United States Office Of Enforcement. March 1992
Environmental Protection (EN-341W)
Agency
&EPA Asbestos NESHAP
Milling, Manufacturing, And
Fabricating Operations
Field Inspection Checklist
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Printed on paper that contains
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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
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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.
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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
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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?
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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?
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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).
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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:
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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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