8.
Malmberg, K.B. EPA Demolition & Renovation Inspection Procedures. Stationary
Source Enforcement Division, Washington, D.C. October 1975.  (S.22 Document).

Piper, S.G., and P. Ford. 1988 NESHAPs Asbestos Demolition and Renovation
Inspection Workshop - Final Report. Alliance Technologies Corporation. EPA
Contract No. 68-02-4465, Work Assignment No. 21. March 1988.

Piper, S.G., et al. Asbestos NESHAP Inspector Safety Workshop - Draft Final
Report.  Alliance Technologies  Corporation. EPA Contract No. 68-02-4465, Work
Assignment No. 40. June 1988.

U.S. Environmental Protection Agency. Asbestos Demolition and Renovation
Enforcement Strategy (Revised). Stationary Source Compliance Division.
Washington, D.C. March 31, 1988.

U.S. Environmental Protection Agency. Draft Health and Safety Guidelines for EPA
Asbestos Inspectors (Revised).  Environmental Health and Safety Division, Office of
Administration and Resource Management, Washington, D.C. June 1990. (Attached
as Appendix C).

Piper, S.G. and N. Lebedzinski. 1989 Demolition and Renovation Inspection and
Safety Procedures Workshop - Final Report. Alliance Technologies Corporation.
EPA Contract No. 68-02-4465, Work Assignment No. 89-112. July 1989.

U.S. Environmental Protection Agency. Asbestos-Containing Materials in School
Buildings: A Guidance Document, Parts 1 and 2. Office of Toxic Substances,
Washington, D.C. C00090, March 1979. (Orange Books).

American Industrial Hygiene Association. Respiratory Protection, a Manual and
Guideline. Prepared by L.R. Binkner, Department of Environmental Health and
Safety Affairs, NY, 1980.
                                        R-l

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 9.



 10.



 11.



 12.


 13.



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 15.


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20.


21.
 U.S. Department of Health and Human Services. Workplace Exposure to Asbestos
 National Institute for Occupational Safety and Health Publication N. 81-103  April
 1980.

 U.S. Environmental Protection Agency. Support Document/Asbestos-Containing
 Materials in Schools/Health Effects and Magnitude of Exposure.  Office of Pesticides
 and Toxic Substances, Washington, D.C. EPA-560/12-80-003, October 1980.

 U.S. Environmental Protection Agency. Asbestos-Containing Materials in School
 Buildings, Guidance for Asbestos Analytical Programs. EPA-560/13-80-017A,
 December 1980.

 U.S. Environmental Protection Agency. Solid Waste Landfill Design and Operation
 Practices. Contract No. 68-01-3915, Washington, D.C. April 1981.

 U.S. Environmental Protection Agency. Evaluation of Encapsulants for Sprayed-On
 Asbestos-Containing Materials in Buildings. Office of Research and Development,
 Cincinnati, OH.  1981.

 The Foundation of the Wall and Ceiling Industry, Washington, D.C.  Guide
 Specifications for the Abatement of Asbestos Release from Spray- or Trowel-
 Applied Materials in Buildings and Other Structures. December 1981.

 U.S. Environmental Protection Agency, Region VII. Asbestos Exposure Assessment
 in Buildings.  Inspection Manual.  October 1982.

 U.S. Environmental Protection Agency. Guidance for Controlling Friable Asbestos-
 Containing Materials in Buildings.  Office of Pesticides and Toxic Substances,
 Washington, D.C. EPA-560/5-83-002, Marchl983. (Blue Book).

 U.S. Environmental Protection Agency. Airborne Asbestos Levels in Schools.
 Washington, D.C. EPA-560/5-83-003, June 1983.

 U.S. Environmental Protection Agency. Evaluation of the Asbestos-in-Schools
 Identification and Notification Rule. EPA-560/5-84-005, October 1984.

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

U.S. Environmental Protection Agency. Asbestos Waste Management Guidance.
EPA-530-SW-85-007, May 1985.  (Little Blue Book).

U.S. Environmental Protection Agency. Guidance for Controlling Asbestos-
Containing Materials in Buildings. EPA-560/5-85-024, June 1985. (Purple Book).
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 22.    U.S. Environmental Protection Agency. Evaluation of Asbestos Abatement
       Techniques, Phase 1: Removal.  EPA-560/5-85-019, October 1985.

 23.    U.S. Environmental Protection Agency. Asbestos in Buildings:  Simplified Sampling
       Scheme for Friable Surfacing Materials. Office of Pesticides and Toxic Substances,
       Washington, D.C. EPA-560/5-85-030A, October 1985.  (Pink Book).

 24.    U.S. Environmental Protection Agency. Measuring Airborne Asbestos Following an
       Abatement Action. Washington, D.C. EPA-600/4-85-049, November 1985.  (Silver
       Book).

 25.    U.S. Environmental Protection Agency. A Guide to Respiratory Protection for the
       Asbestos Abatement Industry. Office of Pesticides and Toxic  Substances
       Washington, D.C. EPA-560-OPTS-86-001, April 1986.  (White Book).

 26.    U.S. Department of Labor, Occupational Safety & Health Administration.
       Occupational Exposure to Asbestos: Tremolite, Anthophyllite, and Actinolite; Final
       Rules. 29 CFR Parts 1910 and 1926. (51 FR 22733) June 1986.

 27.    U.S. Environmental Protection Agency. Guidance for Presenting Asbestos Disease
       Among Auto Mechanics.  Office of Pesticides and Toxic Substances, Washington,
       D.C. June 1986. (Yellow Book).

 28.    U.S. Environmental Protection Agency. Evaluation of Asbestos Abatement
       Techniques, Phase Z: Encapsulation with Latex Paint EPA 560/5-86-016, July 1986.

 29.    U.S. Environmental Protection Agency. Electron Microscope Measurement of
       Airborne Asbestos Concentrations: A Provisional Methodology Manual.  EPA-
       600/2-77-178, Revised June 1978.                         .

 30.    U.S. Environmental Protection Agency. Methodology for the Measurement of
       Airborne Asbestos by Electron Microscopy (Draft Report), July 1984.

 31.    Asbestos: A Perspective To An Overview. Huff, J.E. Toxicology Information
       Response Center, Oak Ridge, Tennessee, March 1978.

32.    Natale, A. and Levins, HJ. "Asbestos Removal and Control," An Insider's Guide to
       the Business. Levins Design, Inc. ISBN 0-917097-00-9.  1984.

33.    Controlling Asbestos Contamination with Negative Air Filtration Systems. Source
       Finders, Voorhees, NJ. ISBN 0-917097-01-7. 1984.

34.    Recommended Contract Specifications for Asbestos Abatement Projects. Maryland
       Department of Health and Mental Hygiene, April 1985.
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35.    Project Protocol for Control Technology Assessment of Asbestos Removal
       Processes.  National Institute for Occupational Safety and Health, February 1985.

36.    National Institute of Building Sciences. Asbestos Abatement and Management in
       Buildings-Guide Specifications. NIBS, Washington, D.C. 1988.

37.    U.S. Environmental Protection Agency.  Asbestos NESHAP Demolition and
       Renovation Inspection Procedures Field Manual. Office of Air Quality Planning and
       Standards, Washington, D.C.  July 1990.

38.    U.S. Environmental Protection Agency.  Asbestos Content in Bulk Insulation
       Samples: Visual Estimates and Weight Composition. Office of Pesticides and Toxic
       Substances. Washington, D.C. EPA-560/5-88-011.  September 1988.

39.    Asbestos:  Manufacture, Importation, Processing and Distribution in Commerce
       Prohibitions; Final Rule. EPA 40 CFR Part 763 Subpart I. (54 FR 29460) July 12,
       1989.
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                                      TECHNICAL REPORT DATA
                             -(Please read Instructions on the reverse before completing)
 REPORT NO.
   340/1-90-007
                                2.
                                                                 3. RECIPIENT'S ACCESSION NO.
 TITLE AND SUBTITLE
   Asbestos NESHAP Demolition and
   Renovation Inspection Procedures
   Field Manual     	•	
              5. REPORT DATE
              November 1990
              6. PERFORMING ORGANIZATION CODE
. AUTHOR(S)
                                                                 8. PERFORMING ORGANIZATION REPORT NO.
   Stephen G. Piper and Nancy Lebedzinski
. PERFORMING ORGANIZATION NAME AND ADDRESS
   Alliance Technologies Corporation^
   Boott Mills South
   Foot of John Street
   TnwHI  MA
                                                                 10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.

                     68-02-4465
2. SPONSORING AGENCY NAME AND ADDRESS
   Environmental Protection Agency
   Office of Air Quality Planning  and Standards
   Stationary  Source Compliance Division
   Washington,  DC   20460      *          •
                                                                 13. TYPE OF REPORT AND PERIOD COVERED
              14. SPONSORING AGENCY CODE
5. SUPPLEMENTARY NOTES
6.
    3TRACT
  ABS~t .
   This document provides EPA guidance on procedures for conducting
   regulatory compliance inspections at asbestos demolition and
   renovation worksites and waste disposal facilities. Detailed
   information concerning the following is included: 1) identification of
   asbestos-containing materials, 2) safety procedures, 3) pre-inspection
   activities, 4) facility inspection procedures, 5) post-inspection
   activities. 6) landfill inspections and 7) bulk  sampling and analysis.

   Inspection checklists designed for facility inspection and landfill
   inspections are appended. The material presented is a summary of
   information and experience gained by  EPA through the inspection and case
   development experiences of a nationwide representation of regulatory staff
   responsible for enforcing the asbestos  NESHAP.
                                   KEY WORDS AND DOCUMENT ANALYSIS
                    DESCRIPTORS
                                                   b.IDENTIFIERS/OPEN ENDED TERMS
                              c. COSATI Field/Group
   Asbestos Abatement
   Asbestos Inspection
   Asbestos Waste Disposal
   Asbestos Waste Handling
   NESHAP
18. DISTRIBUTION STATEMENT

    Available to  the Public
19. SECURITY CLASS (This Report}
  UNCLASSIFIED
21. NO. OF PAGES
     158
                                                   2O. SECURITY CLASS (This page)
                                                     UNCLASSIFIED
                                                                                 22. PRICE
EPA Form 2220-1 (Rev. 4-77)    PREVIOUS EDITION is OBSOLETE

•fr U.S. GOVERNMENT PRINTING OFFICE: 1991 — 281" 72 if'  if 3 5 7 9

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