DEMOLITION AND RENOVATION
INSPECTION AND SAFETY PROCEDURES
WORKSHOP
SLIDE NARRATIVE
Final Report
July 1989
Technologies Corporation
-------
EPA WORK ASSIGNMENT MANAGER
Ms. Linda Lay
SSCD COORDINATOR
Ms. Omayra Salgado
1989 DEMOLITION AND RENOVATION
INSPECTION AND SAFETY PROCEDURES WORKSHOP
SLIDE NARRATIVE
Final Report
Preparedfor
U.S. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
Washington, D.C 20460
Contract No. 68-02-4465
Work Assignment No. 89-112
July 1989
Prepared by
Stephen Piper
Nancy Lebedzinski
ALLIANCE TECHNOLOGIES CORPORATION
213 Burlington Road
Bedford, Massachusetts 01730
(617) 275-9000
A89-370
-------
DISCLAIMER
This Final Report was furnished to the Environmental Protection Agency by the Alliance
Technologies Corporation, Bedford, Massachusetts 01730, in partial fulfillment of Contract
No. 68-02-4465, Work Assignment No. 89-112. 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 circumstances or each
liability for any personal health problems, death, or economic loss arising from any actions
taken in reliance upon this manual.
PEER REVIEW STATUS
This document has not been formally peer reviewed by the Environmental Protection Agency.
-------
NOTE TO THE SPEAKERS
The information contained in this document accompanies the Demolition and Renovation
Inspection and Safety Procedures Workshops Speaker Manual (Final Report, July 1989).
m
-------
IV
-------
Table of Contents
Section Page
1 BACKGROUND INFORMATION AND DEFINITIONS 1
2 NATIONAL REGULATORY STRATEGY/INSPECTOR GENERAL AUDIT 4
3 HEALTH EFFECTS OF EXPOSURE TO ASBESTOS 5
4 IDENTIFYING ASBESTOS CONTAINING MATERIALS 8
5 ABATEMENT TECHNIQUES 14
6 DEMOLITION AND RENOVATION REGULATIONS 19
7 RESPIRATORY PROTECTION EQUIPMENT 21
8 ASBESTOS INSPECTOR SAFETY GUIDANCE.... .-. 24
9 RESPIRATORY PROTECTION PROGRAM ELEMENTS 26
10 PROTECTIVE CLOTHING 27
11 ASBESTOS NESHAP INSPECTIONS LEGAL PERSPECTIVES 28
12 OTHER SAFETY CONSIDERATIONS IN ASBESTOS WORK 29
13 PRE-INSPECTION PROCEDURES „ 31
14 ONSITE FACILITY INSPECTIONS 32
15 POST-INSPECTION 34
16 LANDFILL INSPECTIONS 35
17 ASBESTOS BULK SAMPLING AND ANALYSIS .. 37
18 ASBESTOS AIR MONITORING 40
-------
SECTION 1
BACKGROUND INFORMATION AND DEFINITIONS
Slide 1 Asbestos NESHAP Inspection Safety & Procedures Workshop [word slide
(ws)]
Slide 2-5 Building demolition sequence
Since asbestos is an airborne health hazard, it has been included in the National Emission
Standards for Hazardous Air Pollutants (NESHAP) regulation. Although much of the dust
seen in this sequence of slides may not be asbestos, what portion does exist may be very
harmful.
Slide 6 Asbestos abatement site
The presence of the NESHAP and other regulations has given rise to the multi-billion
dollar a year asbestos abatement industry. Oftentimes, for older facilities, the cost of
asbestos abatement exceeds the original cost to construct die building. Abatement,
however, is still cost effective, for owners of buildings containing asbestos have more
difficulty renting or selling them and usually obtain much less than the full market value
of the property in die process.
Slide 7 Background Information (ws)
Slide 8 Federal Government (ws)
Slide 9 EPA Asbestos Regulations (ws)
CAA = dean Air Act
TSCA = Toxic Substances Control Act
RCRA = Resource Conservation Recovery Act
CERCLA= Comprehensive Environmental Response, Compensation and Liability Act
A89-370
-------
Slide 10 CAA (ws)
Slide 11 Demolition/Renovation (ws)
The demolition/renovation provisions of the asbestos component of NESHAP will be
discussed in detail during this course.
Slide 12 TSCA (ws) -
Slide 13 RCRA/CERCLA (ws)
Slide 14 Blank
Slide 15 Asbestos vein
Slide 16 Geological Terms (ws)
Slide 17 Size Comparison (chart)
Slide 18 Commercial Asbestos product
Slide 19 Asbestos Containing Products (chart)
Slide 20 Asbestos bulk sample closeup
A89-370
-------
Slide 21 Workers scraping ceiling
Workers are removing a spray-applied decorative/acoustical asbestos coating from the
ceiling and walls in this room. The way the material is holding together as it is scraped is
an indication that it has been adequately wetted.
Slide 22 Gymnasium—spray-applied asbestos
If the I-beams in this gymnasium were uninsulated and heated in a fire, they would expand
and lose tensile strength and perhaps be unable to support the roof.
Slide 23 Thermal insulation on pipes
Several types of insulation can be seen in this picture. The straight runs of pipe appear to
be covered with premolded asbestos insulation whereas the elbows and boiler itself are
insulated with a troweled-on cementitious asbestos material. Although not visible, asbestos
may also be found in valve packings or gasket materials in this boiler room.
A89-370
-------
SECTION 2
NATIONAL REGULATORY STRATEGY/INSPECTOR GENERAL AUDIT
NO SLIDES ARE USED IN THIS SECTION
A89-370
-------
SECTION 3
HEALTH EFFECTS OF EXPOSURE TO ASBESTOS
Slide 1 Health Effects of Asbestos Exposure (ws)
Slide 2 Asbestosis (ws)
Slide 3 Layers of Pleura (diagram)
The lungs reside in the chest (pleural) cavity in two membranous sacs known as pleura.
Slide 4 Peritoneum and Pleura (model)
Abdominal organs are enclosed by a similar lining known as the peritoneum.
Slide 5 Respiratory System (diagram)
The chest cavity is lined with a thin, transparent, plastic-like film called the mesothelium.
The mesothelium continues around and adheres tightly to the outer surface of each lung.
The layer on the surface of the lungs is barely separated by a thin layer of fluid from the
membrane lining the chest wall. In a manner similar to two planes of glass with a drop of
water between them, these two membranes will move across one another, but are very
difficult to pull apart It is this particular aspect that allows us to inhale and exhale
without difficulty. As the ribs and diaphragm expand, the pleural cavity lining also
expands. Since this lining is "stuck" to the membrane on the surface of the lungs
themselves, the lungs subsequently expand, allowing air to rush in. If either of these
membranes were damaged, severe difficulty in breathing would result
A89-370
-------
Slide 6 Respiratory System (diagram and commentary)
If asbestos fibers get past the other defenses of the lung, they will probably be attacked by
white blood cells known as macrophages. These cells ordinarily engulf and digest
materials such as bacteria, fungal spores, pollen, etc. which have entered the lung. Unlike
these other substances, however, asbestos fibers are inorganic, so macrophages cannot
digest them. Failing to destroy the fibers, the body does the next best thing...it
encapsulates them. ?
Slide? Blank
Slide 8 Normal & Scarred Air Sacs (diagram)
If enough fibers are encapsulated in these spaces, true scar tissue begins to form and
continues to build up in layers, resulting in a condition known as asbestosis. The scarring
reduces lung capacity and hinders the exchange of oxygen and carbon dioxide across the
alveolar membranes.
Slide 9 Asbestosis x-ray
Normal lungs are not visible on x-rays. The milky white sections visible in the lower lung
fields on this x-ray are the dense scar tissues that have formed in the lungs of this
individual with asbestosis.
Slide 10 Lung Cancer (ws)
Slide 11 Smoking and Asbestos Increases Risk of Cancer (ws)
Smoking is known to paralyze and/or destroy the cilia involved in the muco-ciliary
escalator. Because this defense mechanism is impaired, many more asbestos particles are
thought to be able to reach the deep recesses of the lung and cause harm there.
A89-370
-------
Slide 12 Mesothelioma Cancer (ws)
Mesothelioma continues to be a rare disease, even among asbestos workers. Approximately
75% of the cases reported involve the pleura! cavity and about 25% the abdominal cavity.
Slide 13 Mesothelioma x-ray
The large white mass seen in this x-ray is mesothelioma.
Slide 14 Pleural Plaques (ws)
Slide 15 Pleural Thickening (ws)
Slide 16 Pleural Effusion (ws)
Pleural effusions are treated by extracting the fluid with a hypodermic syringe.
Slide 17 Medical examination
Anyone with prolonged contact with asbestos-containing materials is well-advised to have
regular physical exams. OSHA requires employers whose workers are subject to its
regulations to institute a medical surveillance program to monitor the health of their
employees.
Slide 18 Pulmonary function test
Pulmonary function tests are performed to measure the elasticity and capacity of the lungs,
both of which may be impaired if the lungs are injured in any way.
A89-370
-------
SECTION 4
IDENTIFYING ASBESTOS CONTAINING MATERIALS
Slide 1 Identifying Asbestos Materials
In order to properly conduct an asbestos NESHAP inspection, an inspector needs to be able
to recognize suspect asbestos-containing materials. Although NESHAP deals specifically
with friable forms of asbestos, an inspector should learn to recognize nonfriable forms as
well, for these substances may become friable during renovation or demolition. For this
reason, the following sequence of slides depicts a wide variety of both friable and
nonfriable asbestos-containing materials an inspector may encounter on the job.
Slide 2 Friable Asbestos Containing Materials
Slide 3 Nonfriable Asbestos Containing Materials
SURFACING MATERIALS—INSULATING, FIREPROOFING
Slide 4 "Galbestos" on corrugated siding
The corrugated walls of this building were coated with a thin layer of Galbestos, a product
which contains 20% chrysotile. Since the building was going to be demolished by
wrecking ball and bulldozer, the inspector examining the site recommended that the
building owner remove the siding in sections and dispose of it as asbestos-containing
waste. His recommendation was based on the fact that the nonfriable siding could become
friable in the demolition process. Since a total of 365,000 square feet of material was
involved, the cost of such treatment was $750,000. The building owner had to weigh the
cost of potential fines for violations of NESHAP against the cost of doing the job properly
in this situation. If only a $500 or $1000 fine were levied, the building owner would still
save a significant amount of money during the demolition operation.
A89-370 8
-------
Slide 5 I-beams (overspray)
A great deal of asbestos overspray is visible in this photo.
Slide 6 I-beams (hangers)
Since small amounts of asbestos have to be removed in order to install these hangers, does
NESHAP apply? (only if the cumulative amount meets the minimum amounts specified
for surfacing materials in the NESHAP regulation)
Slide 7 I-beams & decking—troweled-on
A troweled-on, cementitious form of asbestos insulation is seen here.
Slide 8 I-beams & decking—fluffy, spray-applied
Spray-applied fireproofing or insulating material is typically light to medium gray in color
and from a couple to several inches thick. It is very fluffy and resembles dirty cotton.
The rusty spot on this insulated I-beam may be an indication that the roof leaks. This
may cause delamination of die insulation and increase the airborne asbestos levels
throughout the building, for die plenum is often used as an air return. Inspectors should
never lift ceiling tiles without appropriate respiratory protection.
Slide 9 Close-up of fluffy spray-applied
Slide 10 Cementitious insulation on corrugated decking
This corrugated deck coating is thick and quite cementitious but still friable.
A89-370
-------
Slide 11 Worker holding piece of cementitious insulation
This worker is holding a piece of the insulation seen in the previous slide.
SURFACING MATERIALS—ACOUSTICAL, DECORATIVE
Slide 12 Band room storage area
The plaster wall in this band storage area contained asbestos. Students had easy access to
this material and carved names into it All the hats had to be disposed of as
asbestos-contaminated waste. Band rooms may also have asbestos-containing perforated
acoustical wall and ceiling tiles as well as asbestos insulation in their walls.
Slide 13 School hallway
Students also had easy access to the asbestos-coated ceiling in this hallway.
Slide 14 Light switch on wall
Any time this light switch is operated, people come into contact with the asbestos-
containing, decorative wall finish.
Slide 15 Ceiling
Ceilings often have decorative/acoustical asbestos coatings.
Slide 16 Ceiling
Inspectors may find that ceilings have been painted and exhibit a variety of textures.
A89-370 10
-------
Slide 17 Closeup of ceiling
Although this ceiling appears to be granular or cementitious in nature, it may still be
friable.
THERMAL SYSTEM INSULATION
Slide 18 Ductwork
Ductwork may have asbestos block insulation, wire mesh, paper and a final layer of plaster
applied to it
Slide 19 - Ductwork
' *,
Ductwork may be double-walled with a layer of asbestos sandwiched between two layers of
sheet metal or it may have asbestos applied to its inside surfaces. If the building in which
ductwork is located is scheduled for demolition, it is important to know whether asbestos is
present If one cannot determine in any other way whether the ductwork is insulated,
tapping on it and hearing a dull tone rather than a metallic ring may indicate that asbestos
insulation is present
Slide 20 Pre-molded pipe insulation
This pre-molded pipe insulation is in poor condition.
Slide 21 Elevator shaft
Elevator shafts and trash chutes should be examined for the presence of asbestos-insulated
pipes.
Slide 22 Pipe insulation
A89-370 11
-------
Slide 23 Pipe insulation • poor condition
The fibrous nature of this pipe insulation can easily be seen.
Slide 24 Air-cell insulation
Air-cell insulation should always be considered suspect It is typically light to medium
gray in color and is usually held in place by a cheesecloth or canvas wrapping and metal
bands.
Slide 25 Felt wrap pipe insulation
Thick layers of an asbestos-containing felt may also be used to insulate pipes.
Slide 26 Boiler insulation - poor condition
The layers of materials used to insulate this boiler can be seen.
Slide 27 Boiler insulation layering
The wires used to hold the block insulation against the boiler can be seen.
Slide 28 Boiler insulation layering
Chicken wire often was used to hold block insulation in place. The outer layer of plaster
may or may not contain asbestos.
Slide 29 Elbows, valves
Elbows of thermal systems may be insulated with an asbestos-containing cement Valve
packings and gasket material may also contain asbestos.
A89-370 12
-------
Slide 30 Outside thermal system insulation
Suspect asbestos-containing materials may be found outside facilities as well as inside.
Slide 31 Outside thermal system insulation
Boilers may have steel jackets around the asbestos insulation. Inspectors should look
inside the jacket where pipes attach to the boiler to see if block insulation is present.
Slide 32 Hawaiian facility
An inspector marked areas where samples were taken from thermal system insulation on
the roof of this Hawaiian facility.
MISCELLANEOUS MATERIALS
Slide 33 Asbestos paper
Asbestos-containing paper or asbestos board may be found between a hardwood floor and
the subflooring or attached to steel decking. The asbestos sometimes looks like tiles and
may be 1/4" thick.
Slide 34 Johns-Manville 1.1/8" flexboard
Inspectors should always read labels and tags. Any time a Johns-Manville label is
encountered, the inspector should suspect that the material contains asbestos.
Slide 35 Asbestos siding
House siding, Transite board and floor tiles are generally nonfriable. However, with age
and weathering, these materials may become friable.
A89-370 13
-------
SECTION 5
ABATEMENT TECHNIQUES
Slide 1 Abatement Techniques (ws)
Slide 2 Occupied Library
In any asbestos abatement project the area must be prepared before work can begin. In
this library the books, rug, tables, lights and other items must be decontaminated and
preferably removed to facilitate the asbestos removal process.
Slide 3 HEPA Vacuum
This type of vacuum passes air through a high efficiency paniculate air (HEPA) filter
before exhausting it, thereby preventing asbestos fibers from leaving the vacuum once they
have been collected
Slide 4 Emptied Library
As clear a work space as possible is created prior to abatement
Slide 5 Locker room
In this situation the contractor decided that it would be easier to clean these lockers and
protect them with polyethylene (poly) than to remove them from the room.
Slide 6 Critical barriers
The windows and vent seen here are sealed with poly and tape before the wall poly is
attached.
A89-370 14
-------
Slide 7 Warning sign/critical barrier
Both OSHA and the EPA require the posting of signs at abatement sites. There must be
written in English but may also be written in whatever the predominant language is in the
area.
Critical barriers have been established both on the inside and outside of this large opening
so that asbestos fibers cannot leave the worksite.
Slide 8 Prepared worksite
Although the HVAC system is this area has been shut down and sealed with poly and
tape, the electricity to this area has not been shut off. Since water is used during asbestos
removal and workers can easily come into contact with live wires, a very dangerous
situation exists.
Slide 9 Polyethylene being applied to a wall
Slide 10 Polyethylene floor and wall coverings
The walls of a room are usually prepared first since the ladders and other equipment
needed to do this could mar a prepared floor. The floor poly is stretched as smoothly as
possible so that scaffolding and other equipment can be moved easily, tripping hazards are
reduced and cleanup facilitated.
Slide 11 Wrinkled floor polyethylene
This area has not been prepared properly.
Slide 12 "Negative Air" System (diagram)
A89-370 15
-------
Slide 13 Men entering decontamination unit
Slide 14 Worker wiping up leak/Local exhaust unit/Garden sprayer
Leaks in containment are dealt with immediately to prevent the spread of asbestos fibers to
outside areas.
Slide 15 Worker using garden sprayer
Slide 16 Worker using garden hose
Slide 17 Workers using extension wands
Slide 18 Worker using long-handled ice scraper
Slide 19 Worker using joint compound knife
Slide 20 Worker using putty knife
Slide 21 Worker using toilet brush
It is recommended that workers using only nylon or natural bristle brushes to remove
asbestos. It is thought that wire brushes may break up asbestos into finer fibers and
thereby increase airborne concentrations of the contaminant
Slide 22 Worker shoveling debris
Slide 23 Worker using vacuum hose to remove asbestos from I-beam
Slide 24 Worker examining hopper of vacuum equipment
A89-370 16
-------
Slide 25 Dry ACM in plastic bag in fiber drum
The asbestos that has been placed in this bag has not been adequately wetted.
Slide 26 Burlap bag with asbestos
If these bags do contain asbestos, it has not been adequately wetted, nor sealed in properly
labeled, leaktight containers.
Slide 27 Workers loading disposal bag with asbestos debris
Slide 28 Truck storage of disposal bags
The contractor may store bags of asbestos debris in a variety of locations (dumpsters,
trucks, rooms within the facility, etc.). Inspectors should always wear protective clothing
and respiratory protection when investigating these areas.
Slide 29 Metal barrels
Metal drums are sometimes used in the transport of bags containing asbestos debris. These
are usually emptied at the landfill and reused at the worksite.
Slide 30 Worker washing down wall polyethylene
Once all the asbestos has been removed and the area cleaned thoroughly, workers may
hose down the walls...
A89-370 17
-------
Slide 31 Worker wiping down polyethylene on wall
...and wipe them with lint-free cloths before removing the polyethylene. Alternatively,
workers may hose down the walls, encapsulate the poly with latex paint to lock down any
remaining fibers and the remove the poly.
Slide 32 Worker with knife • thermal system insulation
Contractors may choose to fully contain an area and establish "negative pressure" in areas
where pipe lagging is to be removed,
Slide 33 Worker preparing to hang a glovebag
Alternatively, a contractor may decide to use die glovebag technique in the removal of pipe
lagging.
Slide 34 Pipe Lagging Removal (diagram)
Slide 35 Pipe Lagging Waste Disposal (diagram)
A89-370 18
-------
SECTION 6
DEMOLITION AND RENOVATION REGULATIONS
Slide 1 Sources Under Subpart M (ws)
Slide 2 Asbestos NESHAP History (ws)
Slide 3 NESHAP Asbestos D/R Regulation (ws)
Slide 4 Definitions (ws)
Slide 5 Applicability (ws)
Slide 6 Notification (ws)
Slide 7 Contents of Notification (ws)
Slide 8 Procedures for Emission Control (ws)
Slide 9 Double-walled construction in Hawaiian building
Sometimes buildings are constructed with concrete block double outer walls. Risers and
pipes are located within the 8 to 10 inch space between the walls. Questions have arisen
as to whether the exception to removal, Encased in Concrete [61.147 (a)(l)J applies to
such construction. It does not If the building is going to be demolished, predemolition
must be conducted and the asbestos located within the space removed.
Slide 10 Worker spraying asbestos with hose
Inspectors will often find that adequate wetting is being done while the inspector is onsite.
. In order to determine if work practices have been conducted properly prior to his/her
A89-370 19
-------
arrival, the inspector should examine waste disposal bags in the storage area, document that
the 260/160 requirement is met and take samples of the material if a violation of NESHAP
is suspected.
Slide 11 Worker shoveling asbestos debris
Slide 12 Blank
Slide 13 Waste Disposal (ws)
Slide 14 Vacuum truck
An alternative method to bagging asbestos debris inside the facility has been approved for
use. Vacuum trucks, which have an air-cleaning baghouse on the back, may be used to
suck asbestos off the facility components and transport it to the landfill as a slurry. The
landfill must be notified and given adequate time to prepare a trench for the delivery of
the slurry. Once the slurry has been deposited, the trench must be covered immediately.
This sort of collection system is not commonly used. Another type of vacuum truck which
permits the bagging of asbestos debris outside the facility may more often be seen.
Slide 15 Active Waste Disposal Site Provisions (ws)
Slide 16 Future Developments (ws)
A89-370 20
-------
SECTION 7
RESPIRATORY PROTECTION EQUIPMENT
Slide 1 Classes of Respirators (ws)
Slide 2 Air Purifying Negative Pressure Respirators (ws)
Slide 3 Worker wearing single use paper mask
Slide 4 Worker wearing half-face dual cartridge air-purifying respirator
Polyvinyl chloride (PVC), silicone, neoprene or natural rubber may be used in the
construction of respirator face masks. Silicone masks tend to be more pliable and
comfortable than other masks and are less likely to cause irritation or allergic reactions.
The mask shown has a speaking diaphragm which aids in communication in the worksite.
This mask also has dual HEP A filters which are generally magenta or purple in color. The
color is an industry standard (not required by any law) and the shades will vary from
manufacturer to manufacturer. One U.S. company produces an approved gold HEPA
cartridge. In Europe HEPA cartridges are white in color.
Slide 5 Worker wearing full-face dual cartridge air-purifying respirator
This respirator provides both face and eye protection, thus eliminating the need for goggles.
The sealing surface of the mask contacts flatter areas of the face and therefore affords the
wearer greater protection.
Slide 6 Powered Air Purifying Respirators (PAPR) (ws)
Slide 7 Worker wearing PAPR with waist-mounted motor/filtration unit
A89-370 21
-------
Slide 8 Worker donning PAPR with mask-mounted motor/filtration unit
This mask is more tiresome to wear than the previous one shown, for the weight of the
motor/filtration unit is on facepiece itself.
Slide 9 Worker wearing hood/helmet type PAPR
Slide 10 Supplied Air Respirators (ws)
Slide 11 Workers wearing half-face and full-face supplied-air respirators
.Slide 12 Worker wearing supplied-air respirator with auxiliary SCBA
Slide 13 Worker wearing supplied-air respirator with auxiliary HEP A
Slide 14 Self-contained Breathing Apparatus (SCBA) (ws)
Slide 15 Worker wearing SCBA
i*
Slide 16 Selection of Respirators (ws)
Slide 17 Fiber Concentration (ws)
Slide 18 Respiration Selection Criteria (ws)
Slide 19 Conditions for No Respiratory Protection - Outside Barrier (ws)
Slide 20 Conditions for Air Purifying Respirators (ws)
Slide 21 Additional OHSS Conditions for APR's (ws)
A89-370 22
-------
Slide 22 Conditions for SCBA's (ws)
Slide 23 Medical/Physical Considerations (ws)
A89-370 23
-------
SECTION 8
ASBESTOS INSPECTOR SAFETY GUIDANCE
Slide 1 Sources for Inspector Safety Guidance (ws)
Slide 2 OSHA Regulations (ws)
Slide 3 Scope and Application (ws)
Slide 4 OSHA Exposure Limits (ws)
Slide 5 Regulated Areas (ws)
Slide 6 Respiratory Protection (ws)
Slide 7 Protective Clothing (ws)
Slide 8 Hygiene Facilities (ws)
Slide 9 Housekeeping (ws)
Slide 10 Medical Surveillance (ws)
Slide 11 EPA Worker Protection Rule (ws)
Slide 12 EPA/NIOSH Guidance (ws)
Slide 13 Contents of EPA/NIOSH Guidance (ws)
Slide 14 EPA/NIOSH Recommendations (ws)
A89-370 24
-------
Slide 15 Basis for Recommendations (ws)
Slide 16 OHSS Guidelines for Asbestos Inspectors (ws)
Slide 17 Health and Safety Plan (ws)
Slide 18 EPA Asbestos Inspector Training (ws)
Slide 19 EPA Asbestos Inspector Training - continued (ws)
Slide 20 Medical Monitoring (ws)
Slide 21 Respiratory Protection (ws)
A89-370 25
-------
SECTION 9
RESPIRATORY PROTECTION PROGRAM ELEMENTS
Slide 1 Respirator Protection Factors (ws)
Slide 2 Respirator Protection Factors (chart)
Slide 3 Respirator Fit Testing (ws)
Slide 4 Qualitative Fit Testing (ws)
Slide 5 Man undergoing qualitative fit test
Slide 6 Quantitative Fit Testing (ws)
Slide 7 Quantitative Fit Test (diagram)
Slide 8 Respirator Inspection and Maintenance (ws)
Slide 9 Man cleaning respirator
Slide 10 Field Inspection and Checkout Procedures (ws)
A89-370 26
-------
SECTION 10
PROTECTIVE CLOTHING
NO SLIDES ARE USED IN THIS SECTION
DEMONSTRATIONS ARE GIVEN
A89-370 27
-------
SECTION 11
ASBESTOS NESHAP INSPECTIONS LEGAL PERSPECTIVES
NO SLIDES ARE USED IN THIS SECTION
A89-370 28
-------
SECTION 12
OTHER SAFETY CONSIDERATIONS IN ASBESTOS WORK
Slide 1 Other Safety Considerations (ws)
Slide 2 Asbestos abatement workers
These asbestos abatement workers, due to the protective clothing and equipment they wear
and the hot, humid conditions in which they work, are likely to develop symptoms of heat
stress. Inspectors, although similarly attired, will face a much reduced risk of heat-related
problems for they typically will not work so strenuously in the hot environment.
Slide 3 Steep Stairway
Slide 4 Abatement workers on scaffolding and ladder
The worker in the foreground is using a stepladder improperly.
Slide 5 Floor with wrinkled polyethylene
The poly on the floor of this worksite presents a tripping hazard because it was not
stretched out and smoothed properly when applied.
A89-370 29
-------
Slide 6 Workers in high humidity / live electricity
Since a great deal of water is being used at this worksite and the air temperature is cool, a
fog has been produced. Since the electricity is still functioning in the area, a hazardous
situation exists.
Slide 7 Abatement worker working above operating light fixture
Workers are conducting abatement around live electricity in this area as well. An
inspector, perhaps having to climb up to see if the removal process is being done properly,
should be extremely cautious.
Slide 8 Accumulated water in containment
Slide 9 Wrecking ball and building
An inspector entering this building would be wise to ask when the building is scheduled
for demolition.
Slide 10 Partially demolished building
On occasion, an inspector will be required to determine whether the NESHAP standard
applies to a building already being demolished. One's safety should never be jeopardized
at such a site.
Slide 11 Workers near wharf
Inspectors may be asked to conduct inspections in unusual locations. Here, workers were
removing asbestos from a pipe that ran under the pier. An inspector's safety equipment
should include a lifevest in this situation.
A89-370 30
-------
SECTION 13
PRE-INSPECTION PROCEDURES
Slide 1 D/R Inspection Procedures (ws)
Slide 2 Pre-Inspection Procedures (ws)
Slide 3 Inspection Equipment (ws)
A89-370 31
-------
SECTION 14
ONS1TE FACILITY INSPECTIONS
Slide 1 Pre-inspection Observations (ws)
Slide 2 Pre-entry Interview (ws)
Slide 3 Safety Evaluation (ws)
Slide 4 Pre-removal Inspections (ws)
Slide 5 Active Removal Inspections (ws)
Slide 6 Worker spraying facility component
Asbestos abatement equipment and supply dealers now offer contractors a large variety of
wetting agents from which to choose. The EPA recommends using a 50:50 blend of
polyoxyethylene ether and polyoxyethylene ester to ensure adequate wetting of the asbestos.
Slide 7 Workers on scaffold scraping ceiling
The way the asbestos material is holding together and producing no visible emissions as it
is scraped is an indication that it has been adequately wetted.
A89-370 32
-------
Slide 8 Worker wiping down I-beam
Approximately 60-70 percent of the time involved in an asbestos abatement project is used
to final clean the surfaces from which the asbestos has been removed. After the final
cleaning, encapsulant may be sprayed on the facility components to ensure that any
remaining fibers are locked down.
Slide 9 Waste storage area
An inspector visiting a jobsite such as this should take samples of the dry material seen on
the floor and inform the owner/operator that the work practices onsite need improvement.
An enforcement action may not be needed in such a situation. An inspector desiring
samples form the storage bags should take the bags into containment if it is still in place
and open the bags and take samples while near an operating local exhaust unit
Slide 10 Blank
Slide 11 Post-removal Inspections (ws)
Slide 12 Asbestos waste heap
Has a violation of NESHAP occurred if an inspector sees the asbestos debris being
removed from a facility stored outside in this manner? The inspector should take pictures
and samples and document that NESHAP was applicable in this case (260/160 requirement,
adequately wet, maintained in wet condition until collected for disposal).
Slide 13 Post-inspection Interview (ws)
Slide 14 Exit Observations (ws)
A89-370 33
-------
SECTION 15
POST-INSPECTION
Slide 1 Post Inspection Activities (ws)
A89-370 34
-------
SECTION 16
LANDFILL INSPECTIONS
Slide 1 Landfill Inspections (ws)
Slide 2 Entrance to landfill
No asbestos hazard signs are visible at the entrance to this landfill. If an inspector sees
suspected asbestos-containing debris being brought here, additional information will be
required to determine if violations of NESHAP are occurring.
Slide 3 Truck/bulldozer at landfill
Slide 4 Bulldozers compacting and covering material at landfill
Slide 5 Bulldozer covering barrels of ACM with soils
The EPA would like to have containers of asbestos-containing material off-loaded by hand
and have it covered with soil rather than other non-asbestos-containing materials.
Slide 6 Truck dumping packaged ACM
Neatly packaged asbestos-containing material is being off-loaded into the landfill, producing
no visible emissions.
Slide 7 Truck dumping dusty ACM
If an inspector sees this sort of disposal and the material is covered appropriately within 24
hours, is NESHAP being violated? Yes. Although Section 61.156 appears to give either
"no visible emissions" or coverage with "compacted non-asbestos-containing material" as
••v
A89-370 35
-------
options to the landfill operator, Section 61.152 states that there shall be "no visible
emissions to the outside air during ... deposition of any asbestos-containing waste material
generated by the source..." Photographs and samples will help document that the material
was inadequately wetted and handled and that it contained >1% asbestos by weight. The
inspector must also determine that the material came from a "facility" and that the 260/160
provision of NESHAP was met
A89-370 36
-------
SECTION 17
ASBESTOS BULK SAMPLING AND ANALYSIS
Slide 1 OHSS Guidance for Bulk Sample Collection (ws)
Slide 2 Sampling Equipment (ws)
Slide 3 Carrying case for inspector's equipment
Slide 4 Sampling containers
Whirlpack plastic bags sometimes come with an area for information to be recorded. Be
sure to use indelible marking pens since everything taken into the worksite must be
decontaminated in the shower. 35 mm film canisters, either opaque or clear may be used
for sampling, or blood vials may be used.
Slide 5 Demolished structure rubble heap
If a building has not yet been demolished, taking samples is easy. Partial demolition has
occurred here. No inspector should ever jeopardize his/her safety for the sake of acquiring
samples at such a site. By looking around the partially-demolished building, an inspector
may determine that other parts of the building are still safe enough to enter to obtain
samples. Protective clothing and respiratory protection are essential in this sort of
investigation, for vibrations created in the demolition process may have caused an increase
in the airborne asbestos fiber levels.
Slide 6 Pieces of thermal system insulation in barrel
Sampling this suspect asbestos-containing material is easy. However, the inspector must
gather enough information to determine whether NESHAP is applicable. The amount of
.material visible must be measured and site personnel should be interviewed to determine
A89-370 37
-------
where the material came from, who stripped it, what procedures were used in the stripping
and when it was done.
Slide 7 Inspector sampling suspect ACM
A property labeled, rigid sample container is being used to take a sample of suspect
asbestos-containing material. Inspectors must make sure the outside of sampling containers
are cleaned of any dust before sending them to the laboratory.
Slide 8 Inspector sampling suspect ACM
If this were an EPA inspector, what would be wrong with this picture in reference to the
OHSS guidelines for inspectors? (No protective clothing except for one glove and a half-
face mask is being worn.) Two items that should be noted are that the inspector is using
a spray bottle containing amended water to moisten the area where the sample is being
taken and has marked the area with spray paint for photographic documentation of the site.
Slide 9 Fireproofing/Insulation
Inspectors should document the number of homogeneous areas seen in a site and take a
minimum of three samples from each of these areas. In this slide, how many
homogeneous areas can be seen? (3 = thermal system insulation on pipe, troweled-on
insulation on I-beam and spray-applied fireproofing/thermal insulation on decking.)
Slide 10 Analysis Methods (ws)
Slide 11 Polarized Light Microscopy (ws)
Polarized light microscopy can determine the type and percentage of asbestos and other
substances (vermiculite, sand, fibrous glass, etc.) present in a bulk sample. The cost of
such analysis typically ranges from $25-40/sample.
A89-370 38
-------
Slide 12 X-ray Diffraction (ws)
Like humans, every mineral substance is unique. A mineral's "fingerprint" can be
illustrated on Him using a technique known as x-ray diffraction. X-ray diffraction is
typically used to confirm the results of PLM especially if the PLM results report a low
percentage of asbestos in a bulk sample. The technique is a bit more accurate than PLM
but is more expensive, usually costing $75-90/sample.
Slide 13 Electron Microscopy (ws)
Although it is a very accurate technique, electron microscopy is not recommended for use
in analyzing bulk samples for it is very costly and takes more time than PLM and x-ray
analyses which can suffice.
Slide 14 Quality Assurance (ws)
Slide 15 Quality Assurance (ws)
A89-370 39
-------
SECTION 18
ASBESTOS AIR MONITORING
Slide 1 Asbestos Air Monitoring (ws)
Slide 2 Equipment (ws)
Slide 3 Personal air sampling device
A personal air sampling device consists of a pump, air tube and cassette with air filter.
The device is worn and operated for a certain length of time and the cassette sent to a
laboratory for filter analysis. The fibers that have accumulated are counted and the results
averaged over an 8-hour time interval.
Slide 4 Area air sampling device
These devices are often seen operating just outside the decontamination facility at an
abatement site. They are usually placed there by an industrial hygienist hired by the
building owner to certify that the abatement process is not contaminating areas outside
containment
Slide 5 Filter cassettes
Slide 6 Analytical Techniques (ws)
Slide 7 Continuous Monitors (ws)
A89-370 40
-------
Slide 8 Continuous monitor
The fibrous aerosol monitor weighs approximately 20-25 Ibs. and has a 20-lb. battery,
making it portable, but quite heavy.
Slide 9 Man carrying continuous monitor
Until the weight and cost of these units are reduced, inspectors will have to use available
information and their judgment in selecting appropriate protective gear for use at abatement
sites.
A89-370 41
------- |