kvEPA
United States Office of Air Quality
Environmental Protection Planning and Standards
Agency - Washington, DC 20460
EPA-340/1-90-004C
December 1990
Stationary Source Compliance Series
AHERA Training Workshop
for NESHAP Inspectors
Slide Narrative
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EPA- 340/1-90-004C
AHERA Training Workshop
for NESHAP Inspectors
Slide Narrative
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, IX 20460
December 1990
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DISCLAIMER
This document was prepared under contact to an agency of the United States
government. Neither the United States Government nor any of their employees makes
any warranty, expressed or implied, or assumes any legal liability for any third party’s
use of or the results of such use of any information, product, or process discussed in
this document. Mention or iIlus ation of company or adc names of commercial
products does not constitute endorsement by the U.S. Environmental Protection
Agency.
ACKNOWLEDGEMENTS
This document was prepared for the U.S. Environmental Protection Agency (EPA) by
Alliance Technologies Corporation, under Contact No. 68-02-4465. Alliance
appreciates the support and input given by the EPA Project Manager, Ms. Omayra
Salgado during the preparation of this document. We would like to thank for their
review and comments Linda flick, Office of Compliance Monitoring, Phil King, of the
Office of Toxic Substances, Liz Wilde, Region IV, John West, Region VI and Greg
Crahie, Region VI I. Their input is gratefully acknowledged.
H
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TABLE OF CONTENTS
SCChOfl Page
1 Background Information 1-1
2 Regulatory Overview 2-1
3 Asbestos Hazard Emergency Response Act (AHERA) Overview 3-1
4 General Local Education Agency Responsibilities 4-1
5 Inspection, Assessments, Reinspections and Exclusions 5-I
6 Sampling and Analysis 6-1
7 Response Actions 7-1
Operations and Maintenance 8-1
9 Training and Periodic Surveillance 9-1
10 Management Plans 10-1
11 Rccordkceping 11-1
12 Compliance and Enforcement 12-1
13 Transport and Disposal of Asbestos Waste 13-1
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NOTE TO THE INSTRUCTOR
mc information contained in this document accompanies the AHERA Training Workxhop
for NESJL4!’ Inspectors Instructor Manual.
iv
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SECTION 1
BACKGROUND INFORMATION
1-I Background Information (word slide)
1-2 Introduction (word slide)
1-3 Qualifications and Role of the Inspector (word slide)
1-4 AHERA Checklist (word slide)
1-5 AHERA Inspections (word slide)
1—1
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1-2
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SECTION 2
REGULATORY OVERVIEW
2-I Regulatory Overview (title slide)
2-2 Federal Government (word slide)
2-3 EPA Asbestos Regulations (word slide)
2-4 Clean Air Act (word slide)
2-5 Sources Under Subpart M (word slide)
2-6 RCRA/CERCLA (word slide)
2-7 Toxic Substances Control Act (TSCA) (word slide)
2-1
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2-2
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SECTION 3
ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA) OVERVIEW
3 .1 Asbestos Hazard Emergency Response Act (AHERA) (word slide)
3-2 Asbestos-Containing Materials in Schools (word slide)
3-3 Subpart E - Asbestos-Containing Materials in Schools: Table of Contents
(word slide)
3-4 Asbestos-Containing Materials in Schools: Appendices (word slide)
3-5 Model Accreditation Plan (word slide)
3-6 Laboratory Accreditation (word slide)
3-7 State Requirements (word slide)
3-1
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3-2
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SECTION 4
GENERAL LOCAL EDUCATION AGENCY RESPONSIBILITIES
4-1 General Local Education Agency Responsibilities (word slide)
4-2 Accredited Personnel Responsibilities and Training Requirements (word slide)
4-3 Custodial and Maintenance Employee Training (photo)
This letter informs custodians and maintenance employees about the date, time and location
of awareness training to be held.
4.4 Maintenance and Custodial Staff Training (word slide)
4.5 Notification Letter to Parents and Other Affected Parties (photo)
Although a copy of the actual annual notification informing workers and building occupants,
or their legal guardians about inspections, response actions, and post-response action
activities, including periodic reinspection and surveillance activities that are planned or in
progress is not required to be kept by the LEA, this school system has chosen to insert its
letter of notification into its Management Plan for the school.
4-6 Short-term Worker Notification (photo)
As required, this short-term worker is being informed about the location of asbestos material.
4-1
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4-7 Warning Labels (photo)
This warning label was posted in a school boiler room, a routine maintenance area at the
school.
4-8 Availability of Management Plans (photo)
Each of these management plans must contain a thted copy of the annual notification sent to
parent, teacher and employee organizations to inform them of the management plan’s
availability.
4-9 Designated Person (photo)
This “designated person” is in charge of ensuring that the requirements of AHERA are
properly implemented at seven different schools.
4-10 Conflict of Interest (word slide)
Phonebook advertisements may indicate that a company conducts asbestos inspections, writes
management plans and conducts response actions as well. An LEA must consider whether
any conflict of interest may arise among accredited personnel and whether that should
influence the selection of accredited personnel to perform activities under AHERA.
4-2
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SECTION 5
INSPECTION, ASSESSMENTS, REINSPECTIONS AND EXCLUSIONS
5-1 Inspection, Assessments, Reinspections and Exclusions (title slide)
5-2 Blank
The instructor should review important terms with the course participants.
5-3 Sprayed-on Decorative ACM (photo)
ACM on walls is especially accessible. Notice how material near the light switch has been
disturbed and is accumulating on the floor.
5-4 Floor Tiles (photo)
Floor tiles and the underlying mastic are usually nonfriable suspect ACBM.
5-5 Spray-on Fireproofing Above a Drop-in Ceiling (photo)
Both the spray-on fireproofing and the ceiling tiles are suspect ACBM.
5-6 Surfacing ACM (photo)
ACM has been applied in this school hallway primarily as acoustical insulation.
5-7 Surfacing ACM (photo)
This decorative and acoustical spray-on ACM may easily be damaged as the room divider is
moved.
5-1
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5-8 Boiler Room Thermal System Insulation (photo)
Several types of ACM may be found as thermal system insulation. These include pipe
insulation, boiler block insulation, cementitious materials found on T’s and elbows, valve
packings arid gasket materials.
5 -9 Inspector Determining Friability of Suspect ACM (photo)
Note that the inspector is following EPA guidance regarding personal protective equipment
(full-face, negative pressure respirator fitted with HEPA filters and full body coveralls) and
friability testing procedures (applying hand pressure to a piece of dry, suspect ACM after it
has been placed in a transparent, reclosable plastic bag).
5-10 Broken Piece of Ventilation Duct (photo)
Although this material is typically nonfriable, fibers may be released when such a material is
damaged.
5-11 Inspector Taking Bulk Sample (photo)
A small piece of suspect ACM is being taken for analysis of its asbestos content.
5-12 Assessment of ACBM (word slide)
5.13 Important Considerations in Assessing the Condition of ACM (word slide)
5-14 Reinspections (word slide)
5-15 Exclusions (word slide)
5-2
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5-16 Exclusions (word slide)
5-3
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5-4
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SECTION 6
SAMPLING AND ANALYSIS
6-1 Sampling and Analysis (title slide)
6.2 Blank
The instructor should review important terms with the course participants.
6-3 Bulk Sampling Requirements for Surfacing Materials (word slide)
6-4 Bulk Sampling Requirements for Thermal System Insulation (word slide)
6-5 Bulk Sampling Requirements for Miscellaneous or Nonfriable Suspect ACM
(word slide)
6-6 Analysis (word slide)
6-1
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6-2
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SECTION 7
RESPONSE ACTIONS
7.1 Response Actions (title slide)
7-2 Blank
The instructor should review important terms with the course participants.
7-3 Response Actions (word slide)
7-4 Response Options (word slide)
7-5 Response Options (continued) (word slide)
7-6 Abatement Workers (photo)
Response actions, other than small-scale, short-duration repairs, must be designed and
conducted by persons accredited to do so.
7-7 Designated Person (photo)
This designated person is mspecling an abatement area to determine if the abatement activity
has been properly completed.
7-8 Clearance Air Monitoring (photo)
This project monitor is conducting aggressive sampling. Aggressive sampling involves
agitating the air in the work area in an attempt to create a “worst case” situation. If the work
7-1
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area passes final clearance using aggressive techniques, one can be fairly certain that airborne
fiber levels will never rise above the final clearance level.
7.9 Electron Microscope (photo)
After October 7, 1990, all clearance air samples taken where the amounts of ACM removed
exceeds 260 linear feet or 160 square feet must be analyzed via transmission electron
microscopy (TEM).
7.10 Phase Contrast Microscopist (photo)
This individual is counting fibers using a phase contrast microscope which magnifies fibers
400-450 times. PCM is inexpensive and can be performed in the field, so results can be
available the same day the sample is collected.
7-11 Job Completion (word slide)
7-12 PCM Clearance Air Analysis (word slide)
7-2
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SECTION 8
OPERATIONS AND MAINTENANCE
8-1 Operations and Maintenance (title slide)
8-2 Blank
The instructor should review important terms with the course participants.
8-3 O&M Applicability (word slide)
8-4 Worker Protection (word slide)
8-S Cleaning (word slide)
8-6 Operations and Maintenance Activities (word slide)
8-7 Minor Fiber Release Episode (word slide)
8-8 Major Fiber Release Episode (word slide)
8-1
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8-2
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SECTION 9
TRAINING AND PERIODIC SURVEILLANCE
9-1 Training and Periodic Surveillance (title slide)
9-2 Awareness Training (photo)
The individuals seen here are attending a 2-hour asbestos awareness training session as
required by AHERA.
9-3 16-hour Training (word slide)
9-4 Training Course (photo)
In this slide, training on protective equipment is being presented. This is important for
custodial and maintenance personnel who may come into contact with ACM from time to
time.
9-5 Periodic Surveillance (photo)
This designated person is conducting a reinspection and documenting any changes seen in the
condition of the materials.
9-6 Periodic Surveillance (word slide)
9-1
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9-2
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SECTION 10
MANAGEMENT PLANS
10-1 Management Plans (title slide)
10-2 AHERA Deadlines (word slide)
10-3 Deferrals (word slide)
10-4 Additional Requirements (word slide)
10-5 Management Plan Components (word slide)
10-6 Management Plan Components (Cont.) (word slide)
10-7 Additional LEA Responsibilities (word slide)
10-1
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10-2
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SECTION 11
RECORDKEEPJNG
11-1 Recordkeeping (word slide)
1 1—1
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11-2
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SECTION 12
COMPLIANCE AND ENFORCEMENT
12-1 Compliance and Enforcement (word slide)
12-2 TSCA Title I (word slide)
12-3 Compliance with Title II of the Act (word slide)
12-4 Citizen Complaints (word slide)
12-5 AHERA Enforcement Response Policy (word slide)
12-6 Administrative Civil Penalties (Concurrence) (word slide)
12-7 Notices of Noncompliance (NONs) (word slide)
12-8 Injunctive Relief (word slide)
12-9 Criminal Penalties (word slide)
12-10 Other Enforcement Options (word slide)
12-11 LEA Civil Penalties (word slide)
12-12 LEA Civil Penalties (Cont.) (word slide)
12-13 Other Persons Civil Penalties (word slide)
12-14 Private Non-Profit Schools Civil Penalties (word slide)
12-1
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12-2
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SECTION 13
TRANSPORT AND DISPOSAL OF ASBESTOS WASTE
13-1 Transport and Disposal of Asbestos Waste (word slide)
13-2 LEA Recommendations (word slide)
13-3 Waste Disposal Bag (photo)
Many abatement firms package asbestos-containing waste material in a bag such as this.
13-4 Landfill (photo)
This packaged asbestos-containing waste material is producing no visible emissions during its
deposition at the landfill.
13-S Landfill Operation (word slide)
13-1
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13-2
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