DEMOLITION AND RENOVATION
INSPECTION AND SAFETY PROCEDURES
           WORKSHOP
         SLIDE NARRATIVE
            Final Report

             July 1989
                     Technologies Corporation

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        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

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                                   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.

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                       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

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IV

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                                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

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                                   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
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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
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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.
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                          SECTION 2



    NATIONAL REGULATORY STRATEGY/INSPECTOR GENERAL AUDIT
              NO SLIDES ARE USED IN THIS SECTION
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                                    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
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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.
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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.
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                                   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.

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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.
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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.
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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

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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.

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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.

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                                   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.

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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)

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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

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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...
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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)
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                                    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

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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)
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                                    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
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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)
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Slide 22      Conditions for SCBA's (ws)





Slide 23      Medical/Physical Considerations (ws)
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                                 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)








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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)
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                                 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)
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                          SECTION 10
                     PROTECTIVE CLOTHING
               NO SLIDES ARE USED IN THIS SECTION

                  DEMONSTRATIONS ARE GIVEN
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                          SECTION 11
        ASBESTOS NESHAP INSPECTIONS LEGAL PERSPECTIVES
               NO SLIDES ARE USED IN THIS SECTION
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                                   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.
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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.
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                                SECTION 13
                       PRE-INSPECTION PROCEDURES
Slide 1      D/R Inspection Procedures (ws)

Slide 2      Pre-Inspection Procedures (ws)

Slide 3      Inspection Equipment (ws)
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                                   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.
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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)
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                               SECTION 15
                            POST-INSPECTION
Slide 1      Post Inspection Activities (ws)
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                                    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

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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
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                                    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

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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.

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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)
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                                    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)
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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.
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