United States        Office Of Enforcement.    March 1992
             Environmental Protection   (EN-341W)
             Agency
&EPA      Asbestos NESHAP
             Milling, Manufacturing, And
             Fabricating Operations
             Field Inspection Checklist
                                         Rccyctod/ftecydabto
                                         Printed on paper that contains
                                         at toast 60% recycled fiber

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United States
Environmental Protection
Agency
Asbestos NESHAP
Milling, Manufacturing, And
Fabricating Operations

Field Inspection Checklist
U.S. Environmental Protection Agency
Office Of Air Quality Planning And Standards
Stationary Source Compliance Division
Washington DC 20460

March 1992

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                                           DISCLAIMER

This checklist was prepared by Alliance Technologies Corporation for the Stationary Source Compliance
Division of the U.S. Environmental Protection Agency.  It has been completed in accordance with EPA Contract
No. 68-02-4465, Work Assignment No. 92-218. This document is intended for information purposes ONLY,
and may not in any way be interpreted to alter or replace the coverage or requirements of the asbestos National
Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M.
A92-274.CU                                          11

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                                     ASBESTOS NESHAP
                MILLING, MANUFACTURING & FABRICATING OPERATIONS
                          COMPLIANCE INSPECTION CHECKLISTS
                                    TABLE OF CONTENTS
Page   Checklist                                          Applicable? Not Applicable? Completed?

1      Asbestos NESHAP Milling, Manufacturing and Fabricating
       Operations Field Inspection Checklist                        	        	         	
8      Waste Disposal Requirements for Manufacturing and
       Fabricating Operations

11     Waste Disposal for Asbestos Mills

13     Offsite Transport Requirements for Disposal of
       ACWM from Milling, Manufacturing and Fabricating
       Operations

15     Reporting Requirements for Milling, Manufacturing
       and Fabricating Facilities

       Attachment A: Sample Collection Log

       Attachment B: Photo Identification Log Sheet
 A92-274.txt                                      111

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                                      ASBESTOS NESHAP
                 MILLING, MANUFACTURING & FABRICATING OPERATIONS
                                FIELD INSPECTION CHECKLIST
I.       GENERAL INFORMATION:
        Site Name:
        Location:
       Date of Inspection:	
       Time of Inspection:	am/pm

       FACILITY INFORMATION:

       Type of Facility: Milling	Manufacturing	Fabricating

       Material Manufactured (if applicable):

        1.      cloth, cord, wicks, tubing, tape, twine, rope, thread, yarn, roving, lap, or other
               textile materials

       2.      cement products

       3.      fireproofing and insulating materials

       4.      friction products

        5.      paper, millboard, and felt

        6.      floor tile

        7.      paints, coatings, caulks, adhesives, and sealants

        8.      plastics and rubber materials

       9.      chlorine utilizing asbestos diaphragm technology

        10.     shotgun shell wads

        11.     asphalt concrete
        Typical Operating Hours:_
        Date Construction of Facility Commenced:	
        Date Facility Commenced Asbestos-Related Operations:_
        Date Modification of Facility Commenced:	
        A.     Reason for Inspection:

               Routine Compliance     (  )     Citizen Complaint       ( )
               State Oversight/Joint     (  )

        B.     Site Conditions:
               Ambient Air Temperature: 	°C/°F
               Wind Description:	
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               Wind Direction:
               Visibility:	
                         (i.e., clear, partly cloudy, overcast...)
               Other Conditions:	
                         (i.e., drizzle, rain, sleet, snow ...)
        C.     Owner Information:
               Name: 	
               Address:
               Phone Number:  (

        D.     Operator Information:
               Company Name: _
               Address:  	
                Phone Number:  (
                Contact Person:	
                Title:     	
HI.     PRE-INSPECTION INTERVIEW:

        1.      Credentials Shown                                                            Yes  No
               a.      agency identification                                                   	
               b,      medical monitoring certification                                         	

        2.      Name and title of person being interviewed:
        3.      Company:
       4.      Principle Product Produced:

       5.      Process Information:
               a) Description:	
               b) Amount of asbestos-containing material produced by the facility:,
               c) Dates of operation:	
               d) Does the source use a spray-on method?  Y	N	.  If yes, was EPA informed of the
                  process 20 days prior to the application?  Y	N	.

        6.      Control Equipment/Measures:	
       7.      Are HEPA vacuums available on-site?
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        8.      Waste Handling Procedures:_
A92-274.txt
        9.      Is there an active waste disposal facility on site?
        10.     Is there an inactive waste disposal facility on site?.

        11.     Disposal Procedures:	
        12.     Primary waste transporter:
                Name:
                Address:
                Telephone:
        13.     Primary ACWM waste disposal site:
                Name:
                Address:	
                Telephone:
        14.     Interview Notes/Comments:

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IV.     INSPECTION:
        1.      Using the space provided, draw a general location map of the facility.  Note land use
                surrounding site (residential, industrial, recreational).  Estimate and indicate dimensions and
                distances as accurately as possible.
        2.
Using the space provided, draw a sketch of the process and control equipment locations.  Note
sample and photograph locations.
A92-274.ttt

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        3.       Which of the following emission control options has the facility selected?

                a.       Discharge no visible emissions to the outside air	; or
                b.       Use a fabric filter collection device	; or
                c.       Use an Administrator-approved wet collector	; or
                d.       Use a HEPA filter certified to be 99.97% efficient for 0.3 micron particles	; or
                e.       Use other Administrator-approved filtering equipment	.
        4.       Describe any visible emissions seen:
                                                                                               Yes    No
         5.      Is the facility using a fabric filter collection device?                               	   	

                If yes,
                a.      Is the facility using woven	or felted fabric	filters?
                b.      How does the facility ensure that the airflow specifications for these
                        filters are not exceeded?	
                c.      What is the current manometer reading of the pressure drop
                        across the fabric filter of the air cleaning device?	
                d.      Was the fabric collection device installed after January 10, 1989?
                        If yes, have provisions been made for easy inspection for faulty
                        bags (61.152(a)(3))?
                e.      Weight of felted fabric in g/m2: 	
        6.      Visible emission monitoring

                a.      Is visible emission monitoring performed once per day during
                        daylight operating hours for at least 15 seconds per emission source?
                b.      Who conducts the visible emission monitoring?
                        Name:	
                        Title:	

                c.      Comments:                     	
                                                                                                Yes    No
        7.      Conduct walkthrough and identify monitoring sites.  Does the facility               	   	
                monitor each of these potential sources?

                Comments:	___
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        8.       Are records of the results of visible emission monitoring and air cleaning
                 device inspections maintained?.

                 If yes, is the following information included?

                 a.       Date and time of each inspection.

                 b.       Presence or absence of visible emissions.

                 c.       Condition of fabric filters, including presence of any tears,
                         holes, and abrasions.

                 d.       Presence of dust deposits on clean sides of fabric filters.

                 e.       Brief description of corrective actions taken, including date
                         and time.

                 f.       Daily hours of operation for each air cleaning device.

                 Comments:	
        9.      Are the records made available for this inspection?                                 	   	

        10.     Are air cleaning devices used onsite?                                              	   	

                If yes,

                a.       Is each air cleaning device inspected at least once per week for
                         proper operations and for changes that signal the potential for
                         malfunctions?                                                           	   	

                                 or

                b.       For air cleaning devices that cannot be inspected on a weekly basis:

                         i.       Has a written maintenance plan been submitted to the             _      	
                                 Administrator?

                         ii.       Does the plan include a:
                                                                                                 Yes    No
                                 Maintenance schedule?                                           	   	
                                 Recordkeeping plan?                                             	   	

                         iii.      Has the plan been revised since submission?                       	   	

                         If yes, has the administrator been sent the revised plan?                    	   	

                c.       Who conducts the air cleaning device inspections?

                         Name:_	
                         Title:
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        11.      Has the facility retained a copy of all monitoring and inspection records for at
                least two years?

        12.      Are monitoring and inspection records available for inspection?

        13.      Have any visible emissions been recorded during visible emission monitoring?

                If yes, has the facility submitted a copy of the visible emission monitoring
                records to the Administrator within 30 days of the end of the quarter when
                visible emissions occurred? (Quarterly reports are due April 30, July 30,
                October 30 and January 30).

                Comments:	
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WASTE DISPOSAL REQUIREMENTS FOR MANUFACTURING AND FABRICATING OPERATIONS
AH asbestos-containing waste material must be deposited at a waste disposal site operated in accordance
with the provisions of Sec. 61.154.

        1.       Describe waste materials:	_^_^__
        2.      Describe waste handling procedures:
                                                                                              Yes  No
        3.       Has the source chosen to discharge no visible emissions to the outside air
                during the collection, processing (including incineration), packaging, or
                transporting of any ACWM generated?

                               or

                Does it use one of the following emission control and waste treatment
                methods?

                a.       Adequately wet asbestos-containing waste material as
                        follows:

                        i.      Mix control device asbestos waste to form
                               a slurry (Sec. 61.150(a)(l)(i));

                               Adequately wet other asbestos waste
                               material (Sec. 61.150(a)(l)(i)); and

                        ii.      Discharge no visible emissions to the
                               outside  air from collection, mixing,
                               wetting, and/or handling operations (Sec.
                               61.150(a)(l)(ii)) or use methods of Sec.
                               61.152;

                        iii.      Seal all asbestos-containing waste material
                               in leak-tight containers while wet (Sec.
                               61.150(a)(l)(iii)); or

                               For materials that will not fit into leak-tight
                               containers without additional breakage, put
                               materials into leak-tight wrapping; and
A92-274.txt

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                       iv.      Label the containers or wrapped materials
                               as follows:

                                             DANGER
                                  CONTAINS ASBESTOS FIBERS
                                     AVOID CREATING DUST
                             CANCER AND LUNG DISEASE HAZARD
                                                 or
                                                                                            Yes No
               b.      Process asbestos-containing waste material into nonfriable
                       forms as follows:

                       i.      Form all asbestos-containing waste into
                              nonfriable pellets or other shapes;

                       ii.     Discharge no visible emissions to the
                              outside air from collection and processing
                              operations, including incineration or,

                       iii.     Use the method specified by Sec. 61.152 to
                              clean emissions containing paniculate
                              asbestos material before they escape to, or
                              are vented to, the outside air;
                                                     /
                                              or

               c.      Use an alternative emission control and waste treatment
                       method that has received prior approval by the
                       Administrator.

        4.      Is ACWM transported offsite to a disposal site?

                       If yes,

               a.      Are the containers or wrapped ACWM materials labeled
                       with the

                       i.      name of the waste generator and

                       ii.     location at which the waste was  generated?
A92-274.m

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                 b.      Is waste deposited as soon as practical at an

                         i.       active waste disposal site operated in
                                  accordance with the provisions of Sec.
                                  61.154?
                                  or
                          ii.      an EPA-approved site that converts
                                  asbestos-containing waste into non-asbestos
                                  (asbestos-free) material in accordance with
                                  Sec. 61.155?
A92-274.txt                                             10

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                            WASTE DISPOSAL FOR ASBESTOS MILLS
All asbestos-containing waste material must be deposited at a waste disposal site operated in accordance
with the provisions of Sec. 61.154.
        1.      Describe waste materials:
        2.      Describe waste handling procedures:
        3.      Emission control

               a.      Which of the following has the facility chosen to do?

                       i.       Discharge no visible emissions to the outside air from the transfer of control
                               asbestos waste to the tailings conveyor	; or

                       ii.      Use a fabric filter collection device	; or

                       iii.      Use an  Administrator-approved wet collector	; or

                       iv.      Use a HEPA filter certified to be 99.97% efficient for 0.3 micron particles
                               	;or

                       v.      Use other Administrator-approved filtering equipment?	

                                                                                           Yes   No

               b.      Is the asbestos waste from control devices disposed of in
                       accordance with Sec. 61.150(a) (see item 3 on the checklist
                       for WASTE DISPOSAL FOR MANUFACTURING AND
                       FABRICATING OPERATIONS) or 61.149(c)?  (See item 4
                       of this checklist).                                                     	
A92-274.txt                                        11

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                                                                                                 Yes   No
        4.       a.       Has the facility chosen to discharge no visible emissions to
                        the outside air during the collection, processing, packaging,
                        or on-site transporting of any asbestos-containing waste
                        material?                                                                 	

                        or

                b.      Use one of the following methods?                                        	

                        i.       Adequately mix all asbestos-containing
                                 waste material with a wetting agent to
                                 effectively wet  dust and tailings before
                                 depositing the material at a waste disposal
                                 site.                                                              	

                                 Is the wetting agent being used as recommended
                                 by the manufacturer?                                             	

                        ii.       Discharge no visible emissions to the
                                 outside air from the wetting operation; or                          	

                                 Use the methods specified in Sec. 61.152
                                 to clean emissions containing paniculate
                                 asbestos material before they escape to, or
                                 are vented to, the outside air.                                      	

                        iii.      Use an alternative emission control and
                                 waste treatment method that has received
                                 prior written approval from the
                                 Administrator.                                                    	

        5.       Are wetting operations conducted at the site?                                       	

                If yes,

                Have wetting operations at the waste disposal site ever been suspended due to
                temperatures < -9.5°c?                                                            	

                If yes:

                a.      Has the temperature been recorded at least at hourly
                        intervals, and                                                             	

                b.      Have records been kept  in  suitable form for inspection for at
                        least two years?                                                           	
        6.      Record any visible emissions observed.
A92-274.txt                                            12

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               OFFSITE TRANSPORT REQUIREMENTS FOR DISPOSAL OF ACWM
            FROM MILLING, MANUFACTURING AND FABRICATING OPERATIONS
                                                                                        Yes No
        1.      Are vehicles used to transport ACWM marked as follows during the loading
               and unloading of waste?
                                           DANGER
                                   ASBESTOS DUST HAZARD
                            CANCER AND LUNG DISEASE HAZARD
                                    Authorized Personnel Only
       2.      Are Waste Shipment Records (WSRs) with the following minimum
               information maintained?

               a.      Name, address, and telephone number of the waste
                      generator.

               b.      Name and address of the local, State, or EPA Regional
                      office responsible for administering the asbestos NESHAP
                      program.
                                                 i>

               c.      The approximate quantity in cubic meters (cubic yards).

               d.      The name and telephone number of the disposal site
                      operator.

               e.      The name and physical site location of the disposal site.

               f.      The date transported.

               g.      The name, address and telephone number of the
                      transporters).

               h.      A certification that the contents of the 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.

               Comments:
       3.      Is a copy of the WSR provided to the disposal site owner at the time of
               delivery of the asbestos-containing waste to the disposal site?
A92-274.txt                                       13

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                                                                                                 Yes No
        4.       Have signed WSRs been returned by the waste disposal site within 35 days of
                the date the initial transporter accepted the waste?

                If no:

                a.      Was the initial transporter and/or the owner operator of the
                        waste disposal site contacted to determine the status of the
                        waste shipment?

                b.      If a signed copy of the Waste Shipment Record was not
                        received within 45 days of the date the initial transporter
                        accepted the waste, was the agency which administers the
                        asbestos NESHAP program for the waste generator notified
                        in writing?

                        If yes, was the following information submitted?

                        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 to locate
                                the asbestos waste shipment and the results
                                of those efforts.

        5.       Are copies of the Waste Shipment Records signed by the owner or operator of
                the waste disposal site maintained for at least two years?

                Comments:                                          	
A92-274.txt                                          14

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                REPORTING REQUIREMENTS FOR MILLING, MANUFACTURING
                                  AND FABRICATING FACILITIES

                                                                                         Yes  No  NA
        1.       Has the source submitted information to the Administrator as required
                by Sec. 61.153 (Reporting)?                                                 	

                If yes, examine the source information submitted and indicate whether the
                following required items are present:

                a.      A description of the emission control equipment used for
                       each process.                                                     	

                b.      Fabric filter information:

                       i.       The airflow permeability in mVmin/min2
                               (ftVmin/ft2) of a woven fabric filter;                         	
                               whether the fill yarn of a synthetic fabric
                               filter is spun or not spun; and

                       ii.      For felted fabrics:

                               the density in g/m2 (oz/yd2),

                               the minimum thickness in mm (inches),
                               and

                               the airflow permeability in mVmin/m2
                               (ftVmin/ft2).

               c.      A copy of the certified efficiency of the HEPA filter used.

               d.      A brief description of each process that generates asbestos-
                       containing waste material.

               e.      The average volume of asbestos-containing waste material
                       disposed of, measured in  mVday (ydVday).

               f.      The emission control methods used in all stages of waste
                       disposal.

               g.      The type of disposal site  or incineration site for ultimate
                       disposal.
A92-274.txt                                          15

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                                                                                                 Yes  No

                b.      Disposal site or incineration site information:

                        i.       Name of operator  	
                        ii.      Name of disposal site
                        iii.     Location	
        2.      Is this facility a new source (i.e., construction commenced before 01/10/89)?

                If yes,

                a.       Did the source have an initial startup date before November
                         20, 1990?

                         If yes.

                         Did the source provide the above information to the
                         Administrator by February 18, 1991?

                         If no,

                         i.       What was the startup date?	
                        ii.      Was the information submitted within 90
                                days?

        3.      Is the facility an existing source?

                a.      Has the source previously supplied this information to the
                        Administrator?

                        If no, was the information submitted by February 18, 1991?

        4.      New/Existing Sources:

                a.      Have there been any changes in the information submitted?

                        If yes,

                        Has the Administrator been informed in writing within 30
                        days of these changes?

                b.      For new/existing sources with an initial startup date before
                        November 20, 1990, has the following information been
                        submitted to the Administrator by February 18,  1991?

                        i.       Name and address of the owner or
                                operator.

                        ii.      The location of the source.

                        iii.      The type of hazardous pollutants emitted
                                by the  source.


A92-274.txt                                           16

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                                                                                                  Yes  No
                        iv.     A brief description of the nature, size,
                                design and operation of the source (include
                                operating design capacity and identify eacb
                                point of emission for each hazardous
                                pollutant).

                        v.      The average weight per month of the
                                hazardous pollutant

                        vi.     A description of the existing control
                                equipment.
                        vii.     A statement by the owner or operator as to
                                whether the source can comply with the
                                standards within 90 days of the effective
                                date of the regulation.
A92-274.txt                                           17

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V.     POST INSPECTION INTERVIEW:




       Summary of facility inspection:
        Summary of recommendations/discussion with owner/operator:
       Additional Comments:
       Inspector Signature                                   Date
A92-274.UU                                      18

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                                            SAMPLE COLLECTION LOG
Facility Name
Facility Address
Samplers)
                                                                        Date Sampled,
SAMPLE
NUMBER









SAMPLE
LOCATION









SAMPLE
DESCRIPTION









TIME SAMPLE
TAKEN









COMMENTS











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

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