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 ------- 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 ------- 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 ------- 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 ------- 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: A92-274.txt ------- 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? A92-274.txt ------- 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: ------- 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 ------- 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: ___ A92-274.txt ------- 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: A92-274.txt ------- 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: A92-274.txt ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- V. POST INSPECTION INTERVIEW: Summary of facility inspection: Summary of recommendations/discussion with owner/operator: Additional Comments: Inspector Signature Date A92-274.UU 18 ------- SAMPLE COLLECTION LOG Facility Name Facility Address Samplers) Date Sampled, SAMPLE NUMBER SAMPLE LOCATION SAMPLE DESCRIPTION TIME SAMPLE TAKEN COMMENTS fi> 3 •o > 0 FT Oo o =r * i as ° c 3 > 0 (Q ------- Attachment B Photo Identification Log Sheet Name/Address of Facility:. Date: Inspector (photographer): Frame No. Time Sample No. Description Remarks: Inspector Signature: ------- |