Document 65j5ppDgxE9NBddZjk9eYmLw6
PLAINTIFF'S EXHIBIT
GUIDELINE FOR 1984 FIELD AUDIT OF STATE ASBESTOS INSPECTORS AIR ENGINEERING SECTION AIR MANAGEMENT BRANCH
AIR AND WASTE MANAGEMENT DIVISION
I. Before arriving at tha sita with tha Stata Inspector, determine if ha or aha haat A. Racaivad propar notification (10 or 20 days# with all information required by 40 CFR 1, Subpart B(d)(l) or (2)). If not# why? B. Racaivad any training ralatad to thia typa inapaction (personal safety# asbestos demolition project inspection courses# etc.). C. The proper safety equipment. - Proper respiratory protection. - Clothing. - Hard hat# safety shoes, safety glasses. D. Notified the appropriate OSHA office. (Will an OSHA representative be present?)
II. At the asbestos removal project site does the inspector: A. Locate the proper site supervisor (contractor# owner# owner's designee)? B. Properly identify himself to the site supervisor? C. Ascertain the extent of the contaminated area in relation to the rest of the Immediate site area# including the heating/cooling duct system# that could possibly contaminate the rest of the building or site? Is asbestos present in other parts of the building or site?
C 000042
LAM021953
2
D. Assure that proper warning slgna and area security
measures are in place and being observed?
B. Don the proper safety equipment before sintering
contaminated areas?
P. Request the site supervisor accompany him or her during
the inspection?
XXX*
Xn the Contaminated area, does the Inspector check to
see ift
A. The room was properly prepared (remove all removable
items, protect walls, windows and floors with construc
tion plastic, seal off all air conditioning ducts,
install double-walled entrance/egress shield)?
B. The asbestos-containing materials to be removed are
being properly wetted (and obtain information on surfac
tant specifications, mixture ratio, amounts used, note
overuse)?
C. The material is being properly removed from the adhering
surface (so as to minimize fiber emissions)?
D. The material is being properly bagged and labeled?
E. The workers are properly equipped with respiratory
protection, clothing, tools?
P. Ambient sampling is being conducted (in contaminated
area, outside contaminated area, in other parts of
I
building or site)? By whom?
C 000043 LAM021954
3 G. The workers ere taking ear# to prevent tracking of
asbestos-contaminated materials outside eontaninated area and taking proper precaution to contain the asbestos fibers in the eontaninated area? (Do they leave contaminated disposable clothing/footwear in contaminated area?) H. Personnel showers are Installed (is water contained for burial in landfill)? I. The no smoking, drinking or eating rule is being observed in work area? J. During clean-up all contaminated cleaning materials are carefully removed and placed in plastic bags for shipment to burial site? K. The room is sponge-wiped and/or carpets wet-vacuumed or if a HEPA vacuum system is being used? L. All contaminated cleaning materials including cleaning water (vacuum water) are properly disposed of? M. The waste containers are properly labeled and stored in a secured area for shipment to the landfill? N. The waste-hauling vehicle is properly enclosed? O. The bags and/or containers are carefully loaded and unloaded on the hauling vehicles with no containers being broken?
C 000044
LAM021955
4 P. The landfill meets tha requirements of 40 CPR 61,
Subpart B. (la tha aabaatoa waste material eovarad bafora tha and of tha day?) 0. Tha burial alta la balng suitably marked for futura location? IV. Insofar as tha atata'a aabaatoa eampling and analysis capabllltias ara concerned: A. Doaa tha Inspactor avar gathar bulk aabaatoa samples? B. Doaa tha Inspactor conduct air sampling for aabaatoa fiber concantratlons? C. How is analysis conducted? V. After the auditor and inspector leave the site, constructive criticism should be offered to the Inspector by tha auditor, taking care to ensure that he or she understands that the auditor is merely making suggestions rather than dictating policy or procedure changes. In case of improper state agency policy, these matters should be resolved between EPA and Agency directors and followed up during the mid-year evaluation. Comments:
C 000045
LAM021956