Un ited States Office of Air Quality
Environmental Protection Planning and Standards
Agency Washington, DC 20460
EPA-340/1-89-001
April 1989
Stationary Source Compliance Series
Guidelines for
Asbestos NESHAP
Demolition and Renovation
Inspection Procedures
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EPA - 340/1-89-001
Guidelines for
Asbestos NESHAP
Demolition and Renovation
Inspection Procedures
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Mr Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
April 1989
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CONTENTS
Figures ill
Acknowledgment iv
Glossary v
1. Introduction 1
Purpose of Inspections 2
2. Inspector Safety 4
Protective Clothing 4
Respiratory Protection 5
Selection of Respirators 7
Respirator Inspection, Maintenance and Storage 13
Operational Practices for Entering and Exiting Sites . . 17
Disposal of Contaminated Clothing 21
Safety Considerations for Other Hazards 22
3. Pre-Inspection Procedures 24
Review Notification 24
Identifying Non-Notifiers 25
Preparation of Inspection Equipment 25
4. Onsite Facility Inspections 28
Pre-Entry Observations 28
Pre-Entry Interview 29
Pre-Removal Inspections 31
Active Removal Inspections 33
Post-Removal Inspections 41
Post-Inspection Interview 44
5. Post-Inspection 45
Documentation 45
Records Maintenance 47
Inspection Reports 47
6. Landfill Inspections 49
Review Permit Conditions 49
Evaluate Disposal Techniques 50
Evaluate Asbestos Vetting 50
Surveillance 51
References R-l
Appendices
A. National Emission Standards for Hazardous Air Pollutants
(Subpart M - Asbestos) A-l
B. Quantities and Uses of Asbestos B-l
C. Asbestos Bulk Sampling and Analysis C-l
D. Field Inspection Checklists D-l
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FIGURES
Number Page
2-1 Full face air-purifying negative pressure respirator
with HEPA filters 8
2-2 PAPR (tight-fitting) with HEPA filters mounted with battery-
pack on belt 8
2-3 Full facepiece open circuit type pressure demand SCBA 9
2-4 Respiratory selection checklist 14
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ACKNOWLEDGEMENT
This guidelines document was prepared for the U.S. Environmental
Protection Agency (EPA) by Alliance Technologies, Inc. under Contract
No. 68-02-4465. Alliance appreciates the support and input given by the EPA
Project Managers, Ms. Ann Pontius and Ms. Pam Saunders during the preparation
of this guidelines document. Review and comments were provided by legal and
technical staff of all Regional Offices along with Headquarters OAQPS (SSCD
and ESD) OECM and EHSD. Additional comments were provided by Bridget
McGuiness of B.E. McGuiness, Inc. Their input is gratefully acknowledged.
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GLOSSARY OF TERMS
Asbestos-Containing Material; that Is, a material which
contains any amount of asbestos.
Asbestos Hazard Emergency Response Act. Requires schools
to inspect for asbestos, implement response actions, and
submit asbestos management plans to States. Specifies use
of accredited inspectors, air sampling methods, and waste
disposal procedures. 40 CFR 763, Subpart E.
Air Purifying Respirator.
Asbestos School Hazard Abatement Act. Provides funding
for schools having justifiable need for asbestos abatement.
The specific portion of Section 112 of the CAA that
addresses asbestos. Specific regulations are contained in
AO CFR Part 61, Subpart M.
Clean Air Act. The legislation that provides EPA with
authority for dealing with air pollution.
Environmental Health and Safety Division (formerly OHSS or
Occupational Health and Safety Staff). The group within
EPA that is responsible for developing health and safety
guidance specific to EPA employees.
Environmental Protection Agency. The organization within
the Federal government Which is ultimately responsible for
enforcing the asbestos NESHAP in order to protect the
public that works or lives near potential asbestos release
areas such as building# undergoing demolition or
r*novati&i.
Friable Asbestos Material. As defined by the Asbestos
NESHAP, friable asbestos material is any material
containing more than 1 percent asbestos by weight. The
term friable is defined as a material that can be crashed,
pulverized, orreducedto powder when dry by hand
pressure, (EPA considers this definition to also include
non-friable materials that will become friable during the
act of demolition or renovation.)
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GLOSSARY OF TERMS (continued)
High Efficiency Particulate Absolute filter. A filter
which will trap 99.97% of asbestos fibers that are at
least 0.3 microns in length.
Occupational Safety and Health Administration. The
Federal organization which is responsible for enforcing
regulations that protect the health of workers, including
those removing asbestos from buildings.
National Emission Standard for Hazardous Air Pollutants.
The specific legal authority of NESHAP is contained in
Section 112 of the Clean Air Act.
National Institute for Occupational Safety and Health.
The organization within the Federal government which is
responsible for research and development of worker safety
equipment and work practices.
Office of Pesticides and Toxic Substances. The group
within EPA which is responsible for implementing and
carrying out programs to enforce the TSCA regulations.
Any person who owns, leases, operates, controls, or
supervises any building, structure, facility, or
installation which emits or may emit any air pollutant.
Powered Air Purifying Respirator.
Self'Contained Breathing Apparatus.
Stationary Source Compliance Division. The group within
EPA that is responsible for implementing and carrying out
a program to assure that the regulated community complies
with the asbestos NESHAP.
Toxic Substances Control Act. Asbestos is regulated as a
toxic substance under this legislation.
Worker Protection Rule. TSCA regulation 40 CFR 763,
Subpart G which regulates public employees performing
asbestos abatement work in States not covered by OSHA
asbestos standards found in 29CFR 1926.58 Construction
Industry Standard.
260 linear feet (80 linear meters) of friable asbestos
materials on pipes or 160 square feet (15 square meters)
of friable asbestos materials on other facility components.
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SECTION 1
INTRODUCTION
The EPA has identified a need for nationally consistent inspection
guidelines to assist EPA, State and local air agency personnel in conducting
asbestos NESHAP inspections specific to demolition and renovation (D/R) of
buildings containing friable ACM. The primary purpose of this manual is to
present clear, concise inspection procedures to support a nationally
consistent inspection and enforcement program for the asbestos NESHAP (40 CFR
Part 61, Subpart M). EPA first published guidance entitled EPA Demolition and
Renovation Inspection Procedures (S.22)1 in 1975, following the original
promulgation of the asbestos NESHAP in 1973. Subsequently, EPA issued
numerous policy memoranda to provide additional guidance and clarification on
the asbestos NESHAP to agency staff charged with enforcing the regulation.
Additionally, EPA has developed a training program for inspectors that
incorporates two separate manuals. This manual represents a consolidation of
available material focusing on the procedures for establishing compliance with
the 1984 repromulgated asbestos NESHAP and subsequent policy determinations
made through September 30, 1988.
EPA and State agencies are beginning to implement coordinated asbestos
programs under CAA and TSCA. EPA, State, and local NESHAP asbestos inspectors
may also evaluate compliance for certain requirements under AHERA and WPR
regulations. To support the integration programs, this manual includes basic
guidelines for asbestos NESHAP inspectors to follow to determine compliance
with those provisions of AHERA and WPR, in order to refer any potential
violations to the appropriate asbestos program office for follow-up.
The guidance provided in this manual is geared toward EPA asbestos NESHAP
inspectors. However, it is also appropriate guidance for State and local
regulatory inspectors either in lieu of or as a supplement to specific State
and local program requirements. In an effort to minimize the overall volume
of this manual and keep within the goal of a carry-into-the-fieId inspector's
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reference manual, information herein has been condensed with reference to
available sources of further information. The primary reference sources used
to prepare this document are the workshop manuals and course materials
associated with the 3-day NESHAP Demolition/Renovation inspector training
workshop sponsored and funded by EPA.2'5
PURPOSE OF INSPECTIONS
Inspectors are assigned at the EPA, State, and local agency level to
visit the facilities involved in demolition and renovation activities, in
order to ensure that the regulated community adheres to the requirements of
the asbestos NESHAP. Observations made and evidence collected onsite by the
inspector are the foundation of any enforcement actions where violations of
the asbestos NESHAP are detected. The overall objectives of a regulatory
inspector can be broken into the following categories:
¦ Determine the need for immediate action to protect the public or the
workers (may necessitate obtaining a Temporary Restraining Order or
the authority of Section 303 of the CAA "imminent and substantial
endangerment to public health" and Section 113 of the CAA to seek a
court order to stop work);
a Verify that the demolition and renovation operations are carried out
according to all requirements of the asbestos NESHAP regulation;
¦ Gather evidence of any violations of the asbestos NESHAP;
¦ Determine whether a potential AHERA or WPR violation exists; and
¦ Create a regulatory presence as a deterrent to potential violators.
The overall asbestos NESHAP inspection and compliance program follows a
national strategy document entitled Asbestos Demolition and Renovation
Enforcement Strategy.* The guidance contained herein is consistent with the
national strategy document regarding inspector training, inspection criteria,
and enforcement procedures. This guidance is also consistent with EPA policy
to coordinate all asbestos program offices.
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The remaining sections of this guidelines document describe specific
procedures that should be followed by asbestos NESHAP inspectors focusing on
demolition and renovation of buildings. Section 2 contains all safety
procedures that should be followed when performing inspections. Section 3
reviews pre-inspection procedures, including guidance for identifying
non-notifiers. Section 4 sets forth the primary component of the manual which
is onsite facility compliance inspections. Section 5 reviews post-inspection
procedures, and focuses on handling of reports and evidence. Section 6
details procedures for landfill inspections. The appendices include: a copy
of the asbestos NESHAP regulation from the Federal register, a description and
illustration of common uses of ACM, a summary of bulk sampling procedures, and
a copy of checklists recommended for inspections of both D/R facilities and
landfills.
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SECTION 2
INSPECTOR SAFETY
The safety requirements incorporated in this manual have been drawn from
regulations and policies of four separate Federal government entities. OSHA
and EPA have each promulgated regulations pertaining specifically to workers
involved in the asbestos industry. The OSHA standard (29 CFR 1926
Construction Industry Standard) pertains specifically to workers involved in
the removal, demolition, installation, repair, maintenance, transportation,
storage and disposal of ACM. The EPA Worker Protection Rule (40 CFR 763
Subpart G) is specific to State and local employees not covered by the OSHA
standard. In a joint effort, NIOSH and EPA published a safety guide regarding
the selection of respirators entitled A Guide to Respiratory Protection for
the Asbestos Abatement Industry.5
A document prepared by EHSD (formerly Office of Health and Safety
Staff-OHSS) entitled Interim Health and Safety Guidelines for EPA Asbestos
Inspectors - Mav 19876 provides the most applicable safety guidelines for
asbestos NESHAP inspectors assessing compliance with the asbestos
demolition/renovation provisions of the regulation. This document was
supplemented by a June 6, 1988 memorandum by Rabinovitz of EHSD to EPA
inspectors.7 These safety guidelines are specific to EPA asbestos NESHAP
inspectors and incorporate many of the procedures and practices recommended or
required by the previously mentioned regulations and policies. The following
recommendations are based on the EHSD guidelines.
PROTECTIVE CLOTHING
Protective clothing is necessary, and in most cases required, during
asbestos inspections. Protective clothing for the inspector of asbestos
abatement projects usually consists of disposable coveralls, foot and head
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coverings, and gloves. These items are available in many styles and are made
of several types of materials. The advantages of a particular style depend on
the type of inspection conducted. In general, inspectors should wear the
following protective clothing when entering a site where asbestos containing
materials are being disturbed or is presumed to be in some stage of a removal
or demolition operation.
¦ A disposable, full-length, hooded, outer coverall (made of TyvekR
or equivalent material). A coverall with an expanded back should be
worn over an SCBA. In certain cases, an inspector may be required
to use specialty coveralls such as Saronax-coated TyvekR (chemical
resistance) or Nomex (fire retardant).
¦ A bathing suit (or equivalent) or an inner disposable coverall.
When possible, particularly when a changing or decontamination area
is available, all street clothing should be removed before donning
protective clothing. When clothing is removed, the inspector may
choose to wear a bathing suit under the protective clothing. If it
is not possible to remove street clothing, the inspector should
roll-up pant legs and sleeves and don inner and outer disposable
coveralls.
¦ Disposable gloves (PVC or equivalent) taped to coverall.
¦ Disposable inner booties (Tyvek* or equivalent, may be part of
coverall).
¦ Disposable outer booties (water-resistant material) taped to outer
coverall.
¦ Hard hat, safety glasses, safety shoes, hearing protection, when
required by the situation or by the owner/operator.
RESPIRATORY PROTECTION
Several classes of respirators are used by asbestos inspectors. The
following list does not include all respirators available and approved for
asbestos environments. Rather, it represents respirators which are most often
used by regulatory inspectors. For example, it would be impractical and
unwise for inspectors to use air-line respirators supplied by the contractor
when inspecting an abatement project. An air-line respirator may provide
effective protection against asbestos exposure, however, EHSD does not permit
agency inspectors to use non-agency equipment. Therefore, an SCBA would be
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more practical for inspectors while providing equal or better protection than
an air-line respirator and be in accordance with EHSD policy. In addition,
some classes of respirators described here are not recommended in the EHSD
guidance for use in abatement environments, but are used by inspectors.
Half-mask air-purifying respirators equipped with HEPA filter cartridges are
routinely used by inspectors although EHSD recommends that only the
full-facepiece version of air-purifying negative pressure respirators (with
HEPA filters) be used in asbestos abatement environments.
Air-Purifying Negative Pressure Respirators
» Half-Mask--Fits over the bridge of the nose, along the cheek, and
under the chin. Two headbands form a four-point suspension to hold
the mask in place and maintain the facepiece seal. During
inhalation a negative pressure is created within the facepiece,
thereby drawing the ambient air through the HEPA filter and into the
facepiece void space. The expired air exits through an exhalation
valve at the bottom of the facepiece. These respirators are not
recommended by EHSD for demolition/renovation inspections.
¦ Full-Face--Fits over the face across the forehead, along the cheek,
and under the chin. These devices have a head harness with a 5- or
6-point suspension. During inhalation a negative pressure is
created in the facepiece, thereby drawing the ambient air through
the HEPA filter and into the facepiece void space. The expired air
exits through an exhalation valve at the bottom of the facepiece.
EHSD guidance considers a full-face air purifying respirator with
HEFA filters to have a protection factor of 50 and recommends it as
the minimum type of respiratory protection for demolition/renovation
inspections.
Powered Air-Purlfvlng Respirators (PAPRsI with HEPA filter cartridges
¦ Full-Face Mask Type (Tiyht-fittlng)--This type of respirator
functions like a full-face negative pressure respirator except that
an auxiliary blower/filter unit supplies (HEPA) filtered air to the
facepiece. The blower creates a slight positive pressure within the
facepiece. Air is supplied by a small rechargeable, battery-powered
blower that delivers approximately 4 cfm of filtered air to the
facepiece. The EHSD guidelines consider tight-fitting PAPRs to have
a protection factor equal to full-face air purifying negative
pressure respirators with HEPA filters.
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¦ Open-Face Mask Type ^Loose-fitting)--This type of respirator does
not have a face-to-mask seal. Rather, it is a loose-fitting helmet
or hood in which the filtered air supply is delivered at a minimum
of 6 cfm. EHSD does not consider open-face mask PAFRs sufficient
respiratory protection for demolition/renovation inspections.
Self-Contained Breathing Apparatus (SCBA)
An SCBA consists of a full-facepiece, regulator, and a respirable
compressed air supply. The SCBA allows the user to carry the air
supply, thus eliminating the need for a stationary air supply. The
SCBA must be an open circuit type and operate in the pressure demand
mode to be used in asbestos atmospheres. EHSD recommends that SCBAs
be used in all inspections where high or unknown concentrations of
asbestos are encountered because SCBAs offer the greatest protection
of all types of respirators. This would include inspections where
the inspector has reason to believe the work practice procedures are
not being followed properly.
Figures 2-1 through 2-3 illustrate the specific categories of respirators
recommended by EHSD. Facial hair (such as beards and wide sideburns), certain
facial features (including scars, prominent cheekbones, dentures, and lack of
teeth) may prevent respirators from sealing properly. OSHA regulations state
that respirators shall not be worn unless a good face seal is obtained.
SELECTION OF RESPIRATORS
The following criteria for respirator selection are based on guidance
provided by EHSD. The EHSD guidance compares observations made by the
inspector in comparison to a set of specific selection criteria as the means
for selecting the appropriate level of respiratory protection. It is
recommended that the entire EHSD guidelines document (and accompanying
memorandum) be reviewed by anyone conducting asbestos inspections.
Inspectors must not wear respirators unless a physician has deemed them
"medically fit" to wear respiratory protection. This determination is based
on information obtained through a medical history, a physical examination
including a chest x-ray and pulmonary function tests, and other tests or
information requested by the physician. An inspector's fitness may change
over time. Additionally, certain illnesses, medications, or pregnancy may
affect an inspector's ability to wear a respirator.
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Figure 2-1. Full face air-purifying negative pressure respirator with
HEPA filters.
Figure 2-2. PAPR (tight-fitting) with HEPA filters mounted with battery
pack on belt.
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Figure 2-3. Full faceplece open circuit type pressure demand SCBA
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Inspectors must be properly trained in the use of respiratory protection
equipment, before conducting inspections in asbestos-contaminated
environments. According to EHSD, inspectors must participate in a medical
monitoring program and be properly fit tested when using air-purifying
negative pressure respirators. EHSD has stated that a successful qualitative
fit test is sufficient for the full-face negative pressure respirators with
HEPA filters. Qualitative or quantitative fit testing must be conducted
initially and at least semi-annually thereafter, with the same make and model
respirator planned for use.
Pursuant to EHSD guidelines, inspectors must use only agency-supplied
equipment, rather than equipment offered by the owner/operator of a demolition
or renovation site. Ideally, respirators should be selected based on actual
or potential airborne asbestos concentrations present at the site. However,
data on airborne asbestos levels in areas to be inspected is not always
available, and may be impractical to ascertain in advance. Therefore, the
inspector must rely on his or her judgment and experience to assess the area
in order to select the appropriate respiratory protection. To assist the
inspector in making the proper selection, EHSD has developed the following set
of conditions which must be met before using a given type of respirator.
These conditions were specified in the June 6, 1988 EHSD clarification
memorandum.
No Respiratory Protection Required
Respiratory protection (or protective clothing) is not required when
meeting with officials, building representatives, contractors and employee
representatives, under the following conditions:
¦ Remain outside enclosures of work area.
¦ No dust or debris that may have originated from within the enclosure
are visible;
¦ The work area is completely enclosed (which should be confirmed as
the inspector approaches the enclosure);
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¦ All openings into the work area have, at a minimum, a double entry
system (e.g., plastic flaps or equivalent);
¦ Materials brought out of the work area have been cleaned and the
pathway for removal of bags and equipment is clear;
¦ All ventilation systems (that have components in the work area) are
shut down and all vents in the work area have been taped shut;
¦ The contractor indicates that only wet methods are used. No dry
scraping, cutting, sawing or other dust-generating methods are used,
no wire brushes are used on dry materials, and no ACM is dropped or
thrown to the ground or lower floors. Further, no dry debris on the
floor is swept or placed in bags or other containers in a dry state;
and
¦ If glove bagging is used, some secondary containment is in place.
If all of the above conditions have been met, the inspector is free to go
into all areas outside the enclosure without any personal protective
equipment. If any of these items are not physically visible, the inspector
must use his or her judgment regarding the validity of verbally conveyed
information from the owner/operator. Other information that an inspector may
want to review in order to evaluate the likelihood of asbestos fiber
contamination resulting from poor work practices are:
¦ Results of personnel monitoring conducted by the contractor for his
abatement workers; and
¦ Other written materials associated with the job, such as employee
training records or employee medical records.
Respiratory Protection Required
Respiratory protection is required for many situations encountered by
inspection personnel, both inside and outside the active removal area. For
example, respiratory protection is required for inspections conducted outside
the work area if any of the previously listed conditions have not been met.
In addition, respirators are required whenever an inspector enters a work area
that has not been cleared for reoccupancy.
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In the determination of the level of respiratory protection required, an
inspector must rely on available information and observations of the
conditions at the work site. At a minimum, a full-face, air purifying
negative pressure respirator with HEPA filters or a PAPR with tight-fitting
facepiece and HEPA filters is required. An inspector can upgrade respirator
selections at any time, but should never downgrade selection.
Reviewing records, conducting a pre-removal inspection, and interviewing
site personnel may aid in the determination of the appropriate level of
respiratory protection at a given site. If adequate information is not
available to document work practices or site conditions, an inspector may use
his or her judgment in determining appropriate respiratory protection. If,
upon entering the work place, the inspector determines that the following
conditions have not been met, he or she should exit the work area immediately
and upgrade the level of respiratory protection from the full-face air
purifying negative pressure respirator or PAPR to an SCBA. The conditions for
allowing the use of a full-face air purifying negative pressure respirator or
a PAPR with tight-fitting facepiece are:
¦ All conditions listed for not requiring any respiratory protection
outside the work area presented previously must be met.
¦ All ACM must be capable of being adequately wetted from the exposed
outer surface to the innermost surface. No protective coverings
should be on the outside of the ACM which would prevent adequate
penetration or wetting. Further, all of the ACM must be capable of
absorbing the wetting agent. The ACM cannot be cementitious,
impenetrable to water.
¦ The area must have negative pressure relative to areas outside the
enclosure, generated by a HEPA filter air exhaust system. In
addition, a HEPA vacuum cleaner must be inside the work area, and
used for cleaning materials and decontaminating equipment and bags
which contain debris, before they are removed from the work area.
¦ All glove bag operations, with or without secondary containment,
will require the use of air purifying respirators at the removal
site. The inspector should determine that the glove bag methods are
properly used (if not, an SCBA is required).
¦ If the ACM materials are non-friable and can be removed without any
cutting, sawing or any other method which generates particulate
emissions, an air purifying respirator may be used.
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If all of the above conditions are met, the inspector can enter the work
area with a full-face air purifying negative pressure respirator with HEPA
filters or PAPR with tight-fitting facepiece and HEPA filters. If the above
conditions are not met, or if during the course of the inspection the
conditions change, an open circuit pressure demand, full facepiece SCBA is
required. Figure 2-4 is a sample checklist which can be used to assist
inspectors in making respirator selection.
RESPIRATOR INSPECTION, MAINTENANCE AND STORAGE
The respirator must be thoroughly inspected immediately before use by the
individual who will use it. At a minimum, OSHA standards require that the
respirators be inspected for the following:
¦ Tightness of all connections;
¦ Working order of the facepiece, valves, connecting tube, and
canisters; and
¦ Proper functioning of the regulator and warning devices on SCBA.
The following list details checkout procedures which should be performed
before and after each use of the respirator.
Air Purifvinp Negative Pressure Respirator Checkout Procedures
• Examine the facepiece for signs of cracking, tears, holes,
distortion, excessive or residual lint, dirt etc.;
¦ Examine face-to-facepiece seal to ensure that it is flexible and
that there are no cracks or tears;
¦ For full-facepiece respirators, ensure that the lens is neither
cracked nor scratched to the extent that it would impair vision;
¦ Examine air purifying element holders. Check for cracks in holders,
badly worn threads, or missing gaskets;
¦ Check head straps and harness for breaks, loss of elasticity, broken
or malfunctioning buckles, or excessively worn serrations;
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NO RESPIRATOR REQUIRED OUTSIDE THE CONTAINMENT AREA*
No dust or debris is visible which originates from within the
enclosure.
Work area is completely enclosed.
All work area openings have double plastic entry system.
Materials from work area are removed clean, via a designated and
clear pathway.
Ventilation system is shut down and vents inside work are taped shut.
A wet method is employed, and no dry scraping or wire brushing of
dry material is conducted. ACM is not dropped to the ground.
All debris on floor is kept wet until it is put in containers.
If glove bagging is used, some secondary containment is in place.
AIR PURIFYING CARTRIDGE RESPIRATOR REQUIRED**
All conditions for no respiratory protection outside the containment
area have been met.
All ACM is capable of being adequately wetted from the outer surface
to the innermost surface.
Negative pressure system with HEPA filtration is operational.
HEPA vacuum is available inside the work area.
Glove bagging is properly conducted.
Non-friable materials, which cannot be adequately wetted, are
removed without cutting, sawing, etc.
*If all of the above items have been checked, then the inspector can conduct
the inspection outside without respiratory protection.
**If all of the above items have been checked, air purifying cartridge
respirators can be used. If not, use an SCBA.
Figure 2-4. Respiratory selection checklist.
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¦ Examine existance of inhalation and exhalation valves, examine for
foreign particles, cracks, tears, improper seating or installation,
or breaks or cracks in the valve body seating surface;
¦ Ensure that cartridges are the correct type: respirator and
cartridges must be made by the same manufacturer; and cartridges
must be approved for use in an asbestos atmosphere (type H, high
efficiency filter, usually magenta color code, N10SH certified);
¦ Conduct a positive pressure test. With the respirator on and
adjusted, block the flow from the exhalation valve and exhale. The
facepiece should balloon outward slightly with no noticeable
leakage; and
¦ Conduct a negative pressure test. With the respirator on and
adjusted, block the flow into inhalation valves and inhale. The
facepiece should collapse inward with no noticeable leaks.
Positive Pressure Air Purifying Respirator (PAPR) Checkout Procedures
¦ Follow all procedures listed for air purifying negative pressure
respirators; and
¦ Examine corrugated breathing tube for: broken or missing end
connectors, gaskets, or o-rings; missing or loose hose clamps; or
deterioration of the tubing (stretch tubing and look for cracks).
¦ Determine that the battery is fully charged, the cartridges are
properly connected, and the fan is functioning properly.
Self-Contained Breathing Apparatus CSCBA) Checkout Procedures
¦ Check the facepiece in a similar fashion as for air-purifying
respirators;
¦ Check the air supply system for:
integrity and condition of air supply lines and hoses,
including attachments and end fittings;
correct operation and condition of all regulators, valves, and
alarms;
sufficient air charge in the high pressure cylinder for the use
period. Recharge it if less than 80 percent of useful service
time remains. Preferably, the tank should be fully charged; and
up-to-date SCBA inspection (monthly) as required by 29 CFR
1910.134(f).
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¦ Caution: An SCBA tank rated for 30 minutes may be depleted in 15 to
20 minutes depending on the breathing rate of an individual. Care
must be taken to allow air supply time for exiting the area and
properly decontaminating equipment.
Cleaning and Disinfecting
Respirator facepieces should be cleaned after each use and disinfected
daily in accordance with the manufacturer's instructions. These general
instructions may be helpful in cleaning and disinfecting the respirator:
¦ Remove and clean separately all detachable parts such as straps,
valves, and gaskets;
¦ Remove all cartridges, canisters and filters, plus gaskets or seals
not affixed to their seats (Note: Cartridges used during
inspections will have been disposed after completion of an
inspection);
¦ Remove elastic headbands;
¦ Remove exhalation cover;
¦ Remove speaking diaphragm or speaking diaphragm-exhalation valve
assembly;
¦ Remove inhalation valves;
¦ Wash facepiece and breathing tube in cleaner/sanitizer powder mixed
with warm water, preferably at 120° to 140°F. Most respirator
manufacturers market their own cleaners/sanitizers as dry mixtures
of a bactericidal agent and mild detergent. One-ounce packets for
individual use and bulk packages for quantity use are usually
available. Wash components separately from the face mask, as
necessary. Remove heavy soil from surfaces with a hand brush;
¦ Remove all parts from the wash water and rinse twice in clean warm
water;
¦ Air-dry parts in a designated clean area; and
¦ Wipe facepieces, valves, and seats with a damp lint-free cloth to
remove any remaining soap or other foreign materials. Reassemble
respirator and inspect prior to storage.
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Storage
Follow manufacturer's storage instructions which are either supplied with
new respirators or affixed to the lid of the carrying case. These additional
general instructions may be helpful:
¦ After cleaning, inspection, and necessary repair, respirators should
be stored to protect against dust, sunlight, heat, extreme cold,
excessive moisture, or damaging chemicals. Respirators should be
thoroughly dried before being sealed in any container for storage.
¦ Respirators should be stored in a convenient, clean, and sanitary
location. Proper storage of respirators helps ensure that they
function well when used.
¦ Respirators should not be stored in spaces so small that they may be
deformed. Such spaces include: clothes lockers, bench drawers,
tool boxes, or vehicle glove compartments. Place them in wall
compartments at work stations or in a work area designated for
emergency equipment. Store them in the original carton or carrying
case.
¦ Respirators should be packed or stored so that the facepiece and
exhalation valves will rest in the normal position. This will
ensure that function is not impaired by distortion of the respirator
or its straps. Respirators should not be hung by their straps.
OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES
The procedures for entering and exiting sites described in this section
summarize those of the EHSD Guidelines, and are generalized to cover both
air-purifying respirators and SCBAs. Refer directly to the EHSD Guidelines
for a detailed description specific to each type of respirator.
Entering and Exiting Site with a 3-Stage Decontamination System
A 3-stage decontamination system consists of a clean room, shower room,
and equipment room (sometimes referred to as dirty room) contiguous with the
active removal area. This type of decontamination system is required by the
OSHA asbestos construction industry standard (29 CFR 1926.58) for removal,
demolition, and renovation projects (detailed in Appendix F of the OSHA
standard).
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Prior to Entering the Clean Room
Determine that the respirator is functioning properly.
Make sure that you have all materials and equipment necessary
to conduct the inspection safely (e.g., protective clothing,
respirator, duct tape, extra plastic bags, spray bottle,
disposable towels, flashlight, camera, etc.). All materials
carried into the contaminated area should be sealed in plastic
bags to minimize contamination.
If you take a camera into the contaminated area, precautions
must be taken to minimize contamination and to decontaminate
the camera when exiting. Use of a waterproof camera or sealing
a conventional camera in an impermeable clear camera box will
facilitate a more complete decontamination.
In the Clean Room
Remove all street clothing including socks and underwear. If
desired, wear a bathing suit (or equivalent) appropriate
footwear (sneakers, steel-toed shoes, etc.) and inner
disposable footcoverings. The inspector should leave his/her
clothes in a clean sealed plastic bag to protect against
accidental contamination by abatement workers. Any equipment
not being taken into the contaminated area should also be
placed in the plastic bag.
If an SCBA will be used, close the air flow valve and don the
SCBA; let the respirator facepiece hang from the neck by the
strap.
Don disposable, full-body hooded coverall (e.g., Tyvek" or
equivalent). If using an SCBA wear a coverall with an
expandable back or oversize (XXL) Tyvek over the SCBA.
Don disposable outer boots and seal to outer suit with duct
tape. (Tyvek booties will rip quite easily once they become
wet. The inspector may wear disposable rubber boots).
Fit respirator facepiece to face. Perform negative and
positive pressure field checks for air-purifying respirator.
For SCBA, open air valves and adjust facepiece straps.
Fit the coverall hood snugly around the respirator facepiece
and zip up coverall.
Don disposable gloves, using duct tape to seal to outer suits.
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Proceed through the shower area and equipment room and into the
work area (may leave disposable towels and soap behind in the
shower area).
Conduct the inspection.
¦ Before Leaving the Contaminated Area
HEPA vacuum (if possible) any visible debris from protective
clothing and sample containers, sampling equipment, and any
other items which are being taken out of the work area.
Proceed to the equipment room.
¦ In the Equipment Room
If possible, decontaminate all non-disposable equipment
including footwear at the site. If not, seal all contaminated
non-disposable materials in a plastic bag and take them with
you to decontaminate at a later time.
While the respirator is still on, carefully remove protective
clothing by rolling inside out and place it in a proper
container for disposal. Place Tyvek suits, gloves,
bootcoverings, and head coverings into a labelled waste
disposal container.
If a PAPR or SCBA is worn, removal of protective clothing can
be awkward since the respirator must continue to function. For
a PAPR, remove the belt and harness on which the motor and
filter mount and hold while proceeding to the shower. For an
SCBA, carefully remove the tank assembly and lower to the
ground or balance between legs. Remove coveralls and proceed
to the shower, while holding tank assembly.
With respirator on, proceed to the shower area.
¦ In the Shower Area
For negative pressure respirators, thoroughly shower with the
respirator on; then remove respirator and clean it. Remove
HEPA filter cartridges and dispose of as an asbestos-containing
waste.
For PAPRs or SCBA, hold battery and mechanical parts away from
shower water while rinsing your head and the respirator
facepiece. Remove the respirator facepiece and then wet-wipe
the other components of the PAPR or SCBA. Dispose of HEPA
filter as an asbestos-containing waste.
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If wearing a bathing suit, remove and thoroughly rinse it, and
place in a plastic bag. Finish showering, thoroughly washing
the entire body with soap and water.
Proceed to the clean room.
¦ In the Clean Room
Dress in street clothes.
Entering and Exiting Sites Without a 3-Staee Decontamination System
Often inspections are required at sites where a 3-stage decontamination
system is not available. When confronted with such a site, the inspector must
use his or her judgment regarding the safest method of conducting the
inspection.
¦ Before Entering the Contaminated Area
Make sure the respirator Is operating properly.
Hake sure you have all materials and equipment necessary to
conduct the inspection safely (e.g., protective clothing,
respirator, disposable towels, extra plastic bags, spray
bottle, flashlight, camera etc.). Materials carried into the
work area should be sealed in plastic bags to minimize
contamination.
If you take a camera into the contaminated area, precautions
must be taken to minimize contamination or to decontaminate the
camera. Use of a waterproof camera or sealing a conventional
camera in an impermeable clear camera box will enable more
completed decontamination.
Leave all street clothing on. Short-sleeve shirts and short
pants are preferable. If you are wearing long pants or long
sleeves, roll them up.
Don an inner disposable coverall, footwear, and inner booties
(e.g., Tyvek" or equivalent) over street clothes.
If an SCBA will be used, wear the SCBA with the air valve
closed. Let the respirator facepiece hang from the neck by the
strap.
Don outer disposable coverall. Wear coverall with an
expandable back if an SCBA is used, but do not zip it up. (An
oversize (XXL) tyvek suit may substitute for an expandable
backsuit).
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Don disposable outer boots using duct tape to attach the boots
to the outer coverall. (Tyvek* booties will rip quite easily
once they becomes wet. Disposable rubber boots may be used).
Fit the respirator facepiece to the face, open the air valve of
SCBA, and tighten the facepiece straps. If an air-purifying
respirator is used, conduct negative pressure and positive
pressure field tests.
Fit the coverall hood snugly around the respirator facepiece
and zip up coverall. If using a PAPR, fully-charged power
pack, it should be inside the outer coverall.
Don disposable gloves using duct tape to seal gloves to the
outer coverall.
Proceed into the work area.
Conduct the inspection.
¦ Before Leaving the Contaminated Area
Standing near the exit, HEPA vacuum (if possible) and wet wipe
all visible debris from the outer protective clothing (use a
spray bottle containing water and disposable towels to wet wipe
the suit; use plenty of water). Standing at the doorway inside
the work area, remove outer protective clothing by rolling
inside out, and immediately step outside the area. Place the
suit in a labelled waste container.
¦ Outside the Contaminated Area
Thoroughly wet wipe and mist spray the respirator and inner
disposal coverall. Move away from the doorway and remove the
inner protective clothing. Place the disposable coverall into
a labelled waste container.
Wet and seal all contaminated non-disposable materials in a
plastic bag and take them with you to decontaminate later.
DISPOSAL OF CONTAMINATED CLOTHING
Contaminated or potentially contaminated protective clothing should be
discarded as asbestos-containing waste. These materials include coveralls,
disposable boots, disposable gloves, respirator cartridges, and any other
materials such as paper towels and wet wipes. Usually inspectors discard
their contaminated clothing in waste containers provided by the
owner/operator. Since the owner/operator must treat the waste disposed in
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this container as asbestos-containing, the inspector can assume that the
material he or she discards will be disposed of properly. Although this
procedure is generally acceptable, it is always a good idea to obtain
permission from the owner/operator before discarding contaminated clothing.
Contaminated clothing not disposed of at the site must be placed in
sealed 6-mil plastic bags before leaving the site. The inspector should carry
disposal bags with him or her. The bags containing waste should be stored in
a secure area until arrangements can be made for appropriate disposal.
SAFETY CONSIDERATIONS FOR OTHER HAZARDS
Hazards, in addition to inhalation exposure, are among the safety
concerns of asbestos inspectors. Principle hazards which may confront a
regulatory inspector at demolition or renovation sources include:
¦ Heat Stress--Heat stress is common during operations with high
temperature and humidity conditions. The body's response to heat
stress is to sweat. The loss of too much water and electrolytes in
the sweating process is the main cause of heat illness. Heat stress
may occur quickly when wearing clothing which prevents the
evaporation of sweat. For any inspection which lasts more than
15 minutes in an atmosphere of 70°F or higher, the inspector should
follow heat stress guidelines in the NIOSH Interagency Document on
Health and Safety Guidelines for Hazardous Waste Worker.11
s Climbinp Hazards--In certain situations an inspector may need to
climb to elevated surfaces such as scaffolding, work platforms, or
ladders. OSHA standards require that when free-standing mobile
scaffolding is used, the height shall not exceed four times the
minimum base dimension. For mobile scaffolding, the base dimension
should be one-half the height. Most safety precautions involving
ladders and stairways require common sense. For example, do not
stand on the top step of a ladder, and make sure that ladders are on
solid footing. Additionally, the wearing of a respirator may reduce
the vision of an inspector thereby creating more need for caution
when climbing.
¦ Working Surfaces--A polyethylene covering will be on the floors at
most removal jobs. When wet, this floor covering is very slippery.
Tripping hazards such as air lines and water lines, bags of waste,
stripped asbestos and debris, may also be present.
¦ Lighting--Lighting may be unavailable for pre-removal or
post-removal inspections. In these situations, an inspector uses a
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hand-held flashlight. Hazards of poor lighting include risk of head
injury from suspended objects such as low hanging pipes, light
fixtures, etc. Additionally, poor illumination increases the
possibility of tripping and falling over objects on the floor.
Electrical Safety--Due to the use of wet methods, electrical shock
is a risk in the vicinity of electrical panels, conduits, light
fixtures, alarm systems, junction boxes, computers, and
transformers. Inspectors should ensure that the electrical system
is ground-faulted (as required by OSHA). Common recommendations for
electrical safety include: use of non-conductive sample collection
devices (wood, plastic, rubber); and avoidance of puddles of water
near electrical wires or extension cords.
Falling/Fallen Obiects--Such hazards increase the risk of head
injury from impact. All head protection should meet ANSI Z89.1-1969
safety requirements.
Biological Hazards--Wild animals in abandoned buildings, rats,
snakes, insects.
Chemical Hazards--PCBs. spray poly (intense ammonia smell).
Lack of Oxveen--Crawl spaces.
Unsafe Structures--Floors and stairs in old buildings may be unsafe
and in danger of collapse. The Inspector should take care when
conducting inspections in old or partially demolished buildings.
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SECTION 3
PRE-INSPECTION PROCEDURES
In-offlce activities of a NESHAP inspector prior to onsite inspections
ensure smooth field inspections. Specific activities include reviewing
notifications, tracking non-notifiers, and preparing inspection equipment.
Specific details are presented below.
REVIEW NOTIFICATION
The notification should be reviewed for completeness relative to the
requirements of 61.146. When scheduling an inspection, an inspector should
utilize the ranking and prioritization targeting strategy to select top
priority contractors for inspection. This strategy calls for inspecting
contractors listed pursuant to a CAA section 306 listing action, those
contractors cited for work practice standard violations and notification
violations, contractors who have not sent notification for the last four
quarters, and those contractors who sent in late or deficient notices. An
inspector should also focus particular attention on the following details:
¦ Location of the facility;
¦ Schedule for demolition, renovation or removal; and
¦ Quantity of friable ACM (to determine applicability with the
asbestos NESHAP).
Asbestos removal operations at schools should be coordinated with the
Regional Asbestos Coordinator, if possible, to check for compliance with AHERA
and WPR regulations.
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IDENTIFYING NON-NOTIFIERS
The worst-case violation of the notification requirements of 61.146 would
be the complete failure to notify. The following techniques can be used to
identify non-notifiers as part of their overall inspection activities:
¦ Respond to complaints from the general public, employees, or
competitors who may have recognized a very low bid award. Also,
cross-referral information from other Federal, State and local
agency inspectors.
¦ Drive by the site enroute to or from other inspections while the
demolition/renovation appears to be in progress. The presence of a
roll box for disposal of construction debris is strong evidence of
demolition/renovation activities.
¦ Observe trucks entering landfill and question their origin if
suspected asbestos debris is on board. Regularly conducting
inspections at landfills to review asbestos receiving records will
also provide information on contractors who have notified.
¦ Review of demolition or renovation permits written by the local
building department.
¦ Review of trade journals, newspapers, etc., for ongoing or past
projects.
PREPARATION OF INSPECTION EQUIPMENT
In order to ensure the most efficient and complete inspection possible,
an inspector must gather and pack all equipment necessary for the Inspection.
A detailed list of equipment and explanations of the purpose of each item
follows. A checklist is provided in Appendix D for the convenience of
inspectors.
¦ Employee Identification--Proper credentials to prove authority for
performing the inspection, and any certification cards of
respiratory fit-testing or medical monitoring.
¦ Copy of Asbestos NESHAP Regulation--Helps resolve disagreements if
the owner/operator is unfamiliar with regulations. Also, it is
advantageous to leave a copy with the owner/operator.
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Notebook and Writing Implements--Note that Inspectors should take
notes and fill out checklists to every extent possible before
entering the removal area. (Note: in some situations, it may be
critical to enter the work area quickly to assess potential
violations; in these cases the checklist and notebooks can be filled
out after the inspections). Where practical, leave the notebook and
checklist outside the contaminated area and fill out immediately
after decontamination. Alternatively, plastic clipboards, plastic
transparency sheets and waterproof pens, all of which can be
decontaminated, may be used.
Field Data Collection Checklists--Checklists are useful as a
reminder of the baseline information needed for all inspections.
See Section 5 for further discussion and Appendix D for a copy of a
representative checklist.
Camera (with flash)--Take photographs of sample locations and
visible emission sources. Waterproof cameras are convenient when
wet removal is ongoing, and when decontamination is required.
Flashlight--Work may be conducted in areas with inadequate lighting
such as dark basements, above drop ceilings, and in buildings in
which the electricity may be turned off.
Binoculars--Necessary for offsite observations.
Tape Measure--Inspectors should carry tape measures so that they may
accurately quantify the amounts of friable ACM. As an alternative,
an inspector may pace off distances, and estimate distance based on
a previously measured pace.
Chain-of-Custody Forms and Labels--These forms and labels allow
inspectors to properly distinguish each sample and to maintain a
record of sample possession and transfer.
Shipping Supplies--Samples may be sent to a laboratory from the
field.
SampUnp Equipment--The following equipment and materials are used
for bulk sample collection (refer to Appendix C for further details)
sample containers;
water spray bottle;
adhesive tape;
tools (penknife, tweezers, etc.);
drop cloth;
wet wipes;
plastic bags;
glovebag (for those situations where bags are opened outside
the containment area);
disposable towels; and
camera.
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Safety Equipment--In order to protect yourself from exposure to
asbestos fibers, the EHSD guidance recommends the following items
(refer to Section 2 for further details):
respirator(s);
disposable suits;
disposable gloves;
disposable boots;
hard hat;
safety shoes;
duct tape; and
liquid soap
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SECTION 4
ONSITE FACILITY INSPECTIONS
Onsite facility inspections provide the foundation for all asbestos
NESHAP enforcement actions for substantive violations and are critical to
enforcing NESHAP. Onsite inspections are also used to determine whether
potential AHERA or WPR violations exist. In most cases, it is necessary for
the inspector to enter active removal areas to determine compliance and to
collect evidence of non-compliance with NESHAP. Due to irregularly scheduled
asbestos removal, inspectors may find themselves conducting a pre-removal
inspection if a job is delayed, or a post-removal inspection if a job is
completed ahead of schedule. The following provides step-by-step inspection
procedures common to pre-removal, active removal, and post-removal
inspections. All inspections for the asbestos NESHAP are intended to be
unannounced.
PRE-ENTRY OBSERVATIONS
The pre-entry observations (which may be conducted remotely using
binoculars) enable the inspector to determine the location and type of
activities in progress. Additionally, pre-entry observations provide the
inspector with information regarding the appropriate level of safety equipment
required. The following specific pre-entry observations can be made:
¦ Look for visible emissions to the outside air (from window, doors,
etc.).
¦ Look for suspected asbestos-containing debris outside the removal
area.
¦ Observe waste storage area (dumpsters) and evaluate the quantity and
condition of the waste created.
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¦ Note land use surrounding site in order to assess exposure
liabilities such as residential homes, schools, and playgrounds.
(Diagram in the field notes is useful).
¦ Establish magnitude and location of an asbestos project within the
facility.
¦ Sketch general site layout and areas to be inspected. Verify that
all pertinent locations are incorporated into the inspection plan.
¦ Check safety equipment. It is mandatory that inspectors bring
appropriate safety equipment with them (or have it readily
available). An inspector should never assume that the
owner/operator will supply safety equipment.
PRE-ENTRY INTERVIEW
During the pre-entry interview, which follows the inspector's
announcement of his or her presence onsite, it is critical that discussions
are properly documented. They may later be considered admissions of guilt if
violations are detected. The following steps should be followed once an
inspector arrives onsite:
¦ Request to see the owner/operator or site foreman.
¦ Show credentials and explain the authority and purpose of the
inspection. The authority of these inspections is explicitly given
in Section 114(a)(2) of the Clean Air Act which states EPA
inspectors shall . have a right of entry to, upon, or through
any premises in which an emission source is located . . . "8
(Note: State and local agencies may need to carry specific licenses
or certifications.)
¦ It is EPA's policy that liability waivers are never signed. State
and Local inspectors should refer to the specific policies of their
respective agencies.
¦ Establish identity of all responsible individuals, from the person
you are interviewing through the building owner. Also document the
name and title (address if possible) of all parties with whom you
speak during the inspection. (Collecting business cards of these
individuals is a good practice).
¦ Establish an understanding of the procedures being implemented to
minimize asbestos fiber release. Evaluate the following safety
equipment decision criteria:
Is the work area completely enclosed with plastic sheeting or
equivalent?
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Ac a minimum, are all openings into the work area through a
double entry system (usually two or three sheets of plastic
draped between each stage of entry system)?
Are materials removed from the work area cleaned? Is the
pathway clear through which bags and equipment are removed?
Are all ventilation systems (that have components in the work
area) shut down? Are all vents in the work area taped shut?
Are only wet methods used? That is, no dry scraping should be
conducted, nor wire brushes used on dry materials, nor dry
debris on the floor swept or placed in bags or other containers
in a dry state.
Is some secondary containment in place where glove bagging is
used? If so, the area should be enclosed, but does not need to
be under negative pressure.
¦ Determine the logical sequence of site inspection. Promote overall
efficiency of the inspection. Determine if there are any safety
considerations in addition to those anticipated by the inspectors.
If denied entrance, an inspector should not attempt to be forceful. The
appropriate steps should be: (1) clarify that you have authority to conduct
the inspection under the CAA; (2) indicate that the situation will be turned
over to the regulatory attorney; and (3) state that, if necessary, the agency
will apply for a warrant to gain entry. In some instances, a facility
owner/operator may demand to see proof that an inspector is meeting the
requirements of the OSHA medical monitoring program. Because this is a
reasonable request, inspectors are advised to carry some type of medical
monitoring credential. Note that EPA personnel are not specifically subject
to the OSHA standard, however, the guidelines from EHSD are similar to OSHA
requirements.
Interview Questions
Inspectors will collect vital evidence verbally from the owner/operator.
The following general questions may provide valuable evidence in the event
that violations are detected.
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¦ Has the owner/operator ever engaged in removal of asbestos before?
¦ What formal training has the owner/operator or their staff had
regarding the handling of asbestos?
¦ What is the owner/operator's understanding of the handling of
asbestos during removal?
The inspector should develop additional questions after reviewing
site-specific concerns.
PRE-REMOVAL INSPECTIONS
Facility inspections conducted prior to commencement of asbestos removal
do not enable the inspector to fully evaluate the owner/operator's compliance
with the asbestos NESHAP. However, if an inspector does arrive onsite prior
to removal, useful information can be gathered. In this case, the principle
objectives are to verify that the asbestos NESHAP is applicable, and to gain a
sense of the owner/operator's ability to remove the asbestos within the
constraints of the regulations. As with any inspection, safety must be
considered before the inspection begins. Section 2 of this manual details
specific safety criteria for inspectors. The following summarizes inspection
activities relative to NESHAP requirements:
Evaluate Applicability (61.1451
• Verify that the site meets the definition of a facility under 61.141
"any institutional, commercial or industrial structure,
installation, or building (excluding apartment buildings having no
more than four dwelling units)."
¦ Determine whether the activity is classified as a demolition or
renovation as defined under 61.141.
¦ Measure the amount of suspected friable ACM that is scheduled to be
disturbed to determine if the minimum quantity of 260/160 is
exceeded as defined by 61.145.
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Evaluate Notification (61.146')
¦ Verify that a notification exists and, if so, verify that the
information conveyed verbally during the inspection agrees with the
information provided in the notification.
¦ Determine if the amount of friable ACM designated by the
owner/operator for removal is accurate relative to the amount that
the inspector thinks will potentially be disturbed during the
demolition or renovation.
Evaluate Emission Controls and Work Practices (61.147^
¦ Observe equipment onsite and consider verbal explanations of
emission control procedures to ascertain whether the owner/operator
is sufficiently equipped and knowledgeable to meet the wetting and
handling requirements of 61.147. Consider:
The availability of water for wetting friable ACM before
removal and maintaining wet until collected for disposal;
The methods planned to prevent release of visible emissions to
outside air; and
The type of containers to be used for collection, transport,
and deposition of the waste ACM.
Be aware that the asbestos NESHAP has work practice exemptions that apply
to certain situations. For example, removal of friable ACM is not required if
a building is deemed structurally unsound by a government authority, or if the
friable ACM is encased in concrete. However, the asbestos must still be
adequately wet if exposed during demolition or renovation activities.
Additionally, wetting is not required if it causes unavoidable equipment
damage (must have written approval of the Administrator and use a local
exhaust ventilation system). If the temperature at the point of wetting is
below freezing, facility components must be removed as units or sections to
the maximum extent possible and taken to a separate location for stripping in
accordance with wetting requirements of 61.147(d) and (e) or using a local
exhaust ventilation system in accordance with 61.147(d).
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Evidence Collection
In addition to the general information conveyed by the owner/operator,
the following specific evidence should be collected by an inspector during a
pre-removal inspection:
¦ Measurements of area or linear footage of friable ACM that has been
removed and/or that will be removed for the project, to accurately
document that 260/160 is exceeded (document technique of
measurement, preferably using a tape measure).
¦ Samples of material stated to be friable ACM (collected using
techniques described in Appendix C) to provide legal evidence in
case a owner/operator later states that the notification was
misrepresented. Sketches and/or photographs are advisable to
illustrate specific locations of samples.
¦ Samples of suspect friable ACM including non-friable ACM which has
become friable during the demolition or renovation operation
(collected using techniques described in Appendix C) and that was
not listed by the owner/operator in the notification that an
inspector feels will be disturbed during the demolition or
renovation.
ACTIVE REMOVAL INSPECTIONS
To fully evaluate compliance of the asbestos NESHAP, an inspector must be
prepared to enter the active removal area. The inspector will follow the
procedures discussed previously for pre-inspection observations and
interview. The information gathered during pre-inspection activities will
enable the inspector to select the level of safety equipment and procedures
necessary, as detailed in Section 2, Inspector Safety.
The inspector's principle objectives in entering the active asbestos
removal area are to: (1) make first-hand observations of the adequacy of
wetting and maintaining wetness of the suspect friable ACM until collected for
disposal; (2) determine friability by touch and take samples of any suspect
friable ACM to serve as evidence that a violation involved "friable asbestos
material"; and (3) accurately determine whether the quantity of suspect
friable ACM exceeds the minimum regulated quantity of 260/160.
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Enter Removal Area
Inspectors should prepare to enter the active site only after determining
the level of safety equipment needed. The following steps summarize the
procedures detailed in Section 2, Inspector Safety:
¦ If a three-stage decontamination unit is available, the inspector
will enter the clean room, remove street clothes (except bathing
suit), and suit-up in accordance with the procedures in Section 2.
Street clothes should be stored in a plastic bag to ensure that no
accidental contamination occurs.
¦ If there is not a 3-stage decontamination unit, the inspector will
suit-up with double disposable coveralls over his or her street
clothes following the step-by-step procedures listed in Section 2.
Inspection/Sampling Equipment--
Only items that can be washed or showered should be taken into the active
removal area; all other items should be left outside. Critical inspection and
sampling equipment to bring inside include:
¦ Pre-labeled sample containers (as described in Appendix C);
¦ Waterproof camera - automatic 35mm with flash;
¦ Waterproof clipboard with a plastic sheet on which to write (white
paper inside a zip-lock bag provides a good background);
¦ Indelible marker for taking notes on the plastic sheet; and
m Waterproof flashlight.
This equipment may be carried in a zip-lock bag taped to the side of the
disposable coverall, or through which a belt is strapped.
Evaluate Emission Controls and Work Practices (61.147)
If the owner/operator is not following required work practices, the
inspector must refer to the notification and carefully evaluate whether their
rationale is justified by exceptions in the asbestos NESHAP such as:
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61.145(e)- -If a building is deemed structurally unsound by a
government authority, the friable ACM is not required to be removed
prior to demolition. (However, the contaminated demolition debris
must be handled in accordance with 61.152.)
61.147(a)(1)--Removal of friable ACM is not required if encased in
concrete (this would not include double walls with risers insidfe).
61.147(0)--If wetting will unavoidably cause equipment damage, the
owner/operator must have written approval of the Administrator on
site and must utilize a local exhaust ventilation system.
61.147(f)--If the temperature at the point of wetting is below
freezing (32°F), wetting of asbestos is not required. Adherence to
61.147 (d) and (e) is still necessary.
Unless the owner/operator has obtained written permission from the
Administrator, the owner/operator must comply with the following:
¦ 61.147(b)fl) and (2)--When a facility component covered or coated
with friable ACM is removed from a facility in units or in sections,
wet any friable ACM exposed during cutting or disjointing operations
and carefully lower them to ground level. Do not drop or throw them
¦ 61.147(c) --Adequately wet friable ACM when stripping it from
facility components.
¦ 61.147(e)(1)--Adequately wet friable ACM that has been removed or
stripped to ensure that it remains wet until it is collected for
disposal.
¦ 61.147(e)(2) and (3)--Carefully lower friable ACM that has been
removed or stripped to the ground or lower floor without dropping or
throwing it. If transported from more than 50 feet above ground
level, transport ACM to ground in dust-tight chutes or leak-tight
containers.
Determination of Adequately Wet--
The inspector is responsible for the overall determination of "adequately
wet" relative to the above listed citations from the asbestos NESHAP. It is
important for an inspector to document whether or not material has been
adequately wetted and how this determination was made. To properly document
this determination, the following questions should be addressed:
1. Is water or an aqueous solution being sprayed on or otherwise
applied to friable asbestos being stripped?
35
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2. If an aqueous solution is not being used, why not? (i.e., because
there is no source of water at the facility or the contractor ran
out of portable water and continued to work, or maybe the contractor
prepared the area earlier). The inspector should ask a worker why a
wetting agent is not being used.
3. Describe the condition of the material that is being or has been
stripped. Use photographic, as well as narrative descriptions.
4. Is the stripping or any other action which disturbs the friable
asbestos material producing dust?
5. Is it possible for dust to be emitted from friable asbestos material
which has been stripped from facility components or was visible dust
observed?
6. If an aqueous solution is being used, what equipment is used to
apply it (i.e., is a garden hose used or a plant mister)?
7. Take a sample of asbestos material which is not adequately wet.
Adequately wet this sample. Describe and photograph how the
physical characteristics of the material change (i.e., changes in
color, weight, texture, etc.).
Inspection of Waste Containers--
The presence of a regulatory inspector may cause the owner/operator to
improve wetting operations. Inspectors can evaluate the contents of some
contained waste material to consider wetting operations prior to inspection.
The following protocol should be followed:
• If waste material is contained in transparent poly bags:
Visually inspect contents for evidence of moisture in bag
(water droplets, water in bottom of bag);
Without opening the bag, squeeze chunks of debris to ascertain
whether moisture exists; and
Lift the bag to assess overall weight (a bag of dry friable ACM
can generally be lifted easily by one hand while well-wetted
material in a bag would be substantially heavier).
If dry, open the bag using steps described below and collect a
sample using the procedures specified in Appendix C.
¦ If an opaque container is used:
Request that the owner/operator open a container (the inspector
should select the container); reach inside to feel the material
36
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to assess if it was maintained wet until collected for
disposal. If dry, collect a sample using sampling procedures
described in Appendix C.
If the inspector chooses to open the container, he/she must
carefully open it and then reseal it immediately after
evaluating the contents. If dry, collect a sample using
sampling procedures described in Appendix C.
At the inspector's discretion, a glove-bag may be used to
enclose the waste container prior to opening it. The glove-bag
will serve to contain any fiber release during evaluation
activities.
Evaluate Applicability (61.145)
Violations of the asbestos NESHAP cannot be substantiated until the
inspector has sufficient evidence that the site of asbestos removal meets the
applicability requirements of 61.145. The following specific criteria must be
met:
¦ 61.145(a)--For renovations - if the amount of friable ACM that will
be stripped or removed from a facility exceeds 260/160, then all
notification requirements of 61.146 and emission control
requirements of 61.147 apply.
¦ 61.145(3") --For demolitions - if the amount of friable ACM in the
facility exceeds 260/160, then all notification requirements of
61.146 and emission control requirements of 61.147 apply.
¦ 61.145(b") - -For demolitions - if the amount of friable ACM in the
facility is less than 260/160 (even if no asbestos is present), only
the notification requirements of 61.146 apply.
The definition of demolitions and renovations differ only in that a
demolition specifies that a load-supporting structural member is wrecked or
removed. Under 61.141, definition of a demolition includes any related
handling operations which could be interpreted as any asbestos removal prior
to actual demolition.
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Evaluate for TSCA Compliance
During the Inspection, the inspector can also check for any evidence of
apparent violations of the regulations for AHERA and WFR in order to notify
other asbestos program offices that possible violations exist and an
inspection should be conducted. AHERA regulations apply to asbestos abatement
work conducted at schools. WPR regulations apply to State and local
government employees who take part in asbestos abatement work and are not
covered by the OSHA asbestos standard. Abbreviated checklists for the AHERA
and WPR are Included in Appendix D.
Evidence Collection
The following specific evidence should be collected by an inspector
during an active removal inspection:
¦ Measurements of area and/or length of friable ACM to accurately
document that 260/160 is exceeded (document technique of measurement
preferably using a tape measure).
¦ Samples of material stated to be friable ACM collected (using
techniques described in Appendix C) to provide legal evidence in
case an owner/operator later states that the notification was
misrepresented. Sketches and/or photographs are advisable to
illustrate specific locations of samples.
¦ Samples of suspect friable ACM collected (using techniques described
in Appendix C) to document violations of the work practice
standards. Include specific sample locations.
¦ Samples of suspect friable ACM collected (using techniques described
in Appendix C) which was not listed by the owner/operator in the
notification, if an inspector feels it will be disturbed during the
demolition or renovation.
Exit Removal Area
The inspector will leave the active removal area when satisfied that the
operation complies with the requirements of the asbestos NESHAP or has
collected sufficient evidence (observations, samples, photographs, owner/
operator admissions) if a potential violation exists. It is essential that
38
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the Inspector properly decontaminate himself/herself and any Items taken into
the active removal area that will not be disposed of. The following
procedures summarize the detailed decontamination steps listed in Section 2,
Inspector Safety.
¦ If a 3-stage decontamination unit is available, the inspector will
enter the dirty room, remove disposable clothes (with the exception
of the respirator) and move Into the shower area to shower and
remove respirator. At this time, dispose of cartridges. Dry off
using disposable towels, and move to clean room to dress in street
clothes (see Section 2 for more specific decontamination procedures).
¦ If there is not a three-stage decontamination unit and the inspector
has a double disposable coverall over street clothes, he or she will
remove the outer layer just prior to exiting and the second layer
just after exiting. Wet wipes can be used to clean potential
asbestos fibers from the respirator and face area before removing
the respirator and disposing of cartridges (see Section 2 for more
specific decontamination procedures).
Inspectors should record observations immediately upon departing from the
contaminated area.
Inspect Waste Storage Area
The following are specific regulatory criteria for any source that meets
the applicability requirements of 61.145:
61.147(e)(1^--For friable ACM that has been removed or stripped,
adequately wet the materials to ensure that they remain wet until
they are collected for disposal.
61.152(b)--Discharge no visible emissions to the outside air during
the collection, processing, packaging, transporting, or deposition
of any ACM waste or:
Wet material and seal in leak-tight containers while wet;
Process into non-friable forms;
Use an alternative disposal method subject to approval by the
Administrator.
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If the inspector observes a visible emission, he or she must determine
the source of the visible emission and sample the source to verify that the
source of the emission contains asbestos material. It is not necessary to be
a certified visible emission observer to legally document whether a visible
emission exists. The presence of suspect ACM waste dust on the ground may be
evidence of a visible emission violation. As such, inspectors should document
che existance of any suspect ACM waste exposed to the outside air, including
taking samples and photographs.
Inspection of the contents of a sealed container is a standard inspection
procedure which is necessary to determine that waste material was maintained
wet until collected for disposal during operations previous to the inspector's
onsite observations. To inspect the contents of a sealed container, the
following protocol is recommended:
¦ If contained in transparent poly bags:
Visually inspect contents for evidence of moisture in bag;
Without opening the bag, squeeze chunks of debris to ascertain
whether moisture exists; and
Lift the bag to assess overall weight (bag of dry friable ACM
can generally be lifted easily by hand while a well-wetted
material in a bag would be substantially heavier).
If dry, open the bag using steps described below and collect a
sample using procedures specified in Appendix C.
¦ If an opaque container is used:
Request that the owner/operator open a container chosen by the
inspector, and reach inside to feel the material to assess if
it was maintained wet until collected for disposal. If dry,
collect a sample using sampling procedures described in
Appendix C.
If the inspector chooses to open the container, it should be
opened carefully and a spray mister used to suppress any
potential fiber release from the opening. Collect all
necessary samples, using procedures described in Appendix C,
and reseal the container immediately after completing the
evaluation.
At the inspector's discretion, a glove-bag may be used to
enclose the waste container prior to opening. The glove-bag
will prevent the release of fibers during evaluation activities.
40
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As part of the waste storage area inspection, the inspector should verify
that asbestos waste is not stored in any other areas of the site. The
inspector should also check where the waste will be disposed of to compare
with the location listed in the notification. This information will also
provide the Inspector with the option to schedule a landfill Inspection during
the actual disposal of the waste.
Evidence collection, similar to that previously listed for active removal
inspection, will focus on samples of suspect ACM and some measurement of
quantity that could help support evidence of whether the facility contained
more than 260/160.
POST-REMOVAL INSPECTIONS
Inspection of a facility after asbestos removal has been completed is the
least preferred option; any improper removal which may have occurred would
have already released fibers to the ambient air. However, if an inspector
arrives onsite after removal is complete, useful information can still be
gathered. Buildings scheduled for complete demolition can be inspected to
verify that all asbestos was in fact removed.
The necessary level of safety equipment depends on whether the removal
has been completed to allow reoccupancy. Refer to the specific safety
equipment guidelines provided in Section 2, Inspector Safety.
The following inspection procedures should apply to most post-removal
inspections relative to enforceable paragraphs of the asbestos NESHAP.
Evaluate Applicability (61.145)
¦ Interview the owner/operator to ascertain where friable ACM was
removed from and establish (measure or pace off) that the minimum
quantity of 260/160 was exceeded.
¦ Verify that the site meets the definition of a facility under 61.141
"any institutional, commercial or industrial structure,
installation, or building (excluding apartment buildings having no
more than four dwelling units)."
¦ Determine whether the activity was classified as a demolition or
renovation based on the definitions under 61.141.
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Evaluate Notification (61.146)
Verify that notification exists and that the information conveyed
verbally during the inspection agrees with the information provided
in the notification, especially the start date of the
renovation/demolition.
Evaluate Emission Controls and Work Practices (61.147)
¦ Visually inspect all areas from which friable ACM was said to have
been removed. Verify that all friable ACM was removed. No visible
dust or debris should be left behind.
¦ Visually inspect other areas of the facility that will be disturbed
during the impending demolition or renovation to determine if any
other suspect friable ACM exists (Take samples as necessary, in
accordance with procedures described in Appendix C.) If 260/160 is
not already established, that should be done.
¦ If asbestos waste from the removal is stored onsite, inspect the
containers to determine compliance with 61.147(e)(1), which requires
that friable ACM that has been removed or stripped must be
adequately wet to ensure that the materials remain wet until
collected for disposal.
Inspect Waste Storage Area
If the waste is still stored onsite at the time of a post-removal
inspection, the inspector should inspect the containers to determine
compliance with the asbestos NESHAP. Use safety equipment and procedures
detailed in Section 2, Inspector Safety. The following are specific
regulatory criteria for any source that meets the applicability requirements
of 61.145:
¦ 61.147(e)(1)--For friable ACM that has been removed or stripped,
adequately wet the materials to ensure that they remain wet until
they are collected for disposal.
¦ 61.152(b)--Discharge no visible emissions to the outside air during
the collection, processing, packaging, transporting, or deposition
of any ACM waste or:
Wet material and seal in leak-tight containers while wet;
Process into non-friable forms;
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Use an alternative disposal method subject to approval by the
Administrator.
Inspection of Containers--
¦ Inspect for leaking or ripped bags, or other evidence of asbestos
contamination.
¦ If contained in transparent poly bags:
Visually inspect contents for evidence of moisture;
Without opening the bag, squeeze chunks of debriSrto ascertain
whether moisture exists; and
Lift the bag to assess its weight. (A bag of dry friable ACM
can usually be lifted easily with one hand. Well-wetted
material in a bag would be substantially heavier.)
If dry, open the bag using steps described below and collect a
sample using procedures specified in Appendix C.
¦ If an opaque container is used:
Request that the owner/operator open a container selected by
the inspector. Reach inside to feel the material to assess if
it was maintained wet until collected for disposal. If dry,
collect a sample using sampling procedures described in
Appendix C.
If the inspector chooses to open the container, do so
carefully, using a spray mister to suppress any potential fiber
release. Collect all necessary samples, using procedures
described in Appendix C, and reseal the container immediately
after completing the evaluation.
At the inspector's discretion, a glove-bag may be used to
enclose the waste container prior to opening. The glove-bag
will serve as evidence of any fibers released during evaluation
activities.
Evidence Collection
In addition to the general information conveyed by the owner/operator,
the following specific evidence should be collected by an inspector during a
post-removal inspection:
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¦ Samples of any suspect friable ACM left behind as debris or residue;
¦ Measurements of area and/or length where friable ACM was removed, in
order to establish whether the facility had more than 260/160
removed; and
¦ Samples of any dry friable ACM from the storage area if still
available. Sketches and photographs are advisable to illustrate
specific locations of samples.
POST-INSPECTION INTERVIEW
When the inspection is complete, the asbestos NESHAP inspector should
conduct a quick, concise wrap-up interview to obtain any additional
information necessary to complete the checklist and to convey to the
owner/operator the findings of the inspection. However, the inspector cannot
make conclusive compliance determinations in the field. In situations where
potential violations are identified, it is important to document any response
actions taken by the owner/operator which were observed or verbally
communicated. This information becomes strong evidence in situations where a
follow-up inspection is conducted and similar violations are identified.
If the inspection is of a school and subject to the AHERA regulations,
this is the time to ask if the workers are accredited and to check the
accreditation certificate of the supervisor onsite, and fill out an AHERA
checklist (Appendix D-4). If the workers are covered by the WPR, the
inspector can ask if the environmental monitoring records have been maintained
and if the workers' medical records have been maintained. Fill out an NPR
checklist, such as the one in Appendix D-5. Any apparent violations of AHERA
or the WPR should be referred to the appropriate Federal or State agency.
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SECTION 5
POST-INSPECTION
No matter how blatant a violation or how thorough an inspection, a case
cannot be supported without proper records and documentation. It ,is
Imperative that each delegated program office set up and implement a system
whereby supporting documentation is properly taken, controlled, and
maintained. Generated reports and checklists must be clear and concise, and
accurately support the observations of the inspector. Finally, all records
must be organized, properly maintained, and readily available for future
access. The purpose of this section is to outline procedures to aid in the
process of document control, report preparation, and record maintenance and
storage.
DOCUMENTATION
Checklists and reports generated by an inspector may be the basis of
affidavits for civil or criminal enforcement actions. They must be precise
and legible. NESHAP inspections ultimately involve the actions of several
people including one or more inspectors, administrative and legal staff,
laboratory personnel, and clerical staff. Information must be collected and
maintained within a system that allows for processing and expedient access.
Additionally, this system must protect all records or potential evidence that
may be required for enforcement actions. It is imperative that a
comprehensive document control system be implemented during all phases of an
investigation.
45
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Document Control
The purpose of document control is to make certain that all project
documents Issued or generated during a NESHAP investigation are accounted for
when the project is complete. A system which accounts for all investigation
documents should include serialized document numbering, document inventory
procedures, and an evidentiary filing system. Examples of accountable
documents include:
¦ Inspection Checklists;
¦ Field Logbooks;
¦ Sample Data Sheets;
¦ Sample Tags;
¦ Chain-of-Custody Records and Seals;
¦ Laboratory Notebook and Reports;
¦ Internal Memoranda;
¦ Phone Memoranda;
¦ External Written Communications;
¦ Photographs, Drawings, Maps; and
¦ Quality Assurance Plans;.
Under ideal circumstances, each document is given a serialized number
which is listed in a Document Inventory Logbook.
Cprrmipns t
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corrections made to the original document. Corrections may be made by simply
crossing a line through the error, entering the correct information,
initialing, and dating it.
If documents are lost or missing (a sample tag lost in shipment, or a
chain-of-custody record improperly prepared), a written statement should be
prepared detailing the circumstances. The statement should include all
pertinent available information that may be used to support an observation or
sample. This statement becomes part of the permanent case file.
RECORDS MAINTENANCE
Records need to be properly filed and maintained to allow for quick and
easy access of all case documents. Records also need to be retained under
storage conditions which minimize deterioration or loss of data files. With
the current widespread use of micro-and personal computers, data management
capabilities have improved handling, tracking, and manipulation of large
quantities of information. These systems do not replace physical evidence
(such as tags, forms, and checklists). They do alleviate tedious record
searching and sorting tasks, and can provide quick and easy retrieval of
information, and cross-referencing capability.
Regardless of whether computer-based data management systems or manual
procedures are used, responsible individuals within a program office must be
able to access and trace the destination of project files. The inspector must
be familiar with and use all filing procedures. Files should be signed out
when in use, in such a manner as to indicate to others that the file is in the
possession of an Inspector. When returned to the file storage, the inspector
should take care to return it to its proper place to allow for future easy
access.
INSPECTION REPORTS
Inspection reports and checklists must clearly and concisely document
observations and physical evidence from the inspection. A comprehensive and
properly completed checklist can serve as the inspection report. A
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recommended inspection checklist that serves this purpose is included as
Appendix D. An inspector may supplement the checklist with additional
information such as:
¦ Inspector observations;
¦ Owner/operator admissions;
¦ Description of evidence collected (including techniques used); and
¦ Owner/operator response actions.
In cases where violations are observed, an inspector should supplement
the inspection checklist with an inspection report containing the above
information. It may take a year or longer before a lawsuit is filed and a
detailed narrative of the inspection helps to refresh the inspector's memory
and provides strong evidence for the case.
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SECTION 6
LANDFILL INSPECTIONS
The asbestos NESHAP provides emission control and work practice
requirements from the time the asbestos is disturbed (potentially releasing
airborne fibers) until it is ultimately disposed of in a landfill. The
asbestos NESHAP inspector should be prepared to conduct an inspection of the
disposal site of the ACM waste generated by facilities that are applicable
under 61.145. The asbestos NESHAP specifies that the generator of ACM waste,
not the waste disposal site operator, is responsible for following waste
handling regulations at the disposal site. The following steps should be
followed when Inspecting a landfill that handles asbestos-containing waste
material. A sample checklist for landfill inspections is included in
Appendix D.
REVIEW PERMIT CONDITIONS
Upon entering the site, contact the site operator to determine whether
the landfill has a State-required permit to operate and the expiration date of
the permit. (Although permits are not specifically required under NESHAP,
most states have a permitting process for landfills.) If permitted, document
the requirements of the permit and verify that it meets one of the following
requirements of 61.156:
¦ No visible emissions. Warning signs posted and fencing required
(unless a natural barrier adequately deters access by the public).
¦ 6 inch cover (consisting of a compacted non-asbestos material)
provided within 24 hours of the time the waste was deposited. No
sign posting or fencing required.
¦ Effective resinous or petroleum-based dust suppressant provided
within 24 hours of the time the waste was deposited. Warning signs
posted and fencing required (unless a natural barrier adequately
deters access by the public).
49
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¦ Use of an alternative method previously approved by the
Administrator. Warning signs and fencing required (unless a natural
barrier adequately deters access by the public).
EVALUATE DISPOSAL TECHNIQUES
When disposing of ACM waste from a facility which meets the applicability
requirements of 61.145, the generator must handle the waste in accordance with
the following waste handling requirements:
¦ 61.152(b) --Discharge no visible emissions to the outside air during
the collection, processing, packaging, transporting, or deposition
of any ACM waste or:
Wet material and seal in leak-tight containers while wet;
Process into non-friable forms; or
Use an alternative disposal method subject to approval by the
Administrator.
If 61.152(b) is violated, an inspector must collect a sample. For
example, if emissions from dry friable ACM are visible during deposition, the
sample collected will be analyzed to prove that the suspect friable material
is asbestos. Procedures for sample collection are described in Appendix C.
EVALUATE ASBESTOS WETTING
An inspector may choose to inspect the contents of containers containing
suspect friable ACM to evaluate compliance with the following emission control
and work practice requirement (assuming that the material comes from a
facility that meets the applicability requirements of 61.145):
¦ 61.147 (eWl) - - For friable ACM that has been removed or stripped,
adequately wet the materials to ensure that they remain wet until
they are collected for disposal.
Inspection of the contents of a sealed container is a standard procedure
to determine whether waste material was kept wet until collected for disposal
50
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during operations which took place prior to the inspectors' onsite
observations. When Inspecting the contents of a sealed container, the
following protocol is recommended:
If contained in transparent poly bags:
Visually inspect contents for evidence of moisture;
Without opening the bag, squeeze chunks of debris to ascertain
whether moisture exists; and
Lift the bag to assess overall weight (bag of dry friable ACM
can generally be lifted easily by hand while well-wetted
material in a bag would be substantially heavier).
If dry, open the bag using steps described below and collect a
sample using procedures described in Appendix C.
If an opaque container is used:
Request that the owner/operator open a container selected by
the inspector. Reach inside to feel the material and assess
whether it was kept wet until collected for disposal. If dry,
collect a sample using procedures described in Appendix C.
If the inspector opens the container, it should be done with
caution, and a spray mister used to suppress potential fiber
release from the opening. Collect all necessary samples, using
procedures described in Appendix C, and immediately reseal the
container upon completing the evaluation.
At the inspector's discretion, a glove-bag may be used to
enclose the waste container prior to opening. The glove-bag
will prevent the release of fibers during evaluation.
SURVEILLANCE
Asbestos NESHAP inspectors should consider observing trucks entering
landfills, and question the origin of any suspect ACM waste. This technique
is useful in tracking non-notifiers. In addition, determine if there is
waste from other sites on the truck. Final evidence of a violation will
require the establishment of regulatory applicability of the site from which
the waste was generated. That is, the site must meet the definition of a
facility and the 260/160 quantity requirements.
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REFERENCES*
1. Malmberg, K.B. EPA Demolition & Renovation Inspection Procedures.
Stationary Source Enforcement Division of EPA, Washington, D.C. October
1975.
2. Piper, S.G., and P. Ford. 1988 NESHAP Asbestos Demolition and Renovation
Inspection Workshop - Final Report. Alliance Technologies Corporation.
EPA Contract No. 68-02-4465, Work Assignment No. 21. March 1988.
3. Piper, S.G., e£ Asbestos NESHAP Inspector Safety Workshop - Draft
Final Report. Alliance Technologies Corporation. EPA Contract
No. 68-02-4465, Work Assignment No. 40. June 1988.
4. U.S. Environmental Protection Agency. Asbestos Demolition and Renovation
Enforcement Strategy (Revised). Stationary Source Compliance Division.
Washington, D.C. March 31, 1988.
5. U.S. Environmental Protection Agency. A Guide to Respiratory Protection
for the Asbestos Abatement Industry. Office of Pesticides and Toxic
Substances, Washington, D.C. EPA-560-OPTS-86-001. April 1986.
6. U.S. Environmental Protection Agency. Interim Health and Safety
Guidelines for EPA Asbestos Inspectors (Revised). Occupational Health
and Safety Staff, Office of Administration, Washington, D.C. May 1987.
7. Rabinovitz, S. Clarification of Respirator Recommendations in the
Interim Health and Safety Guidelines for EPA Asbestos Inspectors at
Demolition, Removal and Renovation Operations. Memorandum to Users of
Health and Safety Guidelines for EPA Asbestos Inspectors. Occupational
Health and Safety Staff, Office of Administration, Washington, D.C.
June 6, 1988.
8. 42 USC 1857 seq.
9. U.S. Environmental Protection Agency. Guidance for Controlling
Asbestos-Containing Materials in Buildings. Office of Pesticides and
Toxic Substances, Washington, D.C. EPA-560/5-85-024. June 1985.
R-l
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REFERENCES (continued)
10. U.S. Environmental Protection Agency. Asbestos in Buildings: Simplified
Sampling Scheme for Friable Surfacing Material. Office of Pesticides and
Toxic Substances, Washington, D.C. EPA-560/5-85-030A. October 1985.
11. U.S. Department of Health and Human Services (NIOSH), Occupational Safety
and Health Guidance Manual for Hazardous Waste Site Activities.
DHHS/NIOSH 85-115. October 1985
*Reference 9 called out in Appendix B. References 9 and 10 called out in
Appendix C.
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APPENDIX A
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
(SUBPART M - ASBESTOS)
A-l
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Subpart M—National Emission
Standard for Asbestos
Source: 49 FR 13661, Apr. S, 1984, unless
otherwise noted.
161.140 Applicability.
The provisions of this subpart are
applicable to those sources specified in
%\ 61.142 through 61.153.
$61,141 Definitions.
All terms that are used in this sub-
part and are not defined below are
given the same meaning as in the Act
and in Subpart A of this part.
Active waste disposal site means any
disposal site other than an inactive
site.
Adequately wetted means sufficiently
mixed or coated with water or an
aqueous solution to prevent dust emis-
sions.
Asbestos means the asbestiform vari-
eties of serpentinite (chrysotile), rie-
beckite (croddolite), cummingtonite-
grunerite. anthophyllite, and actino-
lite-tremolite.
Asbestos-containing waste materials
means any waste that contains com-
mercial asbestos and is generated by a
source subject to the provisions of
this subpart. This term includes asbes-
tos mill tailings, asbestos waste from
control devices, friable asbestos waste
material, and bags or containers that
previously contained commercial as-
bestos. However, as applied to demoli-
tion and renovation operations, this
term includes only friable asbestos
waste and asbestos waste from control
devices.
Asbestos material means asbestos or
any material containing asbestos.
Asbestos mill means any facility en-
gaged in converting, or in any interme-
diate step in converting, asbestos ore
into commercial asbestos. Outside
storage of asbestos material is not con-
sidered a part of the asbestos mill.
Asbestos tailings means any solid
waste that contains asbestos and is a
$61,142
product of asbestos mining or milling
operations.
Asbestos waste from control devices
means any waste material that con-
tains asbestos and is collected by a pol-
lution control device.
Commercial asbestos means any as-
bestos that is extracted from asbestos
ore.
Demolition means the wrecking or
taking out of any load-supporting
structural member of a facility togeth-
er with any related handling oper-
ations.
Emergency renovation operation
means a renovation operation that was
not planned but results from a sudden,
unexpected event. This term includes
operations necessitated by nonroutine
failures of equipment.
Fabricating means any processing of
a manufactured product that contains
commercial asbestos, with the excep-
tion of processing at temporary sites
for the construction or restoration of
facilities.
Facility means any institutional,
commercial, or industrial structure, in-
stallation, or building (excluding
apartment buildings having no more
than four dwelling units).
Facility component means any pipe,
duct, boiler, tank, reactor, turbine, or
furnace at or in a facility; or any struc-
tural member of a facility.
Friable asbestos material means any
material containing more than 1 per-
cent asbestos by weight that hand
pressure can crumble, pulverize, or
reduce to powder when dry.
Inactive waste disposal site means
any disposal site or portion of it where
additional asbestos-containing waste
material will not be deposited and
where the surface is not disturbed by
vehicular traffic.
Manufacturing means the combining
of commercial asbestos—or, in the case
of woven friction products, the com-
bining of textiles containing commer-
cial asbestos—with any other
material(s), including commercial as-
bestos, and the processing of this com*
bination into a product.
Outside air means the air outside
buildings and structures.
Particulate asbestos material means
finely divided particles of asbestos ma-
terial.
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40 CFR Ch. I (7-1-88 Edition)
Planned renovation operations
means a renovation operation, or a
number of such operations, in which
the amount of friable asbestos materi-
al that will be removed or stripped
within a given period of time can be
predicted. Individual nonscheduled op-
erations are included if a number of
such operations can be predicted to
occur during a given period of time
based on operating experience.
Remove means to take out friable as-
bestos materials from any facility.
Renovation means altering in any
way one or more facility components.
Operations in which load-supporting
structural members are wrecked or
taken out are excluded.
Roadways means surfaces on which
motor vehicles travel. This term in-
cludes highways, roads, streets, park-
ing areas, and driveways.
Strip means to take off friable asbes-
tos materials from any part of a facili-
ty.
Structural member means any load-
supporting member of a facility, such
as beams and load supporting walls; or
any nonload-supporting member, such
as ceilings and nonload-supporting
walls.
Visible emissions means any emis-
sions containing particulate asbestos
material that are visually detectable
without the aid of instruments. This
does rot include condensed uncom-
bined water vapor.
[49 FR 13661. Apr. 5, 1984; 49 FR 25453.
June 21.19841
8 61.142 Standard Tor asbestos mills.
Each owner or operator of an asbes-
tos mill shall either discharge no visi-
ble emissions to the outside air from
that asbestos mill or use the methods
specified by { 61.154 to clean emissions
containing particulate asbestos materi-
al before they escape to, or are vented
to. the outside air.
§61.143 Standard for roadways.
No person may surface a roadway
with asbestos tailings or asbestos-con-
taining waste material on that road-
way, unless it is a temporary roadway
on an area of asbestos ore deposits.
[49 FR 13661, Apr. 5. 1984; 49 FR 25453.
June 21.19841
Environmental Protection Agency
S 61.144 Standard for manufacturing.
(a) Applicability. This section ap-
plies to the following manufacturing
operations using commercial asbestos.
(1) The manufacture of cloth, cord,
wicks, tubing, tape, twine, rope,
thread, yarn, roving, lap. or other tex-
tile materials.
(2) The manufacture of cement
products.
(3) The manufacture of fireproofing
and insulating materials.
(4) The manufacture of friction
products.
(5) The manufacture of paper, mill-
board, and felt.
(6) The manufacture of floor tile.
(7) The manufacture of paints, coat-
ings, caulks, adhesives, and. sealants,
(8) The manufacture of plastics and
rubber materials.
(9) The manufacture of chlorine.
(10) The manufacture of shotgun
shell wads.
(11) The manufacture of asphalt
concrete.
(b) Standard. Each owner or opera-
tor of any of the manufacturing oper-
ations to which this section applies
shall either:
(1) Discharge no visible emissions to
the outside air from these operations
or from any building or structure in
which they are conducted; or
(2) Use the methods specified by
S 61.154 to clean emissions from these
operations containing particulate as-
bestos material before they escape to,
or are vented to, the outside air.
§ 61.145 Standard for demolition and ren-
ovation: Applicability.
The requirements of if 61.146 and
61.147 apply to each owner or operator
of a demolition or renovation oper-
ation as follows:
(a) If the amount of friable asbestos
materials in a facility being demol-
ished is at least 80 linear meters (260
linear feet) on pipes or at least 15
square meters <160 square feet) on
other facility components, all the re-
quirements of If 61.146 and 61.147
apply, except as provided in paragraph
(c) of this section.
(b) If the amount of friable asbestos
materials in a facility being demol-
ished is less than 80 linear meters (260
linear feet) on pipes and less than 15
A-3
-------
§61.146
§61.147
square meters (160 square feet) on
other facility components, only the re-
quirements of paragraphs (a), (b), and
(c) CD. (2), (3). (4), and (5) of §61.146
apply.
(c) If the facility is being demolished
under an order of a State or local gov-
ernmental agency, issued because the
facility is structurally unsound and in
danger of imminent collapse, only the
requirements in § 61.146 and in para-
graphs (d), (e). (f). and (g) of §61.147
apply.
(d) If at least 80 linear meters (260
linear feet) of friable asbestos materi-
als on pipes or at least 15 square
meters (160 square feet) of friable as-
bestos materials on other facility com-
ponents are stripped or removed at a
facility being renovated, all the re-
quirements of §§61.146 and 61.147
apply.
(1) To determine whether paragraph
(d) of this section applies to planned
renovation operations involving indi-
vidual nonscheduled operations, pre-
dict the additive amount of friable as-
bestos materials to be removed or
stripped over the maximum period of
time a prediction can be made, not to
exceed 1 year.
(2) To determine whether paragraph
(d) of this section applies to emergen-
cy renovation operations, estimate the
amount of friable asbestos materials
to be removed or stripped as a result
of the sudden, unexpected event that
necessitated the renovation.
(e) Owners or operators of demoli-
tion and renovation operations are
exempt from the requirements of
SS 61.05(a). 61.07, and 61.09.
(49 PR 13661, Apr. 5, 1984; 49 FR 25453,
June 21.19841
§ 61.146 Standard for demolition and ren-
ovation: Notification requirements.
Each owner or operator to which
this section applies shall:
(a) Provide the Administrator with
written notice of intention to demolish
or renovate.
-------
40 CFR Ch. I (7-1-M Edition)
rials for subsequent removal. However,
friable asbestos materials need not be
removed before demolition if:
(1) They are on a facility component
that is encased in concrete or other
ttimiiar material; and
(2) These materials are adequately
wetted whenever exposed during dem-
olition.
(b) When a facility component cov-
ered or coated with friable asbestos
materials is being taken out of the fa-
cility as units or in sections:
(1) Adequately wet any friable asbes-
tos materials exposed during cutting
or disjointing operations; and
(2) Carefully lower the units or sec-
tions to ground level, not dropping
them or throwing them.
(c) Adequately wet friable asbestos
materials when they are being
stripped from facility components
before the members are removed from
the facility. In renovation operations,
wetting that would unavoidably
damage equipment is not required if
the owner or operator:
(1) Asks the Administrator to deter-
mine whether wetting to comply with
this paragraph would unavoidably
damage equipment, and, before begin-
ning to strip, supplies the Administra-
tor with adequate information to
make this determination; and
(2) When the Administrator does de-
termine that equipment damage would
be unavoidable, uses a local exhaust
ventilation and collection system de-
signed and operated to capture the
particulate asbestos material produced
by the stripping and removal of the
friable asbestos materials. The system
must exhibit no visible emissions to
the outside air or be designed and op-
erated in accordance with the require-
ments in S 61.154.
(d) After a facility component has
been taken out of the facility as units
or in sections, either
(1) Adequately wet friable asbestos
materials during stripping; or
(2) Use a local exhaust ventilation
and collection system designed and op-
erated to capture the particulate as-
bestos material produced by the strip-
ping. The system must exhibit no visi-
ble emissions to the outside air or be
designed and operated in accordance
with the requirements in ( 61.154.
Environmental Protection Agency
(e) For friable asbestos materials
that have been removed or stripped:
(1) Adequately wet the materials to
ensure that they remain wet until
they are collected for disposal in ac-
cordance with § 61.152; and
(2) Carefully lower the materials to
the ground or a lower floor, not drop-
ping or throwing them; and
(3) Transport the materials to the
ground via dust-tight chutes or con-
tainers if they have been removed or
stripped more than 50 feet above
ground level and were not removed as
units or in sections.
(f) When the temperature at the
point of wetting is below 0*C (32*F):
(1) Comply with the requirements of
paragraphs (d) and (e) of this section.
The owner or operator need not
comply with the other wetting re-
quirements in this section; and
(2) Remove facility components
coated or covered with friable asbestos
materials as units or in sections to the
maximum extent possible.
(g) For facilities described in
§ 61.145(c), adequately wet the portion
of the facility that contains friable as-
bestos materials during the wrecking
operation.
S 61.148 Standard for spraying.
The owner or operator of an oper-
ation in which asbestos-containing ma-
terials are spray applied shall comply
with the following requirements:
(a) Use materials that contain 1 per-
cent asbestos or less on a dry weight
basis for spray-on application on build-
ings, structures, pipes, and conduits,
except as provided in paragraph
-------
§61.150
(2) Discharge no visible emissions to
the outside air from the spray-on ap-
plication of the asbestos-containing
material or use the methods specified
by S 61.154 to clean emissions contain-
ing particulate asbestos material
before they escape to, or are vented to,
the outside air.
(c) The requirements of paragraphs
(a) and (b) of this section do not apply
to the spray-on application of materi-
als where the asbestos fibers in the
materials are encapsulated with a bitu-
minous or resinous binder during
spraying and the materials are not fri-
able after drying.
(d) Owners and operators of sources
subject to this section are exempt
from the requirements of § 161.05(a),
61.07, and 61.09.
(Approved by the Office of Management
and Budget under control number 2000-
0264)
§ 61.149 Standard for fabricating.
(a) Applicability. This section ap-
plies to the following fabricating oper-
ations using commercial asbestos:
(1) The fabrication of cement build-
ing products.
(2) The fabrication of friction prod-
ucts, except those operations that pri-
marily install asbestos friction materi-
als on motor vehicles.
(3) The fabrication of cement or sili-
cate board for ventilation hoods;
ovens; electrical panels; laboratory
furniture, bulkheads, partitions, and
ceilings for marine construction; and
flow control devices for the molten
metal industry.
(b) Standard. Each owner or opera-
tor of any of the fabricating oper-
ations to which this section applies
•hall either.
(1) Discharge no visible emissions to
the outside air from any of the oper-
ations or Jrom any building or struc-
ture in which they are conducted; or
(2) Use the methods specified by
161.154 to clean emissions containing
particulate asbestos material before
they escape to, or are vented to, the
outside air.
• 61.150 Standard for insulating materials.
After the effective date of this regu-
lation, no owner or operator of a facili-
5 61.151
ty may install or reinstall on a facility
component any insulating materials
that contain commercial asbestos if
the materials are either molded and
friable or wet-applied and friable after
drying. The provisions of this para-
graph do not apply to spray-applied
insulating materials regulated under
161.148.
961.151 Standard for wast* disposal for
asbestos mills.
Each owner or operator of any
source covered under the provisions of
161.142 shall:
(a) Deposit all asbestos-containing
waste material at waste disposal sites
operated in accordance with the provi-
sions of § 61.156; and
(b) Discharge no visible emissions to
the outside air from the transfer of as-
bestos waste from control devices to
the tailings conveyor, or use the meth-
ods specified by $ 61.154 to clean emis-
sions containing particulate asbestos
material before they escape to, or are
vented to, the outside air. Dispose of
the asbestos waste from control de-
vices in accordance with { 61.152(b) or
paragraph (c) of this section; and
(c) Discharge no visible emissions to
the outside air during the collection,
processing, packaging, transporting, or
deposition of any asbestos-containing
waste material, or use one of the dis-
posal methods specified in paragraphs
(c) (1) or (2) of this section, as follows:
(I) Use a wetting agent as follows:
(i) Adequately mix all asbestos-con-
taining waste material with a wetting
agent recommended by the manufac-
turer of the agent to effectively wet
dust and tailings, before depositing
the material at a waste disposal site.
Use the agent as recommended for the
particular dust by the manufacturer
of the agent.
(II) Discharge no visible emissions to
the outside air from the wetting oper-
ation or use the methods specified by
( 61.154 to clean emissions containing
particulate asbestos material before
they escape to, or are vented to, the
outside air.
(ill) Wetting may be suspended when
the ambient temperature at the waste
disposal site is less than -9.5'C (15*F).
Determine the ambient air tempera-
ture by an appropriate measurement
A-6
-------
40 CFR Ch. I (7-1-88 Edition)
method with an accuracy of
±*C(±2*P), and record it at least
hourly while the wetting operation is
suspended. Keep the records for at
least 2 years in a form suitable for in-
spection.
(2) Use an alternative disposal
method that has received prior ap-
proval by the Administrator.
S <1.152 Standard for waste disposal for
manufacturing demolition, renovation,
spraying, and fabricating operations.
Each owner or operator of any
source covered under the provisions of
IS 61.144, 61.147, 61.148 and 61.149
shall:
- (a) Deposit all asbestos-containing
waste material at waste disposal sites
operated in accordance with the provi-
sions of § 61.156; and
(b) Discharge no visible emissions to
the outside air during the collection,
processing (including incineration),
packaging, transporting, or deposition
of any asbestos-containing waste mate-
rial generated by the source, or use
one of the disposal methods specified
in paragraphs (b)(1), (2), or (3) of this
section, as follows:
(1) Treat asbestos-containing waste
material with water:
(i) Mix asbestos waste from control
devices with water to form a slurry:
adequately wet other asbestos-contain-
ing waste material; and
(ii) Discharge no visible emissions to
the outside air from collection, mixing,
and wetting operations, or use the
methods specified by § 61.154 to clean
emissions containing particulate asbes-
tos material before they escape to, or
are vented to. the outside air; and
(iii) After wetting, seal all asbestos-
containing waste material in leak-tight
containers while wet; and
(iv) Label the containers specified in
paragraph (b)UKiii) as follows:
CAUTION
Contains Asbestos-
Avoid Opening or
Breaking Container
Breathing Asbestos is Hazardous
to Your Health
Alternatively, use warning labels
specified by Occupational Safety and
Health Standards of the Department
Environmental Protection Agency
of Labor, Occupational Safety and
Health Administration (OSHA) under
29 CFR 1910.1001(g)(2)(ii).
(2) Process asbestos-containing
waste material into nonfriable forms:
(i) Form all asbestos-containing
waste material into nonfriable pellets
or other shapes; and
(ii) Discharge no visible emissions to
the outside air from collection and
processing operations, or use the
methods specified by S 61.154 to clean
emissions containing particulate asbes-
tos material before they escape to. or
are vented to, the outside air.
(3) Use an alternative disposal
method that has received prior ap-
proval by the Administrator.
[49 FR 13661, Apr. 5, 1984; 49 PR 25453.
June 21. 1984, as amended at 51 FR 8199.
Mar. 10,1986]
961.153 Standard for inactive waste dis-
posal sites for asbestos mills and man-
ufacturing and fabricating operations.
Each owner or operator of any inac-
tive waste disposal site that was oper-
ated by sources covered under 161.142,
S 61.144, or {61.149 and received de-
posits of asbestos-containing waste
material generated by the sources,
shall
(a) Comply with one of the follow-
ing:
(1) Either discharge no visible emis-
sions to the outside air from an inac-
tive waste disposal site subject to this
paragraph; or
(2) Cover the asbestos-containing
waste material with at least 15 centi-
meters (6 inches) of compacted nonas-
bes tos-containing material, and grow
and maintain a cover of vegetation on
the area adequate to prevent exposure
of the asbestos-containing waste mate-
rial; or
(3) Cover the asbestos-containing
waste material with at least 60 centi-
meters (2 feet) of compacted nonasbes-
tos-containing material, and
it to prevent exposure of the asbestos-
containing waste; or
(4) For inactive waste disposal sites
for asbestos tailings, apply a resinous
or petroleum-based dust suppression
agent that effectively binds dust and
controls wind erosion. Use the agent as
recommended for the particular asbes-
tos tailings by the manufacturer of
-------
§61.153
the dust suppression agent. Obtain
prior approval of the Administrator to
use other equally effective dust sup-
pression agents. For purposes of this
paragraph, waste crankcase oil is not
considered a dust suppression agent.
(b) Unless a natural barrier ade-
quately deters access by the general
public, install and maintain warning
signs and fencing as follows, or comply
with paragraph (a)(2) or (a)(3) of this
section.
(1) Display warning signs at all en-
trances and at intervals of 100 m (330
feet) or less along the property line of
the site or along the perimeter of the
sections of the site where asbestos-con-
taining waste material was deposited.
The warning signs must:
(i) Be posted in such a manner and
location that a person can easily read
the legend; and
(ii) Conform to the requirements for
51 cmx36 cm <20"xl4") upright
format signs specified in 29 CFR
1910.145(d)(4) and this paragraph; and
(iii) Display the following legend in
the lower panel with letter sizes and
styles of a visibility at least equal to
those specified in this paragraph.
Lagand
Notation
Aatmtoa Waste Dapoaal Sta.
2.S cm (1 inch) Sana Sarit.
Gothic or Block
Do Not Oraata Dual
t.S cm (V. inch) Sana Sarrf.
Gothic or Block
BraaMng Aabaatot • Haz-
>4 Point Gothic
ardoua to Your Haalth.
Spacing between any two lines must
be at least equal to the height of the
upper of the two lines.
(2) Fence the perimeter of the site in
a manner adequate to deter access by
the general public.
(3) Upon request and supply of ap-
propriate information, the Administra-
tor will determine whether a fence or
a natural barrier adequately deters
access by the general public.
(c) The owner or operator may use
an alternative control method that
has received .prior , approval of the Ad-
ministrator rather than comply with
the requirements of paragraph (a) or
(b) of this section.
§61.154
161.154 Air-cleaning.
(a) The owner or operator who elects
to use air-cleaning, as permitted by
Sfi 61.142, 61.144(b)(2), 61.147(C)(2),
61.147(d)(2), 61.148(b)(2), 61.149
-------
40 CFR Ch. I (7-1-88 Edition)
equipment in filtering particulate as-
bestos material.
(49 FR 13661, Apr. S. 1984; 49 FR 25453,
June SI, 1984. as amended at 51 PR 8199,
Mar. 10,19861
161.155 Reporting:.
(a) Within 90 days after the effec-
tive date of this subpart, each owner
or operator of any existing source to
which this subpart applies shall pro-
vide the following information to the
Administrator, except that any owner
or operator who provided this infor-
mation prior to April 5. 1984 in order
to comply with { 61.24 (which this sec-
tion replaces) is not required to resub-
mit it.
<1) A description of the emission
control equipment used for each proc-
ess; and
(2) If a fabric filter device is used to
control emissions, the pressure drop
across the fabric filter in inches water
gage; and
(i) If the fabric device uses a woven
fabric, the airflow permeability in ma/
min/m* and; if the fabric is synthetic,
whether the fill yarn is spun or not
spun; and
(ii) If the fabric filter device uses a
felted fabric, the density in g/m*. the
minimum thickness in inches, and the
airflow permeability in m3/min/ms.
(3) For sources subject to SS 61.151
and 61.152:
(i) A brief description of each proc-
ess that generates asbestos-containing
waste material; and
(ii) The average weight of asbestos-
containing waste material disposed of,
measured in kg/day; and
(iii) The emission control methods
used in all stages of water disposal;
and
(iv) The type of disposal site or in-
cineration site used for ultimate dis-
posal, the name of the site operator,
and the name and location of the dis-
posal site.
(4) For sources subject to § 61.153:
(i) A brief description of the site;
and
(ii) The method or methods used to
comply with the standard, or alterna-
tive procedures to be used.
(b) The information required by
paragraph (a) of this section must ac-
Environmental Protection Agency
company the information required by
§61.10. The information described in
this section must be reported using
the format of Appendix A of this part.
(Approved by the Office of Management
and Budget under control number 2000-
0264)
(Sec. 114. Clean Air Act as amended (42
U.S.C. 7414))
§61.156 Active waste disposal sites.
To be an acceptable site for disposal
of asbestos-containing waste material
under §S 61.151 and 61.152, an active
waste disposal site must meet the re-
quirements of this section.
(a) Either there must be no visible
emissions to the outside air from any
active waste disposal site where asbes-
tos-containing waste material has been
deposited, or the requirements of
paragraph (c) or
-------
§61.156
Spacing between any two lines must
be at least equal to the height of the
upper of the two lines.
(2) The perimeter of the disposal
site must be fenced in a manner ade-
quate to deter access by the general
public.
(3) Upon request and supply of ap-
propriate information, the Administra-
tor will determine whether a fence or
a natural barrier adequately deters
access by the general public.
(c) Rather than meet the no visible
emission requirement of paragraph (a)
of this section, an active waste dispos-
al site would be an acceptable site if at
the end of each operating day, or at
least once every 24-hour period while
the site is in continuous operation, the
asbestos-containing waste material
which was deposited at the site during
the operating day or previous 24-hour
period is covered with either.
(1) At least 15 centimeters (6 inches)
of compacted nonasbestos-containing
material, or
(2) A resinous or petroleum-based
dust suppression agent that effectively
binds dust and controls wind erosion.
This agent must be used as recom-
mended for the particular dust by the
manufacturer of the dust suppression
agent. Other equally effective dust
suppression agents may be used upon
prior approval by the Administrator.
For purposes of this paragraph, waste
crankcase oil is not considered a dust
suppression agent.
(d) Rather than meet the no visible
emission requirement of paragraph (a)
of this section, an active waste dispos-
al site would be an acceptable site if
an alternative control method for
emissions that has received prior ap-
proval by the Administrator is used.
(Sees. 112 and 301(a) of the Clean Air Act as
amended (42 UJ&.C. 7412, 7601(a))
A-10
-------
APPENDIX B
QUANTITIES AND USES OF ASBESTOS
During the course of NESHAP inspections, inspectors should be aware of
various commercial uses and applications of asbestos products. Recognizing
the various appearances, compositions, uses, and application techniques can
assist the inspector in identifying friable ACM. The following information
should assist inspectors in recognizing ACM, whether intact or disturbed.
Approximately 66 percent of all asbestos is used in cement products, flat
sheets or sidings, tiles, corrugated roofing sheets, rainwater pipes, gutters,
and pressure piping. These products generally contain 10 to 15 percent by
weight asbestos fibers, which function as a fibrous reinforcement in the
cement. A list of specific uses of asbestos and associated binders in
building materials appears in Table B-l. Both EPA and OSHA define ACM as any
material with greater than 1 percent by weight asbestos.
The following principle categories of asbestos use in buildings may be
subject to the asbestos NESHAP if the building is renovated or demolished.
These categories are surfacing materials, thermal insulation, and
miscellaneous building materials.
ASBESTOS SURFACING MATERIALS
Asbestos-containing surfacing materials are coatings which were applied
by trowel to steel I-beams, decks, concrete ceilings and walls, and other
surfaces. The coatings were applied as thermal insulation fireproofing,
soundproofing, and for decorative purposes.
B-l
-------
TABLE B-l. ASBESTOS-CONTAINING MATERIALS FOUND IN BUILDINGS9
Subdivision Generic name
Surfacing material sprayed- or
troweled-on
Preformed thermal batts, blocks, and
insulating products pipe covering
85% magnesia
calcium silicate
Textiles cloth
blankets (fire)
felts:
blue stripe
red stripe
green stripe
sheets
cord/rope/yarn
tubing
tape/strip
curtains
(theatre, welding)
Cementitious extrusion panels:
concrete-like products corrugated
flat
flexible
flexibly perforated
laminated
(outer surface)
roof tiles
clapboard and shingles:
clapboard
siding shingles
roofing shingles
pipe
Paper products corrugated:
high temperature
moderate temperature
indented
millboard
Roofing felts smooth surface
mineral surface
shingles
pipeline
Asbestos (%) Dates of use Binder/siting
1-95 1935-1970 sodium silicate,
Portland cement,
organic binders.
15
1926-1949
magnesium carbonate
6-8
1949-1971
calcium silicate
100
1910-present
none
90-95
1920-present
cotton/wool
80
1920-present
cotton
90
1920-present
cotton
95
1920-present
cotton
50-95
1920-present
cotton/wool
80-100
1920-present
cotton/wool
80-85
1920-present
cotton/wool
90
1920-present
cotton/wool
60-65
1945-present
cotton
8
1965-1977
Portland cement
20-45
1930-present
Portland cement
40-50
1930-present
Portland cement
30-50
1930-presen;
Portland cement
30-50
1930-preseni
pcrtland cement
35-50
1930-preseni
Portland cement
20-30
1930-present
Portland cement
12-15
1944-1945
Portland cement
12-14
unknown-present
Portland cement
20-32
unknown-present
protland cement
20-15
1935-present
Portland cement
90
1935-present
sodium silicate
35-70
1910-present
starch
98
1935-present
cotton and organic binder
80-85
1925-present
starch, lime, clay
10-15
1910-present
asphalt
10-15
1910-present
asphalt
1
1971-1974
asphalt
10
1920-present
asphalt
B-2
-------
TABLE B-l (continued)
Subdivision
Generic name
Asbestos (%)
Dates of use
Binder/sizing
Asbestos-containing
caulking putties
30
1930-present
linseed oil
compounds
adhesive (cold applied)
5-25
1945-present
asphalt
joint compound
1945-1975
asphalt
roofing asphalt
5
unknown-present
asphalt
mastics
5-25
1920-present
asphalt
asphalt tile cement
13-25
1959-present
asphalt
roof putty
10-25
unknown-present
asphalt
plaster/stucco
2-10
unknown-present
Portland cement
spackles
3-5
1930-1975
starch, casein, synthetic
resins
sealants fire/water
50-55
1935-present
caster oil or polyisobutylene
cement, insulation
20-100
1900-1973
clay
cement, finishing
55
1920-1973
clay
cement, magnesia
15
1926-1950
magnesium carbonate
Asbestos ebony products
50
1930-present
Portland cement
Flooring tile and
vinyl/asbestos tile
21
1950-present
poly(vinyl)chloride
Sheet Goods
asphalt/asbestos tile
26-33
1920-present
asphalt
sheet goods/resilient
30
1950-present
dry oils
Wallcovering
vinyl wallpaper
6-8
unknown-present
—
Paints and coatings
roof coating
4-7
1900-present
asphalt
air tight
15
1940-present
asphalt
B-3
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Sprayed coatings are typically rough and fluffy in appearance, while
trowelled coatings have a smooth finish and may be covered with a layer of
plaster or other non-asbestos material. Both sprayed and trowelled asbestos
coatings are friable in most applications. Most spray-applied asbestos
coatings were banned for fireproofing/insulating in 1973, and for decorative
purposes in 1978. Figure B-l illustrates a typical asbestos surfacing
material on an I-Beam and corregated steel deck.
Figure B-l. Sprayed-on insulation on I-beam and steel deck.
THERMAL INSULATION SYSTEMS
Thermal insulation systems include materials applied to pipes, fittings,
boilers, breechings, tanks, ducts, and other interior or exterior structural
components which prevent heat loss or gain, or water condensation. These
materials are present in a wide variety of forms. The following examples of
typical forms of thermal insulation are based on product categories.
B-4
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Pipe Insulation
Preformed pipe coverings with an average asbestos content of about
50 percent were used for thermal insulation of steam pipes in industrial,
commercial, institutional, and residential applications. This product is
usually white and chalky in appearance and typically in 3-foot long,
half-round sections, joined around the pipe using plaster-saturated canvas or
metal bands. Figure B-2 is a typical example of a preformed pipe insulation.
This covering was applied on straight pipe sections, while wet-applied
coatings were used on elbows, flanges, and other irregular surfaces. The
installation of wet-applied and preformed asbestos insulations was banned in
1975.
Other types of pipe insulation are manufactured from asbestos-containing
felts and paper. An example of a canvas covered asbestos fiber felt is
illustrated in Figure B-3. Asbestos-containing paper products are
manufactured on conventional papermaking equipment and use asbestos fibers
rather than cellulose. The typical asbestos-paper pipe covering looks and
feels like corrugated cardboard and is generally rolled onto the pipe in
several layers. It is usually held in place with metal bands. Figure fi-4 is
an example of this type of pipe insulation.
Boilers and Hot Water Tanks
Preformed block insulation was used as thermal insulation on boilers, hot
water tanks, and heat exchangers in industrial, commercial, institutional, and
residential applications. These blocks are commonly chalky white, 2 inches
thick, from 1 to 3 feet square. They are often held in place around the
boiler by metal wires or expanded metal lath. A plaster-saturated canvas was
often utilized as a final covering or wrap. An illustration of boiler
insulated with blocks covered with plaster is provided in Figure B-5. The
installation of this type of asbestos insulation was banned by EPA in 1975.
Elbows. Valves and T-Flttlnes
Batch mixed ACM was trowel-applied to Irregular joints on thermal
B-5
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Figure B-2. Preformed asbestos pipe insulation with canvas wrap.
Figure B-3. Canvas wrapped asbestos felt insulation on a pipe.
B-6
-------
Figure B-4. Corrugated asbestos paper pipe wrap.
Figure B-5. Asbestos insulation on a boiler and pipes.
B-7
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Insulation systems including elbows, valves and T-fittings. They are often
covered with a canvas wrap or other covering similar to the adjacent pipe wrap
which may make it difficult to distinguish from the material in the straight
runs. It is not uncommon to find asbestos-containing "elbow mud" or "lagging"
adjacent to straight-runs of non-asbestos pipe insulation. Figure B-6
presents an example of trowel-applied pipe lagging on the valve with premolded
pipe insulation is on straight lengths of pipe.
Figure B-6. Trowel-applied pipe lagging.
MISCELLANEOUS BUILDING MATERIALS
Miscellaneous materials may consist of other friable or non-friable
asbestos-containing building materials. Friable miscellaneous materials
include ceiling tiles such as the 2 ft x 3 ft dropped ceiling tiles and the
1 ft x 1 ft glue-in panels. It is estimated that 5 to 10 percent of currently
installed ceiling tiles contain asbestos.
B-8
-------
Typical non-friable miscellaneous asbestos materials include floor tiles,
asbestos cement sheet (transite), and asphalt roofing shingles. Generally,
the asbestos in these products is tightly bound and non-friable. These
materials may become friable during the course of demolition or renovation.
Non-friable materials must be evaluated on a case-by-case basis for their
potential to become friable.
B-9
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APPENDIX C
ASBESTOS BULK SAMPLING AND ANALYSIS
The purpose of bulk sampling is to determine and document if friable
material contains regulated amounts of asbestos (>1 percent by weight). This
is critical when investigating a potential violation. Samples should be
collected when a violation is suspected or an enforcement action is
anticipated. The results obtained from that sample serve as evidence that the
material in question contains asbestos and is subject to regulation.
PROTECTIVE EQUIPMENT
The EHSD Guidelines for EPA Asbestos Inspectors specifies personal
protective equipment recommended for persons collecting bulk samples. These
recommendations are summarized below. For further details, refer to Section
2, Inspector Safety.
¦ Protective Clothing--Inspection personnel should wear the following
protective clothing when collecting bulk samples in active abatement
environments. Inspectors may choose to wear less protective
clothing for non-abatement inspections or may defer to more
stringent guidelines if the situation warrants:
Disposable, full-length, hooded coverall (TyvekR or
equivalent);
Disposable inner boots;
Disposable gloves;
C-l
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Hard hat, safety glasses, safety shoes, and ear protection, as
required by the site.
¦ Respiratory Protection--At a minimum, inspectors collecting bulk
samples should wear air purifying cartridge respirators. Cartridges
must be NIOSH-approved for asbestos environments. More stringent
protection should be used if necessary.
¦ Disposable Towels--For use after showering.
SAMPLING EQUIPMENT
The following items are recommended for inclusion in the inspector's
sampling kit:
¦ Sample Containers--Anv dry, sealable, and clean container such as a
35mm film canister, plastic vial, or whirlpak bag.
¦ Water Sorav Bottle--For wetting a surface prior to sampling to
prevent generation of dust (may use a surfactant).
¦ Adhesive Tape--To seal the sample container and to temporarily
repair a sampled area, such as a pipe wrap.
¦ Tools--Tools such as metal tweezers, a pen knife, coring device,
scissors, etc.
¦ Wet Wipes--To clean tools between samples, as well as to
decontaminate equipment, sample containers, etc., when leaving the
sampling area.
¦ Plastic Bags--To place potentially contaminated waste generated
during the sampling exercise. The bags should be properly sealed
and disposed of as ACM. Zip-lock bags are also useful for placing
sample containers for delivery or shipment to the laboratory.
¦ Documentation Material--Notebook or clipboard, inspection checklist,
sample labels, chain-of-custody forms, and pens.
¦ Spray Paint--For identification of sample sites on photographs.
The above items are considered essential and should be included in every
sampling kit. Other items such as specialty corers, hammer and chisel, and
vinyl tile knives may be helpful during the inspection. Appendix D provides a
comprehensive inspection equipment checklist.
C-2
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COLLECTION TECHNIQUES
The asbestos NESHAP regulation does not provide any specific
recommendations for collecting bulk samples. Procedural guidelines for site
selection and sample collection can be found in the FHSD Interim Health and
Safety Guidelines for EPA Asbestos Inspectors, in the TSCA publications
entitled Guidance for Controlling Asbestos-Containing Materials in
Buildings.9 and Asbestos in Buildings: Simplified Sampling Scheme for
Friable Surfacing Material.10. The TSCA guidelines are geared towards
environments which are neither contaminated nor disturbed, such as those
encountered during asbestos school inspections, pre-abatement inspections, and
pre-demolition inspections. Asbestos NESHAP inspectors will inspect both
non-abatement situations and abatement inspections.
Non-Abatement Inspections
Nonabatement inspections are conducted less frequently than abatement
inspections. Extensive guidance is available through the TSCA Asbestos-in-
Schools program. The most direct sources of information on non-abatement
inspections are References 9 and 10.
Abatement Inspections
The samples collected during active abatement inspections include
materials which have been removed or disturbed. The environments in which
these samples are collected are usually not conducive to formal random
sampling approaches such as those used during pre-abatement and TSCA
inspections. The representativeness of enforcement samples is usually based
on the judgment of the inspector. Because the goal of collecting enforcement
samples is to determine and document whether materials associated with a
violation contain greater than 1 percent asbestos, this subjective approach is
warranted and appropriate. This approach does not exempt the inspector from
following some general rules when collecting enforcement samples, including:
C-3
-------
¦ Wear proper safety equipment, including disposable coveralls,
overshoe boots, gloves, and a properly selected respirator. A hard
hat, safety shoes, protective glasses, and ear protection may also
be necessary.
¦ Collect samples of materials where a violation or suspected
violation is observed.
¦ Understand that different types of friable ACM may be removed at the
same abatement project. Collect representative samples of each
different type of suspect material associated with a violation or
suspected violation.
¦ Collect multiple samples if possible. A minimum of three samples of
each type of material encountered is recommended.
¦ Collect a complete core or cross-section of the material.
¦ Spray the area to be sampled with a water mist or amended water mist
to minimize fiber release. This is done primarily to reduce
inspector exposure.
¦ Use sampling equipment listed in Appendix D checklist.
¦ After sampling is completed, wipe the outside of the container with
a wet wipe or damp cloth. Wipe tools between sampling points.
¦ Record a unique I.D. number on a label and affix to the container.
Tape the label to prevent it from peeling off and tape the lid shut.
¦ Photograph the sampling location(s). If necessary, take a second
photograph with a reference point. The inspector can also use
bright spray paint to indicate the sampling point.
¦ Complete all documentation including checklist entries and
chain-of-custody form. A sample chain-of-custody form is shown in
Figure C-l. Samples must be secured if making more than one
inspection.
¦ Dispose of all sampling waste as asbestos-containing waste.
Not all samples must be analyzed. It is advisable to collect extra
samples and only analyze enough to satisfy the evidence requirements. Samples
may be analyzed at a later time if necessary.
C-4
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BULK SAMPLE ANALYSIS
The analysis of a bulk sample Is intended to detect the quantity (percent
by area), as well as the specific type of asbestos for each sampled area. The
NESHAP standard contains no specific method for the analysis of bulk samples
for asbestos. EPA's policy has been to adopt the procedure published in
40 CFR Part 763 Appendix A entitled Interim Method for the Determination of
ftsbestos in Bulk Insulation Samples. This procedure is an optical microscopy
technique known as polarized light microscopy (PLM).
The general principals of PLM are as follows:
¦ Based on optical crystallographic properties, the PLM method must be
performed by a microscopist with formal training in Optical
Mineralogy.
¦ PLM gives a qualitative differentiation between asbestos and
non-asbestos fibers along with a quantitative estimate of percent
asbestos by area.
In no case should asbestos field test kits be used to confirm the
presence or absence of asbestos. The solutions age and may indicate false
negative results.
Results from PLM analysis are interpreted as follows:
¦ If one or more samples from a homogeneous suspect ACM contains
greater than 1 percent asbestos, then consider the entire material
to contain asbestos.
¦ If a doubt exists, or if further information is needed, reanalyze
samples or collect additional samples.
QUALITY ASSURANCE
stipple I .P. Numbers
Assign a unique sample I.D. number to each sample. A non-systematic
(random) numbering scheme is recommended, the purpose of which is to eliminate
C-5
-------
the potential for bias on the part of a microscopist. For example, if a
numbering system indicates that seven samples were from the same room, the
microscopist may not be objective about each individual sample.
Chain-of-Custodv Forms
In order to ensure that the samples are properly identified and tracked
from the point of sample collection through receipt by the analytical
laboratory, EPA requires that a chain-of-custody form is completed and
accompanies the samples. Figure C-l is a sample chain-of-custody. Any form
can be used that contains the essential items such as: identification number,
date, name of sampler and signature of recipient. Chain-of-custody forms must
be completed in the field and accompany the samples when they leave possession
of the inspector.
Quality Control (00 Samples
Collection of side-by-side duplicates are recommended at the rate of 1 qc
sample/building or 1 QC sample/20 samples, whichever is larger. The
laboratory should analyze duplicates without knowing which are the QC
samples. The results of duplicates are compared to determine sampling and
analytical precision. For additional QC, split side-by-side duplicates with a
second laboratory to confirm the results of the first analyses. Any
disagreements generated by the QC effort must be investigated; samples should
be reanalyzed, or additional samples collected.
Accredited Laboratories
Accredited laboratories should be used for the analysis of bulk samples
as required under EPA's AHERA regulations, 40 CFR Part 763, Subpart E. A
listing of accredited laboratories is published by EPA twice per year. It is
available through the EPA Regional Asbestos Coordinator or the TSCA Hotline
(202)-554-1404.
C-6
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CHAIN OF CUSTODY RECORD
Prajict C»de
fniwt Nmm
/ / / / / / / / / / REMARKS
SAMPLERS (S«Mt«n>
I.D.
NO.
DATE
TIME
LOCATION
¦
-
Relmqiiiilied by. (SifiMtufe)
Dtlc/Timc
Recuvttf by: (Si|niiui«)
Relinquished by: (Signature)
Date/Time
Received by (Statute)
Relinquished by: {Siffutore)
D*ie/Time
Received by: (Sifnetuie)
Relinquished by (Signature)
Om/Time
Received by (Si)fieluie)
Relinquished by: (Signature)
Oatt/Timc
Received lor Uboutoiy by:
(Sifntluie)
Dtte/1
ime
Remtrki
Figure C-l. Representative chain-of-custody record.
-------
APPENDIX D
FIELD INSPECTION CHECKLISTS
D-l
-------
APPENDIX D-l
INSPECTION EQUIPMENT CHECKLIST
D-2
-------
ASBESTOS NESHAP
DEMOLITION AND RENOVATION
INSPECTION EQUIPMENT CHECKLIST
General Tngr«>rHon Enulpm^i-
— Employee I. D.
— Copy of Regulation
Field notebook
Pens/pencils
Inspection Checklist
Camera/flash
Flashlight
—. Tape measure
— Clipboard (plastic coated)
Duct tape
— Disposable towels
Mylar sheets
Waterproof marker
Safety Equipment-
r^Xm£grlfylne negative pr"sure "¦*»**
SCBA (pressure demand type)
_— Respirator cartridges
Disposable full-body coveralls
Disposable boots
Hard hat
Safety glasses
— Safety shoes
Plastic garbage/asbestos waste bags (preferably 6 mil)
Sampling Eauipmftfifr
Sample containers
Water spray bottle
Cellophane tape
~~ I?°ls ^pen knife, tweezers, borers)
Plastic drop cloths
Wet wipes
_ Zip-lock bags
Chain-of-Custody forms
Sample labels
Spray paint
Shipping supplies
D-3
-------
APPENDIX D-2
FACILITY INSPECTION CHECKLIST
D-4
-------
ASBESTOS DEMOLITION AND RENOVATION (D/R) Page 1 of 11
FIELD DATA COLLECTION CHECKLIST
Site Name: Inspector(s):
Location: Date of Inspection:
Time of Inspection:
Weather Conditions:
Notification Received: Yes (date) No
Reason for Inspection:
Citizen Complaint State Oversight/Joint
Routine Compliance Inspection Suspected Non-Notifier
Other (explain)
I. PRELIMINARY OBSERVATIONS (before announcing arrival)
1. Visible Emissions to the Outside Air Observed? Yes No
If yes, describe specific location (e.g., door, window, waste
storage area, etc. - use sketch area provided on page 2)
2. Suspect ACM Debris Observed Outside Removal Area Yes No
If yes, describe (e.g., location estimated, quantity, etc.)
D-5
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SKETCH
Page 2 of 11
3. Land use surrounding site (i.e., residential, homes, schools,
businesses, etc.):
a. Distance to the closest residence/public building from the D/R
site:
b. Number of residences or occupied buildings surrounding the area:
c. Distance to pedestrian walkway, street, or thoroughfare from
site:
d. Any additional information indicating potential public exposure:
D-6
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Page 3 of 11
4. Building/Structure Information
a. Use (office, retail, industry, school, etc.)
b. Physical description of the building. (Include a brief
description of building involved, i.e., number of floors,
dimensions, etc.)
c. Age--Constructed: Renovated:
II. PRE-INSPECTION INTERVIEW (after announcing arrival)
1. Show Credentials: Yes No
2. Name and position of person being interviewed (include company name):
3. Establish Identity of Owner/Operator(s)
a. Owner name:
b. Main contact person and title:
c. Mailing address:
City State Zip Code
d. Telephone (include area code):
4. Are there any changes/modifications to the information provided in
the notification:
Are there any discrepancies in the information:
D-7
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Page 4 of 11
5. Prime Contractor (provide information for each contractor related to
the D/R job):
a. Company name:
b. Main contact person and title:
c. Mailing address: _
City State Zip Code
d. Telephone (include area code):
e. Responsibilities at job:
f. Number of employees involved in job:
g. Number of employees trained in asbestos removal onsite: ^______
h. Supervisor training:
6. Subcontractors onsite (provide information for each subcontractor
related to the D/R job and function (i.e., hygienist, consultant,
etc.):
a. Company name:
b. Main contact person and title: __
c. Mailing address:
City State Zip Code
d. Telephone (include area code): __
e. Responsibilities at job:
f. Number of employees involved in job:
g. Number of employees trained in asbestos removal onsite:
D-8
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Page 5 of 11
h. Supervisor training:
7. Other persons with control over D/R operations at facility (i.e.,
parent company, hiring, agent, etc.)
a. Name
b. Address
c. Responsibilities
8. Activity Description:
a. Is there more than one project occurring at the facility?
Yes No
If yes, complete a separate checklist for each or differentiate
accordingly.
b. Demolition Renovation Condemned
c. Describe the project(s) and indicate the current phase of the
project:
d. Describe type of abatement involved (removal or encapsulation):
III. SITE INSPECTION OBSERVATIONS
A. Tvoe of ACM
Pipe lagging Sprayed on Block insulation
Ceiling tiles Other
B. Quantity Determinations
1. Linear footage of friable ACM present on pipes*:
*Use Attachment A to provide additional detail, if desired.
D-9
-------
Page 6 of 11
2. Square footage of friable ACM present on other facility components*:
3. Method of measuring or estimating amount of friable ACM present:
C. Removal Procedures
1. Structurally unsound building: Yes No
If yes, name of governmental authority designating it as condemned
and emission control procedures being implemented:
If yes, were there visible dust emissions? Yes No
2. Encased in concrete: Yes No
If yes, describe emission control procedures being implemented:
3. Unit/section removal: Yes No
If yes, describe the procedures being implemented:
4. Stripping in place: Yes No
If yes, describe the procedures being implemented:
D-10
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Page 7 of 11
D. Emission Control Procedures (61.147)
1. Temperature at point of wetting: Below 32#F Above 32°F
If below 32°F, are there visible dust emissions? Yes No
2. Has owner/operator been granted permission for alternate emission
control techniques: Yes No
If yes, who granted authority and what alternative emission control
techniques are being implemented:
If yes, are there visible dust emissions to the outside air?
Yes No
3. If wetting practices are used, evaluate the adequacy of the wetting
practices by answering the following:
a. Is there a water or wetting agent supply? Yes No
b. What equipment is used to apply it?
c. Is water or wetting agent observed being sprayed on suspect ACM?
During removal of section: Yes No
During stripping: Yes No
d. Is there visible dust observed in the vicinity of ACM
disturbance?
Yes No
e. Examining a cross-section of some removed ACM, does the full
depth appear adequately wet from the wetting?
Yes No
f. How does the material change when it is wet? (i.e., changes in
color, weight, texture):
4. Determine that friable ACM remains wet until collected for disposal
by answering the following:
a. Is the friable removed ACM awaiting containerization adequately
wet through the full depth? Yes No
D-ll
-------
Page 8 of 11
If no, describe the type of ACM (take sample, document,
location, and photograph as necessary)*
b. Evaluating waste in bags, is the waste ACM adequately wet
throughout?
Yes No Not Evaluated
If no, describe the type of ACM (take sample, sketch, location,
and photograph if necessary)*
c. Are there any open or ripped waste bags? How many?
5. Is stripped waste being transported from a height above ground of:
Less than 50 ft Greater than 50 ft _____
a. If less than 50 ft, is the waste ACM carefully being lowered to
ground level (not dropping or throwing)? Yes No
b. If greater than 50 ft, is waste ACM transported in dust-tight
chutes or leak-tight containers? Yes (specify) No
*Use Attachment B for documenting sample information and Attachment C
for documenting photograph information.
D-12
-------
Page 9 of 11
E. Waste Handling (61.152>
1. Are there visible emissions to the outside air? Yes No
If yes, collect a sample of the friable material generating the
visible emission (document location and photograph as necessary)*
2. Is there any suspect ACM dust on the ground? Yes No
If yes, describe the quantity and location of dust and collect a
sample (sketch and photograph as necessary):
3. Is the owner/operator choosing an alternative to the no visible
emission standard? Yes No
If yes, which option:
Treat with water and put into leak-tight, labeled containers
Process into nonfriable forms
Alternative method approved by Administrator
Explain: _________
*Use Attachment B for documenting sample information and Attachment C
for documenting photograph information.
D-13
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Page 10 of 11
IV. OSHA REQUIREMENTS
Containment Barrier: Yes No
Respiratory Protection: Yes No
Glove Bag: Yes No
Decontainment Unit: Yes No
Signs Posted: Yes No
Estimated size of containment area:
Number of negative air machines:
Name of Hygienist:
V. POST INSPECTION INTERVIEW
Summary of Recommendations/Discussion with Owner/Operator:
D-14
-------
VI. ADDITIONAL COMMENTS
Inspector Signature
(A88-302)
Page 11 of 11
Date
D-15
-------
ATTACHMENT A
ASBESTOS D/R CHECKLIST
QUANTIFICATION OF ACM
Ouantitvb Measurement/
Facility Area Length Estimation
Component" ft2 ft Technique6 Friabled
Total
"Examples of facility components; pipe, duct, boiler, I-Beam, ceiling,
steel deck, etc.
Quantity of suspect ACM that will be disturbed during demo/reno
Measurement Technique: Measure or estimated - if estimated, explain
technique.
dFriable rating: yes, no, or potentially during demolition or renovation.
D-16
-------
SAMPLE COLLECTION LOG
red my iwiw
Samples).
Facility Address.
MiSampM.
0
1
SAMPLE
NUMBER
SAMPLE
LOCATION
SAMPLE
DESCRIPTION
COMMENTS
t
w
w
n
H
0
w ~
01 K
|g
w
§
o
s
-------
ATTACHMENT C
ASBESTOS D/R CHECKLIST
PHOTO IDENTIFICATION LOG SHEET
Name/Address of
Facility
Date Time
Samples Taken By: __ Signature
Frame No. Description
REMARKS:
(A88-359)
D-18
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APPENDIX D-3
LANDFILL INSPECTION CHECKLIST
D-19
-------
ASBESTOS DISPOSAL LANDFILL
INSPECTION CHECKLIST
Page 1 of 4
Site Name Inspectors)
Location Date of Inspection
Time of Inspection
I. PRELIMINARY INTERVIEW
1. Site Contact
2. Title
3. Affiliation
4. Phone
5. Is landfill approved by state? Yes No
If yes, Operating Permit No.
Effective Date through
6. Permit Conditions Applicable to the Asbestos NESHAP
a. No VE; with warning signs/fencing Yes No
b. 6 inch cover within 24 hours Yes No
c. Dust suppressant within 24 hours; with warning signs/fencing Yes No
d. Alternative method approved by Administrator.
Yes No If yes, explain:
II. SITE CONTACT INTERVIEW
1. When was ACM waste last received?
D-20
-------
Page 2 of 4
2. Name(s) of generator(s)? __
3. Method of containerization?
4. How was it deposited (e.g., manually off loaded, dumped semiautomatically)?
5. Where was it actually deposited? (note on sketch below)
6. Are there special provisions for handing asbestos-containing waste at this landfill?
Yes No
If yes, describe
SKETCH OF DISPOSAL SITE (PLAN VIEW)
(Include Site Entrance and Boundaries, Roadways, Active Cells,
Closed Cells, Borrow Areas, Direction of Prevailing Wind,
and Location of Deposited Asbestos-Containing Waste)
D-21
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Page 3 of 4
HI. VISUAL OBSERVATIONS
1. Waste sufficiently covered: Yes No
2. Waste covered daily: Yes No Not observed
3. Depth of cover material: Inches, Feet
4. Type of cover material:
5. Is a dust suppressant agent used: Yes No
6. Type of suppressant used
7. Type of barriers (fencing or natural)
8. Warning signs posted Yes No
9. Is any ACM waste exposed Yes No
If yes, answer with the following questions.
a. Was it deposited within the past 24 hours: Yes No
b. Is it sealed in leak-tight containers: Yes No
c. Are the containers intact: Yes No
If no, explain
d. Are the containers properly labeled: Yes No
If no, explain
e. Are visible emissions observed: Yes No
If yes, describe location, magnitude and activity causing the emission
(collect sample and photograph as necessary).*
~Use Attachment A for documenting sample information and
Attachment B for documenting photograph information.
D-22
-------
Page 4 of 4
IV. POST INSPECTION INTERVIEW
Summary of Recommendations/Discussions with Site Operator:
V. ADDITIONAL COMMENTS
Inspector Signature Date
(AB8-359)
D-23
-------
SAMPLE COLLECTION LOG
Facility Nam*
Samples).
Facility Address.
Date Sampled.
©
i
N>
4^
SAMPLE
NUMBER
SAMPLE
LOCATION
SAMPLE
DESCRIPTION
COMMENTS
R
»TJ
CO
p)
>
H
M
3
tn
£
i
»
M
CO
H
O
CO
a o
B
M 3
PS
8*
8
w
CO
H
A88-302/A
-------
Name/Address of
Facility
ATTACHMENT B
ASBESTOS LANDFILL CHECKLIST
PHOTO IDENTIFICATION LOG SHEET
Date
Time
Samples Taken By:
Signature
Frame No.
Description
REMARKS:
(A88-359)
D-25
-------
APPENDIX D-4
AHERA INSPECTION CHECKLIST
D-26
-------
AHERA INSPECTION CHECKLIST
Date of Inspection:
Inspection Site:
Type of Employees:
1. Are person designing or conducting a response action in a school
building, i.e., removal, encapsulation, enclosure, or repair of
asbestos-containing material, accredited under AHERA for that activity?
Yes No
2. Do accredited persons have their accreditation certificates at the
location where they are conducting the work?
Yes No
3. Is at least one accredited supervisor at the worksite at all times while
work is in progress?
Yes No
Inspector's Signature:
D-27
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APPENDIX D-5
WORKER PROTECTION RULE CHECKLIST
D-28
-------
WORKER PROTECTION RULE CHECKLIST
Date of Inspection:
Inspection Site:
1. Is asbestos abatement work being done? (Abatement means activity
involving the removal, enclosure or encapsulation of friable asbestos
material.)
Yes No
2. Is abatement work performed by State and local government employees not
covered by the OSHA Rule (29 CFR 1926.58)?
Yes No
3. Does the work involve more than 3 linear feet or 3 square feet?
Yes No
Notes:
Inspectors Signature Telephone Number Date
D-29
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1
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Guidelines for Asbestos NESHAP Demolition and
5. REPORT DATE
April 1989
Renovation Inspection Procedures
6. PERFORMING ORGANIZATION CODE
7. AUTHORISE
8. PERFORMING ORGANIZATION REPORT NO.
Stephen G. Piper
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Alliance Technologies Corporation
10. PROGRAM ELEMENT NO.
213 Burlington Rd.
Bedford, MA 01730
11. CONTRACT/GRANT NO.
68-02-4465
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
13. TYPE OF REPORT AND PERIOD COVERED
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document provides EPA guidance on procedures for conducting
regulatory compliance inspections of demolition, renovation, and associated
waste handling and disposal, of facilities with asbestos-containing materials.
The document covers (1) safety procedures that should be followed when
performing inspections, (2) pre-inspection procedures including guidance for
identifying non-notifiers, (3) onsite facility inspection procedures including
procedures for entering and exiting the containment areas, (4) post-inspection
procedures including handling of reports and evidence, (5) landfill
inspections, and (6) sampling techniques. Inspection checklists designed
for facility inspections and landfill inspections are appended. The material
presented is a summary of information and experience gained by EPA through
the inspection and case development experiences of a nationwide representation
of regulatory staff responsible for enforcing the asbestos NESHAP.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Asbestos Abatement
Asbestos Inspection
Asbestos Waste Disposal
Asbestos Waste Handling
NESHAP
18. DISTRIBUTION STATEMENT
Available to the Public
19. SECURITY CLASS (This Report J
UNCLASSIFIED
21, NO. OF PAGES
106
20. SECURITY CLASS (Thispage)
UNCLASSIFIED
22. PRICE
EPA Pwin 2220-1 (Rav. 4-77) previous
EDITION IS OBSOLETE
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EPA Form 2220-1 (Rav. 4-77) (R«v«ria)
•U.S. CO* NT PRINT IMS Orritti19B9-617-003ia«909
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