Document 7Ojg0R8ZvKMgRdXrZXK6E57Ve

SOHIO CARBORUNDUM c SOHIO MATERIAL SAFETY DATA SHEET Sohio Emergency Phone In Ohio: 800-362-8059 Outside Ohio: 800-321-8642 CHEMTREC Assist: 800-424-9300 Other Product Safety Info.: 216-575-8024 MANUFACTURER: Sohio Engineered Materials Company - Fibers Division ADDRESS: P.0. Box 808, Niagara Falls, New York 14302 PRODUCT IDENTIFICATION TRADE NAME: fiberfraxr CAS NUMBER: NA SYNONYM(S): Ceramic Fiber; Refractory Fiber; MMVF CHEMICAL FAMILY: Vitreous Aluminosilicate Fibers MOLECULAR FORMULA: NA MOLECULAR WEIGHT: NA SOHIO PRODUCT CODE: NA HIERARCHY: MSDS NUMBER: AV2 NA PRODUCT HAZARD SUMMARY HEALTH WARNING! CMAY BE HARMFUL IF INHALED MAY BE IRRITATING TO THE SKIN, EYES AND RESPIRATORY TRACT POSSIBLE CANCER HAZARD BASED ON TESTS WITH LABORATORY ANIMALS FIRE NON-COMBUSTIBLE REACTIVITY STABLE PRODUCT HEALTH HAZARD INFORMATION ROUTE OF EXPOSURE INGESTION: May cause gastrointestinal disturbances. vomiting and diarrhea. EFFECTS OF OVEREXPOSURE Symptoms may include irritation, nausea, SKIN: SLIGHTLY TO MODERATELY IRRITATING. May cause irritation and inflammation due to mechanical reaction to sharp, broken ends of fibers. EYE: SLIGHTLY TO MODERATELY IRRITATING. surface of the eye. Abrasive action may cause damage to the outer C ND = No Data NA s Not Applicable AV2/Page 1 PERSONAL PROTECTION INFORMATION The following personal protective guidelines should be followed, especially where f engineering controls (e.g. mechanical dust collection and other means of exhaust ventilation) are not technically feasible or do not reduce airborne fiber concentrations to recommended exposure limits. EYE PROTECTION: Wear safety glasses or chemical goggles to prevent eye contact. Do not wear contact lenses when working with this substance. Have eye baths readily available where eye contact can occur. SKIN PROTECTION: Wear gloves, hats and full body clothing to prevent skin contact. Use separate lockers for work clothes to prevent fiber transfer to street clothes. Avoid taking unwashed work clothes home. Wash work clothes separately from other clothing. Rinse washing machine thoroughly after use. If clothing is to be laundered by someone else, inform launderer of proper procedures. RESPIRATORY PROTECTION: Use NIOSH or MSHA approved equipment when airborne exposure limits are exceeded. NIOSH/MSHA approved breathing equipment may be required for non-routine and emergency use. Ventilation may be used to control or reduce airborne concentrations. Acceptable respirators recommended for given airborne ceramic fiber concentrations are: Concentration c 2.0 - 5.0 f/cc 5.0 - 50.0 f/cc > 50.0 f/cc Respirator Type 3M 8710 or equivalent. Survivair full face piece with high efficiency filter 1090-00 or equivalent. MSA 01-00-06 full face piece type C supplied-air or equivalent. OSHA approved air source required. Pending the results of long-term health effects studies, engineering control of airborne fibers to the lowest levels attainable is advised. PHYSICAL PROPERTIES BOILING POINT, C (F): NA MELTING POINT, C (F): ND VAPOR PRESSURE, on Hg: NA VAPOR DENSITY (AIR*1): NA SOLUBILITY IN WATER, X: ND APPEARANCE/ODOR: ND SPECIFIC GRAVITY: ND X VOLATILE: NA EVAPORATION RATE (BUTYL ACETATE1) : VISCOSITY, SUS: NA POUR POINT: NA pH: NA NA FIRE AND EXPLOSION DATA FLASH POINT, C (F): None AUTOIGNITION TEMPERATURE, C (F): None ND = No Data NA = Not Applicable AV2/Page 3 removing and handling ceramic fiber used in high temperature applications, special C caution should be taken to avoid unnecessary cutting and tearing of the used material to minimize generation of airborne dust. Use NIOSH or MSHA approved equipment when airborne exposure limits may be exceeded, especially in confined areas with inadequate ventilation or other areas. Acceptable respirators recommended for given airborne cristobalite concentrations are: Concentration Up to 10 times PEL 10 to 100 times PEL > 100 times PEL Respirator Type 3M 8710 or equivalent. Survivair full face piece with high efficiency fiI ter 1090-00 or equivalent. MSA 01-00-06 full face piece type C supplied-air or equivalent. OSHA approved air source required. TRANSPORTATION REQUIREMENTS 0.0.T. HAZARD CLASS (49 CFR 172.101): NA D.O.T. PROPER SHIPPING NAME (49 CFR 172.101): 0.0.T. LABELS REQUIRED (49 CFR 172.101): NA D.O.T. PLACARDS REQUIRED: NA BILL OF LADING DESCRIPTION: ND UN/NA CODE: NA NA ^ INGREDIENT/HEALTH HAZARD INFORMATION COMPONENT I CAS NO. | XI EXPOSURE LIMITS - REFERENCE Aluminosilicate (vitreous) NA 99+ 2 fibers/cc TWA; 10 fibers/cc CL (SOHIO)* Remaining components not determined hazardous and/or hazardous components present at less than 1.0/C (0.1X for careinogens). Mixture Trace NA "Pending the results of chronic health effects studies, airborne exposures should be controlled at or below the SOHIO recommended exposure limit listed above. REVISION DATE: 2/15/85 REPLACES SHEET DATED: COMPLETED BY: G. R. Krautter APPROVED BY: ----------- ' L NOTICE The information presented herein is based on dm considered to bo accurate as of the dm of preparation of this Material Safety Dm Sheet However. no warranty or representation express or implied. is mad* as to tho accuracy or completeness of the foregoing data and safety information, nor it any authorization given or implied to practice any patented invention without a license In addition, no responsibility can be assumed by vendor for any damafe or injury resulting from abnormal use. from any failure to adhere to recommended practices, or from any hazards inherent in the nature of the product ND = No Data NA = Not. Ann I i rah I AV2/Page 5 .-tog i'aies Ervrcrmenaj Agency iec:.cr -'ever: er ara exes vVasrirgtcn. 3.C. 2C460 C CPA A GUIDE to performing odu REINSPECTIONS UNDER THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA) A GUIDE TO PERFORMING REINSPECTIONS UNDER THE ASBESTOS HAZARD EMERGENCY RESPONSE ACT (AHERA) U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics Environmental Assistance Division February 1992 ACKNOWLEDGEMENTS The Environmental Protection Agency (EPA) would like to take this opportunity to acknowledge a number of individual contributors from inside and outside EPA that strengthened the development of this guidance document. The individuals identified below contributed immensely to this publication, therefore ensuring that school districts, inspectors, management planners, and training providers receive the foremost technical guidance available. The EPA project coordinator for development of this guidance document was Betty Weiner, from the Environmental Assistance Division. Betty's diligence and perseverance led to the successful development of this manual. To assist in the preparation of this document, EPA entered into a contractual agreement with WESTAT, Inc. of Rockville, Maryland. The following individuals associated with WESTAT, Inc. were instrumental in the unfolding of this document: Susan Marie Viet, CIH Alexa Fraser, Ph.D. Dale L. Keyes, Ph.D. EPA Regional Staff James Bryson Louis Bevilacqua Al Kramer Carole Dougherty Rhonda Evans Terrence Stanuch Steve Vargo Wolfgang Brandner Greg Crable David Combs Jo Ann Semones Matt Wilkening U.S. EPA Region I U.S. EPA Region II U.S. EPA Region II U.S. EPA Region III U.S. EPA Region IV U.S. EPA Region V U.S. EPA Region VI U.S. EPA Region VII U.S. EPA Region VII U.S. EPA Region VIII U.S. EPA Region IX U.S. EPA Region X EPA Headquarters Staff Tom Ripp Stationary Source Compliance Division Mary Jane Angelo - Office of General Counsel, Pesticides and Toxic Substances Div. Cindy Fournier Pesticides and Toxics Enforcement Division Sally Sasnett Office of Compliance Monitoring Sanda Howland Office of Compliance Monitoring Environmental Assistance Division Dave Kling Bob McNally Gina Bushong Joe Schechter Phil King Bob Jordan Diane Sheridan Other Federal and Outside Organizations National Association of Independent Schools James T. Kaull Council for American Private Education Greg D. Kubiak The National Association of Elementary School Principals - Ed Keller The Council of the Great City Schools - Michael Casserly American Association of School Administrators - Joyce Hill U.S. Catholic Conference - Rev. William F. Davis National Education Association - Joel Packer National Parent Teacher Association - Carolyn Henrich Department of Defense Stateside Dependents Schools - Dr. Hector O. Nevarez Occupational Safety and Health Administration - Dr. Carol J. Jones Chapter 1 2 3 4 5 TABLE OF CONTENTS & INTRODUCTION................................................................................... 1-1 1.1 The Purpose of this Guide......................................................... 1-1 1.2 Time Periods for Reinspections................................................ 1-2 1.3 Terminology Used in this Guide................................................ 1-3 1.4 Summary of Relevant AHERA Evaluation Study Reinspection Findings................................................................ 1-4 AHERA DESIGNATED PERSON'S REINSPECTION PLANNING RESPONSIBILITIES........................................................ 2-1 INSPECTOR'S REINSPECTION RESPONSIBILITIES.................... 3-1 MANAGEMENT PLANNER'S REINSPECTION RESPONSIBILITIES............................................................................. 4-1 AHERA DESIGNATED PERSON'S RECORDKEEPING RESPONSIBILITIES............................................................................. 5-1 List of Appendices Appendix A B C Page AHERA Regulatory Citations for Reinspections................................ A-l Sample Reinspection Form 1: Original AHERA Inspection Information Abstracted from the Management Plan and Instructions for Using Reinspection Form 1......................................... B-l Sample Reinspection Form; Reinspection of ACBM: Findings and Management Planner Recommendations and Instructions for Using Reinspection Form 2............................................................ C-l TABLE OF CONTENTS (continued) Exhibit A B C D E List of Exhibits Pae Recommended Reinspection Checklist for the AHERA Designated Person - Planning for the Reinspection............................ 2-2 Recommended Reinspection Checklist for the Inspector.................... 3-2 Recommended Reinspection Checklist for the Management Planner........................................................................... 4-2 Recommended Reinspection Checklist for the AHERA Designated Person - Recordkeeping.................................................... 5-2 Recommended Sample Reinspection Notification Letter.................... 5-4 :\ CHAPTER 1. INTRODUCTION 1.1 The Purpose of This Guide Under the Asbestos Hazard Emergency Response Act (AHERA)1, the United States Environmental Protection Agency (EPA) requires each elementary and secondary school to perform an inspection for asbestos-containing building material (ACBM) and to prepare an asbestos management plan. The AHERA regulations further require a reinspection of the ACBM at least once every 3 years. This reinspection guide will assist: Local Education Agencies (LEAs), AHERA designated persons, Asbestos inspectors, and Management planners in meeting the specific requirements for an AHERA reinspection. Further, it provides guidance for improving the accuracy and quality of information available about ACBM during the reinspection. The reinspection period provides an excellent opportunity for schools to re-evaluate and update their programs for managing asbestos. EPA recently issued general guidelines for asbestos in buildings in an advisory letter from the EPA Administrator which was sent to all LEAs. The letter summarizes EPA's policies for asbestos control in schools and other buildings in the form of "Five Facts." This letter is presented in Appendix H. This guide addresses only the Federal requirements for reinspections. A school may also be subject to State or local requirements not discussed here. The Regional Asbestos Coordinators and the State AHERA designees are both listed at the end of Appendix I. These individuals can provide more specific information about local regulations, and information on how to obtain further training and assistance. *AOCFR763. Asbestos-Containing Materials in Schools: Final Rule and Noace, U S. Environmental Protection Agency. October 1987. 12 Time Periods for Reinspections The AHERA regulation states that schools must perform reinspections at least once every 3 years after the management plan is implemented. It also required management plans be implemented by July 9, 1989. Therefore, LEAs must complete the first round of reinspections on or before July 9, 1992. If a management plan was implemented before July 9,1989, the LEA must complete its reinspection within 3 years of the earlier date. Additional questions concerning the AHERA requirements for reinspections are answered in the EPA publication, Answers to the Most Frequently Asked Questions about Reinspections. A copy of this publication is in Appendix D. Example 1. The LEA implements the school's management plan on January 30, 1989. The first reinspection must be completed by January 30, 1992, The second reinspection must be completed by January 30, 1995, and so forth. The LEA must submit management plans to the State Governor's office for buildings brought into service after October 12, 1988, prior to their use as a school building. The AHERA regulation also requires reinspection of these buildings at least every 3 years from the date of management plan implementation. Example 2. The LEA begins to use a building as a school building on September 3, 1991. The LEA performs the original inspection and submits the management plan to the State Governor, as required, on August 30, 1991. Upon expiration of the 90-day period for State review, the plan is implemented on November 30, 1991 (unless the plan has been disapproved by the state). The first reinspection for this building must be completed by November 30, 1994. Example 3. The school implements its management plan on July 9, 1989. The school takes the building out of service as a school building on January 1, 1992. If the school returns the building to service on June 1, 1992, the reinspection must be completed by July 9, 1992, within the original 3 year reinspection period. If the school returns the building to service on September 1, 1992, the reinspection must be completed by October 1, 1992, within 30 days after commencement of use, for whatever reason. Note: If the school had not retained the original management plan and inspection reports when the building was taken out of service, a complete original AHERA inspection must be performed (including bulk sample collection), and a new management plan must be developed prior to using the building as a school building again. (See Example 2 above.) Reinspections are considered complete after four steps occur. These are (1) inspector's completion of the visual examination and assessments of ACBM as detailed in 40CFR763.85(b), (2) inspector's submission of the reinspection findings to the designated person within 30 days following the field work, (3) management planner's review of the results of the reinspection, and (4) management planner's submission of recommendations for response actions to the designated person. 1J Terminology Used in this Guide This section presents important terms or concepts that are used throughout the guide. See Appendix E for a glossary of other key terms. Functional Space versus Room/Area AHERA regulations define a functional space as "a room, group of rooms, or homogeneous area designated by a management planner, project designer, or person accredited to conduct response actions." The AHERA Preamble refers to functional space as a "term of art" used by the accredited expert to appropriately characterize an area as containing "significantly damaged friable surfacing ACM" or "significantly damaged friable miscellaneous ACM." In the context of response actions, the affected functional space is that area within the containment area. This indicates that a functional space can be a grouping of areas with similar response action recommendations. The AHERA definition requires that management planners, not inspectors, define functional spaces. For the discussion in this guide, the term room/area refers to spaces defined by the inspector during the reinspection. The inspector may interpret this as an individual space surrounded by walls, such as a hallway or classroom; a group of individual spaces; or the entire homogeneous sampling area. We strongly recommend the first interpretation, i.e., an individual space surrounded by walls. This dearly-defined space will enable the LEA, school staff, and parents to easily review information about ACBM for a specific location. Original Inspection Versus Reinspection Original inspection or original AHERA inspection refers to the initial inspection (generally performed before July 9, 1989) to meet AHERA requirements. Reinspection refers to the required reinspection of all ACBM identified during the original AHERA inspection. LEAs must perform reinspections at least once every 3 years. When we refer to materials that were not identified during the original AHERA inspection and which are found at a later date (possibly as part of the reinspection activity), we use the term inspection since it refers to the first recording of these materials in the management plan. LEA Versus AHERA Designated Person The LEA must designate and train a person to ensure that the AHERA regulations are properly implemented. Since this designated person acts on behalf of the LEA, we use the terms LEA and AHERA designated person or designated person interchangeably in this guide. 1.4 Summary of Relevant AHERA Evaluation Study Reinspection Findings In June, 1991, the EPA released the report entitled Evaluation of the Asbestos Hazard Emergency Response Act (AHERA). This report was prepared as part of a commitment to Congress by EPA to evaluate the effectiveness of the AHERA regulation and to determine which elements might be used in future regulation of public and commercial buildings. A summary document entitled Asbestos in Schools: Evaluation of the Asbestos Hazard Emergency Response Act (AHERA): A Summary Report presents the Evaluation Study's major findings. The summary document can be obtained by calling the Toxic Substances Control Act (TSCA) Hotline (see Appendix F). The Evaluation of AHERA: A Fact Sheet, which was sent to all schools in the summer of 1991, can also be obtained through the hotline. The evaluation study was based on a national statistical sample of 198 schools in 30 communities. The study focused only on occupied school buildings in the United States with students in any of grades 1 through 12. There were a few exclusions: buildings constructed after October 1988, buildings where the original AHERA inspection found no asbestos, and buildings where no inspection was conducted in response to AHERA. The report estimates that the schools in the target population, from which the sample for this evaluation was drawn, represent approximately 80 percent of the 106,000 schools in the nation. The evaluation study covered six major areas of the AHERA regulation: identification and assessment of material; management plan evaluation; response action evaluation; original AHERA inspection evaluation; process of notification; and a maintenance and custodial worker training and experience. The following represent the findings of the AHERA Evaluation that pertain to performing reinspections: a unidentified materials Many original AHERA inspections did not identify at least one suspect material present. The most consistently unidentified materials were: fire doors duct insulation resilient sheet flooring/linoleum vibration dampening cloth The study did not evaluate smooth wall materials [such as gypsum wallboard (also called sheetrock or drywall), joint compound, and hard plaster]. However, the EPA believes original inspections may have frequently missed these materials. material locations Only 56 percent of the areas where ACBM was identified had the exact location recorded in the management plan. material quantity An estimated 89 percent of the total quantity of suspect ACBM reinspected in the evaluation was reported in the original AHERA inspection. material assessments Ninety-two percent of the ACBM that should have been assessed according to AHERA was actually assessed. Forty-four percent of the ACBM assessed used AHERA categories reporting the amount of damage and potential for damage at the time of inspection. management plans Written management plans generally contain all the required information. This information is often difficult to understand, however, without specialized instruction. CHAPTER 2. AHERA DESIGNATED PERSON'S REINSPECTION PLANNING RESPONSIBILITIES Exhibit A presents the first of two checklists for the AHERA designated person. He or she must take a number of steps in planning for the reinspection prior to any field activities. Each of these steps is discussed below. [~~| Al. Select the inspector(s) and management planner to perform reinspection activities; obtain proof of their current accreditations. A person's accreditation is current if he or she has successfully completed an EPA or State approved accreditation or refresher course within 1 year prior to the reinspection activity. Similarly, the management planner reviewing the reinspection results must be accredited under AHERA as a management planner and his or her accreditation must be current. While there is an additional 1-year grace period to take the refresher course without having to take the full course over again (total of 2 years since the last accreditation course), an individual is not considered accredited during the second-year period. There are no other restrictions on the inspector or management planner, with the exception of possible conflict of interest (see page 2-3). The inspector and management planner may be: the person(s) who performed the original inspection and/or prepared the management plan, if accreditation is still current. His or her familiarity with the school could increase efficiency and thus save some time and money. On the other hand, these individuals may repeat errors made during the original inspection; the AHERA designated person or other LEA employee, if accredited. However, the LEA must ensure that reinspections are performed conscientiously. Someone who works in a building every day may not be attuned to changes in ACBM condition or may fail to identify suspect materials not reported in the original inspection; or a consultant or consulting company employee, if accredited. Request copies of inspector and management planner certificates to verify that accreditations are current. Include these in the management plan. Exhibit A. Recommended Reinspection Checklist for the AHERA Designated PersonPlanning for the Reinspection H 1 Select the Inspector(s) and management planner to perform reinspection activities; obtain proof of their current accreditations. n 2. Determine the scope of work. [~~| 2a. Clarify which buildings are to be included In the reinspection. Determine whether each building is used as a school building. 1~| 2b. Determine whether previously grouped, similar materials (e.g., all floor tile) should be separated into distinct materials. n 2c. Determine whether previously assumed ACBM should be bulk sampled. Determine whether other bulk samples should be collected. |~| 2d. Determine whether quantities of ACBM should be re-estimated. |~| 2e. Determine whether the inspector should look for previously unidentified suspect materials. (Highly recommended by the EPA.) f~l 3. Determine how the reinspection results will be reported. I"! 3a. Determine whether locations of ACBM should be reported on a room-by-room basis, rather than by a building or homogeneous sampling area basis. [~~1 3b. Determine whether a floorplan or written description, or both, will be used to locate ACBM. [~| 3c. Determine whether ACBM will be assessed on a room by room, homogeneous sampling area, or some other basis. Q 3d. Determine whether photographs or videotape will be used to document material condition. Conflict of Interest Although any person whose inspector or management planner accreditation is current may perform their respective roles, the LEA should consider whether a conflict of interest exists. This is particularly important where one person or firm may serve two or more roles at the school. For example, a conflict of interest might exist if the management planner and the asbestos contractor both worked for the same firm. The planner might recommend response actions that are more expensive than necessary to protect human health and the environment. A similar conflict of interest might arise if the same person acts as both inspector and management planner for the school. Reinspection Assistants Only an accredited inspector may perform required reinspection activities. An unaccredited assistant cannot locate, touch, or assess AC6M or sign reinspection forms. Such an assistant can, however, record information dictated by the inspector, carry supplies, assist in gaining access to areas, and perform other non-regulated tasks. n A2. Determine the scope of work. You may want to expand upon the minimum requirements for a reinspection, as discussed below. Carefully consider the work required before beginning the field work. |~1 A2a. Clarify which buildings are to be Included in the reinspection. Determine whether each building is used as a school building. List the buildings to be reinspected. Include any temporary buildings. LEAs must reinspect all buildings or portions of buildings which were originally inspected and which they "lease, own or otherwise use as a school building^ [see 40CFR763.85(b)(l)]. Administrative and maintenance buildings, storage areas, garages, utility facilities, and student housing essential to operating the school and under the authority of the LEA must all be reinspected, if they contain friable or nonfriable known or assumed ACBM. Management plans are to be developed on a "per school" basis. Homo geneous sampling areas are to be identified for each "school building." A "school" may be comprised of numerous "school buildings." Management plans, however, often do not distinguish between buildings on the same campus. In addition, homogeneous sampling areas are sometimes incorrectly defined across several buildings. For example, one homogeneous sampling area may be "2x4 ceiling tile in Buildings 1, 2, and 3." Treat each building individually for reporting and bulk sampling purposes. Review whether these types of errors occur in the reports for buildings scheduled for reinspection, and instruct the inspector to correct any possible deficiencies. Buildings which may not need reinspection include: Buildings no longer used as school buildings. Buildings do not require a reinspection if they are no longer used as school buildings when a reinspection is scheduled. This is true even if the LEA still owns or leases them. An example is a temporary trailer which is unused due to decreased enrollment. It is recommended that the LEA provide a statement in the management plan that the building is not currently used as a school building. If the LEA decides to use the building at a later date, the building must be reinspected (see Section 1.2). Remember, however, that LEA buildings not currently or ever used as classrooms (e.g., storage or administrative buildings) are subject to AHERA. Buildings in which no known or assumed ACBM was reported in the original AHERA inspection. If no known or assumed ACBM was reported during the original inspection, the building does not have to be reinspected. There should be a statement in the management plan that no ACBM was present. Further, no reinspection is required if the management plan contains a signed statement that the building is asbestos-free in accordance with 40CFR763.99(a). We recommend, however, that the LEA reinspect each building for materials often not identified in the original inspection. Such materials include fire doors, resilient sheet flooring/linoleum, interior and exterior duct insulation, vibration dampening doth, and suspect wall materials. It would also be prudent to look for other suspect materials not identified during the original inspection. (See page 2-7, A2e.) Buildings in which all known or assumed ACBM has been removed. In strict accordance with the AHERA regulation, a building does not have to be reinspected if all ACBM has been removed. Indude documentation of the removal in the management plan. We recommend that the LEA verify that the removal of ACBM has been complete with no debris left behind, and that there are not still suspect materials in the building which were unidentified during the original AHERA inspection. Buildings constructed after October 12,1988. School buildings built after October 12, 1988 do not require reinspection if an architect or project engineer responsible for the construction of the building, or an accredited inspector, signs a statement that no ACBM was specified in the construction documents or, to the best of the person's knowledge, that ACBM was not used as a building material. H A2b. Determine whether previously grouped, similar materials (e.g., all floor tile) should be separated into distinct materials. Grouping different materials into one homogeneous sampling area was common during the original inspections. Grouped materials were generally assumed to be ACBM. For example, a management plan might describe all floor tile in a building as a single homogeneous area of ACBM, even though there were five colors or various sizes of floor tile. If this practice occurred, it was a misinterpretation of the homogeneous area concept and should be corrected. Determine whether the original inspector grouped any unlike materials in your building. Decide whether to treat these materials as different homogeneous sampling areas based on distinguishing factors, such as texture, color, or location. By breaking these groups into their individual materials, a significant quantity of material might be reclassified as non-ACBM (based on results of laboratory analysis). (~1 A2c. Determine whether previously assumed ACBM should be bulk sampled. Determine whether other bulk samples should be collected. There are two choices in dealing with previously assumed ACBM during a reinspection: (1) continue to assume the material is ACBM, or (2) collect bulk samples for laboratory analyses, in which case the material can be reclassified as either known ACBM or non-ACBM. Factors which might affect the decision to collect bulk samples of previously assumed ACBM include: additional resources for laboratory analysis are available, or assumed ACBM is the only ACBM remaining in a building. The LEA could eliminate periodic surveillance and other ongoing management activities if laboratory analysis confirmed the material as non-ACBM.  the LEA is planning removal projects or renovations which might affect the assumed ACBM. It is then required to determine whether the material does, in fact, contain asbestos. The LEA may want to collect additional bulk samples in the following cases: the number of samples of pipe fitting insulation or a miscellaneous material appear insufficient to determine if the material is or is not ACBM. An example is where homogeneous areas are very large. EPA strongly recommends that at least three samples be taken in large homogeneous areas, even when the regulations do not require it. previously unidentified suspect materials are found during the reinspection. These may be bulk sampled or assumed to contain asbestos. materials grouped together for efficiency during the original inspection are now separated into distinct homogeneous sampling areas. An example would be blue 9x9 floor tile and green 9x9 floor tile previously grouped and designated as "all floor tile throughout the building." [~| A2d. Determine whether quantities of ACBM should be re-estimated. Consider whether the original ACBM quantities were sufficiently accurate for proper management of the material. If actual quantities are significantly different than reported, adjusted cost estimates may affect plans for response actions. In addition, if the LEA now wants to record ACBM quantities room by room, rather than by building, new measurements must be taken. In either case, inspectors' estimates of ACBM quantity are intended for planning purposes only. We recommend that the LEA have their project designer verify the quantities of ACBM in each abatement project during the design development phase. Decide how the inspector should report quantities of ACBM, i.e., in square feet or linear feet. The AHERA regulations require inspection measurements reported in linear feet or square feet. Decide also how unit quantities should be handled (as in the case of insulated pipe joints). For abatement purposes, the project designer and contractor normally base their estimates on the number of joints and the diameter of the pipe. This method of reporting is, in fact, easier to track if the location is specific. It may be used in addition to the linear or square feet calculations. f~l A2e. Determine whether the inspector should look for previously unidentified suspect materials. (Highly recommended by the EPA.) The LEAs must conduct reinspections of all "friable and nonfriable known or assumed ACBM " [see 40CFR763.85(b)]. Thus, if an inspector overlooked a suspect material during the original AHERA inspection, there is no specific requirement that it be included in the reinspection. However, any missed actual or suspect ACBM present in the school represents a violation of AHERA for which both the LEA and the original inspector could be liable. Moreover, since an LEA cannot properly manage asbestos in a building unless it is all identified, we recommend that the original AHERA inspection information be verified, and corrected if necessary, during the reinspection process. With this goal in mind, consider the following materials for inspection: a materials that were frequently missed in the original inspection fire doors, resilient sheet flooring/linoleum, interior and exterior duct insulation, and vibration dampening cloth; suspect wall materials such as gypsum wallboard (also called sheetrock or drywall), joint compound and hard plaster which the EPA suspects were frequently overlooked; distinct materials which were improperly grouped together as a single homogeneous sampling area. Examples are different types or styles of floor tiles and ceiling tiles, and similar acoustical plaster applied at different dates; other materials such as boiler fire brick, gaskets, and caulking which may have been missed; specific materials of interest to the LEA, such as exterior roofing materials, auditorium curtains, light socket collars, electrical wire insulation, or stored building materials. The regulation does not, however, require inspection of these materials; and a materials introduced to the building during renovations which have not been properly documented as ACBM or non-ACBM. Q A3. Determine how the reinspection results will be reported. Management plans present original inspection results in a variety of formats, many of which are difficult to follow without specialized instruction. The AHERA regulation does not specify the format for reinspection results. Determine what format will work best for the school. Issues to consider include: Has the original plan been a useful reference in answering questions about ACBM in the school? Are parents and staff interested in detailed reports? Are there numerous materials or numerous ACBM locations, or both, to manage in the school? Do State or local laws have required formats? Do State or local laws exceed Federal requirements? A3a. Determine whether locations of ACBM should be reported on a room-by-room basis, rather than by a building or homogeneous sampling area basis. The reinspection is a good time to address how to report locations of ACBM. Some management plans report only general locations, e.g., "ceiling tile throughout building." This reporting may be acceptable where 1) only one kind of ceiling tile is present in the building, 2) the material's location is clearly indicated, and 3) the quantity of material is clearly shown. This type of reporting is unacceptable where two or more tile types are present or where both asbestos-containing tiles and non-asbestos-containing tiles are present in the same building. Reporting locations of ACBM room by room is clearer. Although it may generate extra paperwork for the inspector, it provides the best information for properly managing the materials. In some cases, it may be useful to further describe the location within the room/area. An example would be stating that "transite paneling is installed on the north wall of Room 127" where the other three walls are visually-identical, concrete block walls. Another approach is to locate each ACBM by describing its entire homogeneous sampling area. In this case, the inspector must clearly define the homogeneous sampling area by an inclusive and exhaustive listing of rooms. Rooms should be identified by number rather than use (such as music room, etc.) since room functions may change. An alternative is for the inspector to highlight on a floorplan all rooms in which the material is present. |--| A3b. Determine whether a floorplan or written description, or both, will be used to locate ACBM. Decide whether the inspector will record the locations of ACBM by a written description or by highlighting a floorplan, or by some combination of each. In rare cases, floorplans may not be available or readily generated. A floorplan is decidedly more useful than a written description if rooms are not numbered or where numbers may be changed. Even where rooms are numbered, a highlighted floorplan may be the most efficient means of communication. Remember, however, that highlights do not photocopy well. f~) A3c. Determine whether ACBM will be assessed on a room by room, homogeneous sampling area, or some other basis. Management plans generally report assessment categories for entire homogeneous sampling areas. Although this meets the requirements of the regulation, it may result in small areas with significant damage being ignored because they are part of a larger category of damaged ACBM. In addition, some management plans do not specify where the damaged ACBM is, e.g., "pipe insulation damage observed in random locations above suspended ceilings." It is useful to assess ACBM in small and specific areas. In this way, the management plan indicates the exact locations of the damaged ACBM. |~1 A3d. Determine whether photographs or videotape will be used to document material condition. Visual records, either photographs or videotape, of ACBM can be very valuable during reinspections. These will show actual changes in materials over time, thus permitting direct comparison between reinspections. These records add to the cost of reinspection, however, and the AHERA regulation does not require them. r \ t i i ii i CHAPTER 3. INSPECTOR'S REINSPECTTON RESPONSIBILITIES Exhibit B presents the checklist of reinspection activities performed by the inspector. It includes preparatory activities, fieldwork and recordkeeping. | | Bl. Review the Items on the Reinspection Checklist for the AHERA Designated Person Planning for the Reinspection. Review and understand the decisions made by the designated person for each item on the designated person's reinspection planning checklist (Exhibit A). It is a good idea to meet with the designated person to discuss the scope of work and any specific requests he or she may have. I"! B2. Select the field forms to be used (reinspection, reassessment, Inspection, bulk sample logs, photograph logs, chain of custody, floorplans). Appropriate field forms include: a reinspection form (see Sample Reinspection Form 2 in Appendix C); assessment form, if a separate form is to be used; chain of custody and bulk sample collection forms, if additional sampling is expected; inspection forms, if previously unidentified materials are to be inspected; copies of floorplans, if available; and photograph log forms, if photographs are requested. Ask the designated person to determine whether the forms meet the LEA's specific requirements for the reinspection. Most inspection firms have standardized forms. However, it is usually not too complicated to adopt new formats prior to going into the field. Exhibit B. Recommended Reinspection Checklist for the Inspector Planning for the reinspection field activities f~1 1. Review the items on the Reinspection Checklist for the AHERA Designated Person Planning for the Reinspection. f~l 2. Select the field forms to be used (reinspection, reassessment, inspection, bulk sample logs, photograph logs, chain of custody, floorplans). I"! 3. |~1 f~l 4. Review the management plan for the school (see Sample Reinspection Form 1 in Appendix B). 3a. Obtain or generate a list of all ACBMs and non-ACBMs (and associated identification numbers, if provided) and material categories reported during the original inspection. 3b. Record the sample results for each homogeneous sampling area of suspect material. 3c. Record all reported locations of material (descriptions and/or location diagrams) for each homogeneous sampling area. 3d. Copy the location diagrams, if possible. 3e. Record the original inspection assessment category assigned to ACBM in each room/area. 3f. Record any response actions which have occurred and the location of each. 3g. Record any renovations which have occurred and the location of each. 3h. Review records of periodic surveillance. Arrange administrative details - time of inspection, school escort, and keys. 5. Assemble all field materials. Sa. A supply of all field forms, pens, calculator, tape measure, flashlight, and tools. 5b. Blank floorplans and inspection location diagrams, if available. 5c. Bulk sample collection tools and clean-up supplies, if required. 5d. Personal protective equipment, if needed. 5e. A ladder, if needed. Exhibit B. Recommended Reinspection Checklist for the Inspector (Continued) Performina the field activities 6. 7. 8. Meet the school escort. Select the first room/area to be reinspected. Observe and record each ACBM in the selected room/area, referring to the list of homogeneous areas of ACBM and non-ACBM abstracted from the management plan (see Sample Reinspection Form 2). 9. Mark the rooms/areas where each ACBM was observed on the diagram or floorplan (optional). 10. Re-estimate the quantity of each ACBM in the selected room/area (if requested by the designated person). 11. Touch each ACBM In the room/area to determine whether it is friable. 12. Collect additional bulk samples, as instructed by the designated person. 13. Look at the condition and determine the potential for damage or significant damage to each friable ACBM and asbestos-containing TSI in the room/area. 14. Assign a reassessment category to each friable ACBM and asbestos-containing TSI in the room/area. 15. Record the justification of the assigned reassessment category (can use assessment form or notes). 16. Photograph the material, if requested by the designated person. 17. Assess previously unidentified materials in the room/area, if requested by the designated person. 18. Move to next room/area, and repeat as above. RecordkeeDina 19. Complete all field form data Hems. 20. Record name, signature, date, and accreditation number and State (if applicable) on the reinspection form. Exhibit B. Recommended Reinspection Checklist for the Inspector (Continued) Recordkeeping (continued) f~] 21. If additional bulk aamples ware collected, include the exact iocationa where they were taken. Also include a description of the process used to select sample locations, and the name, signature, date, and accreditation number and State (If applicable) of the Inspectors) collecting each bulk sample in each copy of the school's management plan. Q 22. Submit the results of the reinspeetion to the AHERA designated person within 30 days after the reinspeetion is completed. Note, at a minimum, any changes in ACBM assessment. f~| B3. Review the menegement plan for the school (see Semple Reinspection Form t in Appendix B). It can be difficult to abstract the original inspection data necessary to perform the reinspection properly. This is especially so where a different inspector or company is performing the reinspection. Management plans present the original AHERA inspection data in a wide variety of formats. The way AHERA regulations list required elements in a management plan commonly led to separation of different types of information into distinct chapters. This forces the reader to flip from chapter to chapter, or table to table, in order to find all the information about a particular material. In some cases, management plans describe the same material in different ways. Often the plans use material numbers and verbal descriptions interchangeably or inconsistently. In other instances, suspect ACBMs which did not contain asbestos are not clearly indicated as distinct homogeneous sampling areas. Indeed, the only reference to these materials may be in the laboratory report of analyses. Some states have standardized reporting forms. Where the forms are logically sequenced, cross-referenced, and properly completed, it is generally straightforward to abstract the necessary information. Unfortunately, however, management plans generally do not include instructions for use of these standardized forms. Sample Reinspection Form 1: Original AHERA Inspection Information Abstracted from the Management Plan (Appendix B) shows one way to record all the information necessary for reinspection concisely. Most buildings have less than 10 suspect ACBMs so, the inspector should need only two or three pages of this form. This form is not mandatory. A few pages of the management plan may contain all the necessary information and can be photocopied to take into the field. Most management plans are too bulky to use in the field. [~~| B3a. Obtain or generate a list of all ACBMs and non-ACBMs (and associated identification numbers, if provided) and material categories reported during the original inspection. The AHERA regulation requires a "list of whether homogeneous areas...are surfacing material, thermal system insulation, or miscellaneous material" and "an inventory of the locations of the homogeneous areas..." in the management plan. Based on these requirements, most management plans have some listing of materials from which to begin the complete listing. Do not, however, assume that any single list represents all suspect materials addressed by the inspection. Review the entire management plan to discover whether additional materials are reported elsewhere. Read the text for any references to miscellaneous materials which were not recorded in the inspection data. For example, firedoors were rarely listed as a suspect material. If addressed at all, they were usually discussed generically as suspect ACBM. It is just as important to obtain information about non-ACBMs as ACBMs. Later, during the inspection, each material in the building can be clearly identified as ACBM, non-ACBM, or a material which was not previously identified. Often, the only information about non-ACBMs is found in the laboratory results section. Sometimes management plans discuss fiberglass, foam glass, and rubber materials to explain why certain materials in the building were not sampled. This information could be useful during the reinspection. Record any available information. f~| B3b. Record the temple results for each homogeneous sampling area of suspect material. After generating the list of ACBMs and non-ACBMs, relate each material to the management plan's findings. These findings are either bulk sample results or the designation "assumed ACBM". The material description on the bulk sample form or laboratory results and the material descriptions for the homogeneous sampling areas may not be the same. In these cases, it may be possible to match laboratory results to materials by comparing the bulk sample location with the listed locations of the homogeneous sampling areas. [~1 B3c. Record all reported locations of material (descriptions and/or location diagrams) for each homogeneous sampling area. Record the location of each ACBM listed in the management plan. As above, scan the entire management plan for location information. For example, non-ACBMs may be indicated only on the bulk sample collection form. Although this form will probably not list all locations, it is a start and should permit the inspector to identify the material. Occasionally management plans interchange a room number and a room name. For instance, Room 101 may be called the art room in some sections of the management plan. Discuss these problems with the designated person or building maintenance staff, or refer to the building floorplan. [~~| B3d. Copy the location diagrams, if possible. Some management plans contain marked floorplans to show the locations of each ACBM or homogeneous sampling area. This information is useful and can replace listing of locations if copies can be carried into the field. Note that highlighters don't photocopy well. Make sure you have the original. |~] B3e. Record the original inspection assessment category assigned to ACBM in each room/area. Record the assessment category assigned to each ACBM during the original inspection. Since the reinspection is a comparison to the original AHERA inspection, be careful not to record assessments from a more recent periodic surveillance report. The AHERA regulation does not require assessment of undamaged nonfriable ACBM (except asbestos-containing TSI). However, some management planners created a new assessment category 8 for nonfriable ACBM. Others listed them as either category 5 or 6, ACBM with potential for damage or significant damage, respectively. Thus, if a surfacing or miscellaneous ACBM remains nonfriable and undamaged at the time of the reinspection, indicate "no change in assessment." (See page 3-11 for a list of the AHERA assessment categories.) 1~] B3f. Record any response actions which have occurred and the location ot each. Record where response actions [including Operations and Maintenance (O&M)] were taken. This information is necessary to perform the reinspection properly. For example, if the LEA removed ACBM from a previously documented location, no material should be found in that location. If the LEA encapsulated ACBM, you must determine the friability and overall condition of the material and encapsulant. The AHERA regulation requires that management plans contain all documentation about ACBM in a Building. Thus, records about any response actions, including initial cleaning should be available for review. Some records may be bound separately from the original plan. For example, removal project specifications can be very long. Ask the designated person to provide the complete asbestos file for the building. In some cases, there may be no record of an originally recommended response action being taken. Damaged or significantly damaged ACBM involved in these situations should be carefully checked in the field. If you find that, in fact, the recommended response actions have not been carried out (except for response actions scheduled for some future date), you should bring this information to the designated person's attention. [~~| B3g. Record any renovations which have occurred and the location of each. Although management plans do not have to record general renovations, previously unidentified materials may be exposed by such activities. Review information about renovations so newly revealed suspect materials can be inspected. In order to have accurate information about all ACBM or suspect ACBM, schools should maintain records on the asbestos content of materials installed in their buildings after October 12, 1988. Under the National Emission Standards for Hazardous Air Pollutants (NESHAP) Asbestos Standard, a school is considered a "facility" and is subject to the requirements of the standard for demolition and renovation. n B3h. Review records for results of periodic surveillance. Periodic surveillance records may contain useful information about an ACBM not recorded elsewhere. Examples include the recording of a small repair activity performed during the periodic surveillance or comments about the cause of new damage to a material. Remember that the reinspection results must compare current conditions to the original inspection conditions. Be careful not to confuse the results of periodic surveillances with the original inspection results. Periodic surveillances do not have to be performed by accredited inspectors nor are they as comprehensive as a complete AHERA inspection or reinspection. f~| B4. Arrange administrative details - time of inspection, school escort, and keys. Arrange all administrative details with the designated person before beginning field activities. Many schools do not allow contractors in buildings during school hours. Some may have to arrange for appropriate school personnel to work overtime in the evenings to escort the inspector. Request the keys for all locked areas. | | BS. Assemble all field materials. To conduct an efficient reinspection, bring all necessary field materials with you to the building. We suggest the following items: |~1 B5a. [~~| B5b. A supply of all field forms, pens, calculator, tape measure, flashlight, and tools. Assemble adequate copies of all field forms (see page 3-1, B2). If ACBM quantities are to be re-estimated, you should have a calculator and tape measure. A flashlight is frequently needed to look in areas such as above suspended ceilings, crawlspaces, and closets. Screwdrivers and pliers may be needed to remove access panels, grilles, vents, and electrical plates. Blank floorplans and inspection location diagrams, if available. As discussed above, homogeneous sampling area location diagrams generated during the original AHERA inspection are useful. Blank floorplans are also helpful in assuring you have seen all locations and can be used to generate location diagrams. Fire and emergency escape floorplans, usually available for school buildings, are satisfactory substitutes. s  B5c. Bulk sample collection tools and cleanup supplies, if required. If the designated person requests that you collect bulk samples of assumed ACBM or previously unidentified materials or makes some other special bulk sample request, assemble appropriate bulk sampling tools. Include clean up supplies such as a spray bottle of encapsulant, paper towels, labeled disposal bags, and a high efficiency particulate air (HEPA) vacuum. B5d. Personal protective equipment, if needed. You may encounter areas where personal protective equipment is needed. You might need these in a crawlspace or when bulk samples are collected. Pack an appropriate respirator and protective clothing in accordance with the school's or your employer's policies. B5e. A ladder, if needed. Determine whether you need a ladder to gain access to any area in the school, e.g., above suspended ceilings. Also, find out whether die school will provide a ladder for this activity. Many schools will not provide ladders. Be. Meet the school escort. Most schools require that a school representative escort building visitors. Review the purpose of the reinspection with the assigned escort and answer his or her questions before beginning the reinspection. B7. Select the first room/area to be reinspected. Many original inspections began in the boiler room since most thermal system insulation was found there. The first room/area to be reinspected is not as critical since the ACBM types in the building have been identified. Once the first room has been selected, move in a logical pattern through the building so that all areas are reinspected. Be. Observe and record each ACBM in the selected room/area, referring to the list of homogeneous areas of ACBM and non-ACBM abstracted from the management plan (see Sample Reinspection Form 2). Each suspect ACBM in the room/area should be on the list of information abstracted from the management plan. Identify each ACBM, assumed ACBM, and non-ACBM material. Note the description of each and use consistently in other rooms/areas. If debris, residue, or overspray of an ACBM is noted in a room/area where it was reported to have been removed, this should be recorded so that the response action can be completed. If an observed material is not on the list of abstracted information, determine whether the unlisted material is fiberglass, foam glass, rubber or other material which the AHERA regulation excludes from inspection. If it is not an excluded material, it is a previously unidentified material. Proceed in accordance with instructions from the designated person (see page 2-7, A2e). |~1 B9. Mark the rooms/areas where each ACBM waa observed on the location diagram or floorplan (optional). Describe the location of each ACBM on the reinspection form. If the designated person wishes additional location diagrams or floorplans, mark them while in each room/area. |-| Bio. Re-estimate the quantity of each ACBM In the selected room/area (if requested by the designated person). If the designated person has requested re-estimation of ACBM quantities, measure each ACBM. Also, make original estimates of the quantity of newly identified suspect material. | | B11. Touch each ACBM in the room/area to determine whether it is friable. Touch each ACBM in at least one location. Determine whether the ACBM is friable or nonfriable. A friable material is one which can, when dry, be crumbled, pulverized, or reduced to powder by hand pressure. It is not advisable to touch friable materials in every location as this may cause unnecessary fiber release. Once you determine a material is friable, you may discontinue touching it. If, however, the material has been encapsulated in a room/area, you should examine it closely across the entire surface and touch it in various locations to ensure the encapsulation is complete for the entire homogeneous area. Based on the touch determination, the friability rating of an ACBM may be changed during the reinspection: Previously considered nonfriable materials may be reclassified as friable, e.g., where water has deteriorated the bonding matrix; or Previously considered friable materials may be reclassified as nonfriable, e.g., if an adequate encapsulation of surfacing material or enclosure of TSI has been performed. Q B12. Collect additional bulk samples, as instructed by the designated person. If the designated person wants the inspector to collect bulk samples, it is most efficient to collect them while in the room/area. However, in some cases, reinspection must be completed before bulk sampling can begin. In these cases, define new homogeneous sampling areas and determine random sampling locations in accordance with 40CFR763.86. Whenever the homogeneous area is large, EPA recommends that at least three samples be taken. B13. Look at the condition and determine the potential for damage or aignificant damage to each friable ACBM and asbestos-containing TSI in the room/area. Look at the condition of each friable ACBM and asbestos-containing TSI to determine if the material is not damaged, damaged, or significantly damaged. Familiarize yourself with the definition of damaged and significantly damaged friable ACBM as given in the AHERA regulations and interpretive documents. For information on obtaining these documents see Appendix F. Determine the reasonable potential for damage or significant damage to undamaged friable ACBM and TSI. The AHERA regulations do not specify the procedure for making this determination. Some suggestions include considering the use of the area or the presence of water, vibration, or air streams. An additional factor is the likelihood of human contact with the material. Most inspection companies have created decision trees for use by their employees. Inspector training curricula also provide decision trees for determining potential for damage. The spatial unit for determination of damage and potential for damage may vary. The entire homogeneous area, the ACBM in each room, or some grouping of rooms/areas may be used. In any case, it is best to record ACBM condition in each room quantitatively and descriptively. For example, record "Room B3 - 10 square feet of surfacing material severely damaged due to water leak above." f~l B14. Assign a reassessment category to each friable ACBM and asbestos-containing TSI in the room/area. Assign a category to each friable ACBM and each asbestos containing TSI in the room/area. Assign the appropriate AHERA 1 through 7 category (either numerically or in exact words) based on damage, potential for damage, and material category. Examine the original assessments carefully as the correct number may not have been used, or numbers may not have been used at all. Also other assessment rankings have been developed and you may use these in addition to but not instead of, the AHERA categories to add detail to the assessments. The seven AHERA assessment categories are as follows: 1. Damaged or significantly damaged TSI ACBM. 2. Damaged friable surfacing ACBM. 3. Significantly damaged friable surfacing ACBM. 4. Damaged or significantly damaged friable miscellaneous ACBM. 5. ACBM with potential for damage. 6. ACBM with potential for significant damage. 7. Any remaining friable ACBM or friable suspected ACBM. r Even when inspectors use the same assessment scheme, assessment variability may be high. Thus, it is important to review the initial assessment rather than performing "blind" reassessments. If the assessment is different than the original AHERA assessment, but the condition of the material is probably the same, explain this difference. For example, "assessed each room rather than the entire homogeneous sampling area." Use periodic surveillance records as a reference for change. (~~[ 815. Record the justification of the assigned reassessment category (can use assessment form or notes). The AHERA regulations require a justification for each reassessment category assigned. This may be done by completing a separate assessment form or simply explaining the assigned category. Material category, current amount of damage, and potential for damage are the minimum considerations in justifying the assigned assessment category. However, the causes of the damage, the type of damage, the amount and location and accessibility of the material, and types and number of occupants using the area are all important to the management planner in determining appropriate response actions. |~| B16. Photograph the material, if requested by the designated person. Photograph ACBM in the room/area in accordance with instructions from the designated person. [~~| B17. Assess previously unidentified materials in the room/area, if requested by the designated person. If the designated person wants previously unidentified suspect materials inspected, assess these materials while in the room/area. Classify each material into one of the three material type categories (thermal system insulation, surfacing material, or miscellaneous material), determine friability, and assign an assessment category. If previously unidentified materials are found, but have not been included as part of the reinspection, we suggest you inform the designated person of the additional material. |~~] B18. Move to next room/area and repeat as above. Start the reinspection in one room/area and proceed in a logical sequence from room to room until all rooms/areas of the building with ACBM have been reinspected. t i I The AHERA regulation does not require reinspection of rooms/areas in which no ACBM was reported during the original AHERA inspection. Confirm the full scope of the reinspection with the designated person prior to field work. LEAs are being encouraged to reinspect all rooms/areas to correct any deficiencies from the original inspection. We recommend that rooms/areas in which the presence or absence of ACBM is not well documented be reinspected. Such areas might include: areas locked or otherwise inaccessible during the original inspection; areas where ACBM might be present but were not clearly indicated in the management plan. Examples include rooms where pipe elbow insulation might be present above the suspended ceiling, or student restrooms which are attached to classrooms but not indicated as containing floor tile; areas where renovation may have exposed new material. The EPA did not intend that inspectors undertake destructive steps in locating suspect ACBM and, thus, some materials that were hidden at the time of the original inspection may now be visible because of building renovations; and areas where ACBM has been removed (to ensure the completeness of the removal activity). I""! B19. Complete all field form data items. Review each form to ensure you have completed all data items. Clarify any entries that are incomplete or vague. Make sure your handwriting is legible, and all abbreviations used are clear. f~~] B20. Record name, signature, date, and accreditation number and State (if applicable) on the reinspection form. Sign and date the form and provide current accreditation information. [""1 B21. If additional bulk samples were collected, include the exact locations where they were taken. Also Include a description of the process used to select sample locations, and the name, signature, date, and accreditation number and State (if applicable) of the Inspector(s) collecting each bulk sample in each copy of the school's management plan. Record all of the information listed above whenever a bulk sample is collected. Many management plans do not describe the procedures used to determine each sampling location. Often, the plan merely quotes the AHERA requirements for the number of random samples based on quantity of surfacing material present. Many do not state how sample locations are determined for each thermal system insulation and miscellaneous material. 3-! 3 r~l B22. Submit the result* of the reinspection to the AHERA designated person within 30 days after the reinspection is completed. Note, at a minimum, any changes in ACBM assessment Deliver the reinspection report to the designated person within 30 days after completing the field activities. This report must indicate any changes in ACBM assessment. Thus, if you found no changes in assessment the reinspection report can be as simple as a letter stating that fact. The designated person may, however, have requested a more elaborate report documenting the actual locations and the specific ACBMs reinspected. CHAPTER 4. MANAGEMENT PLANNER'S REINSPECTION RESPONSIBILITIES Exhibit C presents the management planner's checklist of reinspection activities, including recommendations for response actions and recordkeeping. These activities are described in this chapter. | | Cl. Review the results of the original AHERA inspection, periodic surveillance records, and the reinspection. Review the original inspection report, periodic surveillance records, and the completed reinspection forms and report in preparation for making response action recommendations. H C2. Visit the school or take other necessary actions to recommend response actions to the LEA. Take any additional steps needed to make response action recommendations. Such steps may include visiting the building to consider the possible alternative response actions, talking with the inspector to clarify the reassessment information, and reviewing the budget constraints and planned response actions at the school with the designated person. [~~1 C3. For each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI reported by the inspector, make written response action recommendations. Written recommendations for response actions are particularly important if either the assessment or friability determination has changed since the original inspection, or if the reinspection discovers previously unidentified ACBM. [I C3a. Describe preventive measures and response actions for each assessment location of the ACBM. Describe the exact response actions or preventive measure you recommend. For example, preventive measures might include repairing a water leak to prevent further deterioration of pipe joint insulation, installing a doorstop to prevent damage to asbestos walHxjard, or instructing teachers not to hang anything from asbestos-containing ceiling tiles. Describe "how to" perform repairs to ACBM if this response action is recommended. For example, do not say "repair damaged pipe insulation." Rather, say "use wettable lagging and encapsulant to repair damage." 4 I Exhibit C. Recommended Reinspection Checklist for the Management Planner Recommendations for response actions i. Review the results of the original AHERA inspection, periodic surveillance records, and the reinspection. 2. Visit the school or take other necessary actions to recommend response actions to the LEA. |~] 3. For each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI reported by the inspector, make written response action recommendations. n 3a. Describe preventive measures and response actions for each assessment location of the ACBM. I"! 3b. Consider whether cleaning in accordance with procedures In 40CFR763.91(c) should be performed in each area and make appropriate recommendations in writing. [~~| 4. Include a schedule for beginning and completing the recommended cleaning and response actions. n 5. Estimate the resource requirements for the recommended response actions. [~| 6. Review the adequacy of the O&M Plan. Recordkeeping [~~| 7. Record name, signature, date, and accreditation number and State (if applicable) on the reinspection form. [~~| 8. Submit written recommendations for the response actions to the designated person.  C3b. Consider whether cleaning in accordance with procedures In 40CFR763.9l(c) should be performed in each area and make appropriate recommendations In writing. Recommend additional cleaning where friable ACBM, assumed friable ACBM, or damaged or significantly damaged TSI is present. Specify cleaning methods and frequency. Indicate each specific room/area requiring cleaning. Rather than parrot the regulation's statement that cleaning must be performed in certain instances, specify how, when, and where to perform cleaning. |~~) C4. Include a schedule for beginning end completing the recommended cleaning and response actions. Specify a schedule that designates actual dates for beginning and completing each response action recommended so that human health and the environment are protected. |~| C5. Estimate the resource requirements for the recommended response actions. Estimate the resource requirements for all response actions you recommend. This should be a comprehensive presentation of all estimated costs. Include purchase of required ACBM maintenance equipment and supplies, training of personnel, removal costs (including design fees), and air sampling and laboratory costs. |~~1 C6. Review the adequacy of the O&M Plan. Although not specifically required by the AHERA regulation, you should review the adequacy of the written O&M Plan to maintain all ACBM in good condition. If deficiencies are found, make recommendations for changes to the designated person. An example might be to recommend additional training for maintenance personnel in a school where repairs to ACBM have not been sufficient to prevent the release of fibers into the air. |--| C7. Record name, signature, date, and accreditation number and State (if applicable) on the recommendation form. Sign the written recommendations for response actions and provide current accreditation information. f~1 C8. Submit written recommendations for response actions to the designated person. Forward the written recommendations to the designated person. The AHERA regulations do not specify a time frame for this submittal, but it is important to be as prompt as possible and probably should not exceed 30 days. The reinspection is not complete until the management planner has submitted written recommendations. CHAPTER 5. AHERA DESIGNATED PERSON'S RECORDKEEPING RESPONSIBILITIES The designated person has the final responsibility for recordkeeping. This recordkeeping is detailed in Exhibit D. (~1 Dl. Include the reinspection report and recommended response actions in each copy of the school's management plan. Include a reinspection report in every copy of the management plan. In addition to maintaining the report at the district administrative offices and the school's administrative office, as required, the LEA may have copies maintained at maintenance or custodial offices and the designated person's office. [-) 02. Include a written statement indicating agreement or disagreement with the management planner's recommendations for response actions, justification for any disagreement, and an implementation schedule for the response actions in the management plan. (Recommended by the EPA.) Write a statement showing agreement or disagreement with the recommended response actions. Assist in the preparation of a schedule for implementation of the response actions. This schedule must be within the time frame specified by the management planner. If this is not possible, present justification for why the time frame will not be met, and a plan for how the affected materials will be managed in the interim under the O&M Plan. | | D3. Include inspection report findings for any previously unidentified materials (and, if ACBM is found, Include management planner recommendations) In the management plan. If previously unidentified materials were inspected, include the inspection report in the management plan. An inspection report is similar to the reinspection report with additional information. Refer to the AHERA regulation or contact a State or EPA Regional Asbestos Coordinator (Appendix I) for details on inspection reports. [~~1 D4. Include a copy of a document describing steps taken to inform workers and building occupants, or their legal guardians, about the reinspection in each copy of the school's management plan. The AHERA regulation allows a great deal of flexibility in the methods used to notify parents and staff of the reinspection. Letters to PTA and the employee's union, an article in an LEA newsletter, or letters to each parent about the reinspection are all appropriate methods of notification. At a minimum, inform parents and staff that a reinspection has occurred. It may also be useful to tell them of any new materials Exhibit D. Recommended Reinspection Checklist for the AHERA Designated Person Recordkeeping |~1 1 | | 2. 3. |~~| 4. 5. Include the reinspection report and recommended response actions in each copy of the school's management plan. Include a written statement indicating agreement or disagreement with the management planner's recommendations for response actions, Justification for any disagreement, and an implementation schedule for the response actions in the management plan. (Recommended by the EPA.) Include inspection report findings for any previously unidentified materials (and, if ACBM found, include management planner recommendations) in the management plan. Include a copy of a document describing steps taken to inform workers and building occupants, or their legal guardians, about the reinspection in each copy of the school's management plan. Evaluate the effectiveness of the asbestos operations and maintenance (O&M) program and periodic surveillance. Revise, as appropriate. found. Parents and staff generally prefer a letter for each school with comments about specific materials. Exhibit E presents a sample letter for notification of reinspection. Information about reinspections must also be included in the required annual notification to parents and workers. The AHERA regulations do not clearly specify the time frame for providing notification of reinspections. It is best however, that the LEA or school provide notification as soon as possible after receiving the reinspection report and recommendations. At a minimum, include information about the reinspection in the annual notification about management plan availability. Once parents and staff are notified, include a dated notification in the management plan as documentation. Notify the State, if required. |~~| D5. Evaluate the effectiveness of the asbestos Operations and Maintenance (O&M) Program and periodic surveillance. Revise, as appropriate. When the reinspection is complete, take time to evaluate whether the asbestos O&M Program has been effective in maintaining all ACBM. Think about problems the staff has experienced in implementing O&M procedures. Consider alternative procedures and revise the written O&M Program to reflect these changes. An example is adding a written work permit system to prevent maintenance staff from drilling into asbestoscontaining ceiling material. Also, consider whether the periodic surveillance was effective in identifying areas of increased deterioration and damage, and alter the schedule for areas needing closer scrutiny. Delete any O&M procedure which is no longer applicable. An example is deleting the written procedure for repairing pipe elbow insulation after all TSI is removed from the school. Exhibit E. Recommended Sample Reinspection Notification Letter EASTSIDE COMMUNITY PUBLIC SCHOOLS East Park Avenue EastsIde, CA 91005 (999)922-3333 Bob Smith, Superintendent Notification of Asbestos Reinspections TO: FROM: DATE: Parents and Staff of Eastside Middle School Bob Smith, Superintendent of Schools December 15,1991 In compliance with the U.S. Environmental Protection Agency (EPA) Asbestos Hazard Emergency Response Act (AHERA), in the fail of 1988 we performed inspections of each of our school buOdings for asbestos-containing building materials. The inspection findings and asbestos management plans have been on file in each school administrative office since that time. The EPA requires us to perform reinspections of the asbestos materials every three years. During the months of September through November 1991, accredited asbestos inspectors performed these reinspections. An accredited management planner reviewed the results of the reinspections and recommended actions we should take to safely manage each asbestos material in our buildings. Two significant findings were noted during the reinspection of Eastside Middle School: Asbestos-containing water pipe insulation in the kitchen over the dishwasher is slowly deteriorating due to high humidity. The material is scheduled for removal over the Christmas break. Linoleum in all bathrooms was not Included in the original AHERA inspection. The backing (between the vinyl layer and the floor) is assumed to contain asbestos. The vinyl layer is in good condition and provides an effective barrier, preventing asbestos fiber release. This material has been added to our asbestos maintenance program and we will monitor it for any changes in condition. All other asbestos materials in this school are in good condition and we will continue to manage them in piace, as recommended by the accredited management planner. The results of the reinspection are on file in the management plan in the school's administrative office. Everyone is welcome to view these anytime during normal school hours (M-F, 8:00 a.m. - 4:30 p.m ). The Asbestos Program Manager, Jill Williams, is available to answer any questions you may have about asbestos in our buildings at (999) 922-3334. APPENDIX A AHERA REGULATORY CITATIONS FOR REINSPECTIONS r AHERA REGULATORY CITATIONS FOR REINSPECTIONS The following are quotations cited in this document from the AHERA regulations published October 30, 1987. They are presented to assist LEAs, AHERA designated persons, inspectors, and management planners in performing their responsibilities. 40 CFR 763.84 General Local Education Agency Responsibilities (c) Ensure that workers and building occupants, or their legal guardians, are informed at least once each school year about inspections, response actions, and post-response action activities, including periodic reinspection and surveillance activities that are planned or in progress. 40 CFR 763.85 Inspections and Reinspections (b) Reinspections (1) At least once every 3 years after a management plan is in effect, each local education agency shall conduct a reinspection of all friable and nonfriable known or assumed ACBM in each school building that they lease, own, or otherwise use as a school building. (2) Each inspection shall be made by an accredited inspector. (3) For each area of a school building, each person performing a reinspection shall: (i) Visually reinspect, and reassess, under 763.88, the condition of all friable known or assumed ACBM. (ii) Visually inspect material that was previously considered nonfriable ACBM and touch the material to determine whether it has become friable since the last inspection or reinspection. (iii) Identify any homogeneous areas with material that has become friable since the last inspection or reinspection. (iv) For each homogeneous area of newly friable material that is already assumed to be ACBM, bulk samples may be collected and submitted for analysis in accordance with 763.86 and 763.87. (v) Assess, under 763.88, the condition of the newly friable material in areas where samples are collected, and newly friable materials in areas that are assumed to be ACBM. i\ a-: (vi) Reassess, under 763.88, the condition of friable known or assumed ACBM previously identified. (vii) Record the following and submit to the person designated under 763.84 a copy of such record for inclusion in the management plan within 30 days of the reinspection: (A) The date of the reinspection, the name and signature of the person making the reinspection, State of accreditation, and if applicable, his or her accreditation number, and any changes in the condition of known or assumed ACBM. (B) The exact locations where samples are collected during the reinspection, a description of the manner used to determine sampling locations, the name and signature of each accredited inspector who collected the samples. State of accreditation, and, if applicable, his or her accreditation number. (C) Any assessments or reassessments made of friable material, the name and signature of the accredited inspector making the assessments. State of accreditation, and if applicable, his or her accreditation number. 40 CFR 763.93 Management Plans (d) Each local educational agency shall maintain and update its management plan to keep it current with ongoing operations and maintenance, periodic surveillance, inspection, reinspection, and response action activities. All provisions required to be included in the management plan under this section shall be retained as part of the management plan, as well as any information that has been revised to bring the plan up-to-date. (e) The management plan shall be developed by an accredited management planner and shall include: (1) A list of the name and address of each school building and whether the school building contains friable ACBM, nonfriable ACBM, and friable and nonfriable suspected ACBM assumed to be ACM. (2) For each inspection conducted before December 14, 1987: (i) The date of the inspection. (ii) A blueprint, diagram, or written description of each school building that identifies clearly each location and approximate square or linear footage of any homogeneous or sampling area where material was sampled for ACM, and, if possible, the exact locations where bulk samples were collected, and the dates of collection. A-3 (iii) A copy of the analyses of any bulk samples, dates of analyses, and a copy of any other laboratory reports pertaining to the analyses. (iv) A description of any response actions or preventive measures taken to reduce asbestos exposure, including if possible, the names and addresses of all contractors involved, start and completion dates of the work, and results of any air samples analyzed during and upon completion of the work. (v) A description of assessments, required to be made under 763.88, of material that was identified before December 14, 1987, as friable ACBM or friable suspected ACBM assumed to be ACM, and the name and signature, State of accreditation, and if applicable, accreditation number of each accredited person making the assessments. (3) For each inspection and reinspection conducted under 763.85: (i) The date of the inspection or reinspection and the name and signature, State of accreditation and, if applicable, the accreditation number of each accredited inspector performing the inspection or reinspection. (ii) A blueprint, diagram, or written description of each school building that identifies clearly each location and approximate square or linear footage of homogeneous areas where material was sampled for ACM, the exact location where each bulk sample was collected, date of collection, homogeneous areas where friable suspected ACBM is assumed to be ACM, and where nonfriable suspected ACBM is assumed to be ACM. (iii) A description of the manner used to determine sampling locations, and the name and signature of each accredited inspector collecting samples, the State of accreditation, and if applicable, his or her accreditation number. (iv) A copy of the analyses of any bulk samples collected and analyzed, the name and address of any laboratory that analyzed bulk samples, a statement that the laboratory meets the applicable requirements of 763.87(a) the date of analysis, and the name and signature of the person performing the analysis. (v) A description of assessments, required to be made under 763.88, of all ACBM and suspected ACBM assumed to be ACM, and the name, signature, State of accreditation, and if applicable, accreditation number of each accredited person making the assessments. (4) The name, address, and telephone number of the person designated under 763.84 to ensure that the duties of the local education agency are carried out, and the course name, and dates and hours of training taken by that person to carry out the duties. (5) The recommendations made to the local education agency regarding response actions, under 763.88(d), the name, signature, State of accreditation of each person making the recommendations, and if applicable, his or her accreditation number. (6) A detailed description of preventive measures and response actions to be taken, including methods to be used, for any friable ACBM, the locations where such measures and action will be taken, reasons for selecting the response action or preventive measure, and a schedule for beginning and completing each preventive measure and response action. (7) With respect to the person or persons who inspected for ACBM and who will design or carry out response actions, except for operations and maintenance, with respect to the ACBM, one of the following statements: (i) If the State has adopted a contractor accreditation program under section 206(b) of Title II of the Act, a statement that the person(s) is accredited under such plan. (ii) A statement that the local education agency used (or will use) persons who have been accredited by another State which has adopted a contractor accreditation plan under section 206(b) of Title II of the Act or is accredited by an EPA-approved course under section 206(c) of Title II of the Act. (8) A detailed description in the form of a blueprint, diagram, or in writing of any ACBM or suspected ACBM assumed to be ACM which remains in the school once response actions are undertaken pursuant to 763.90. This description shall be updated as response actions are completed. (9) A plan for reinspection under 763.85, a plan for operations and maintenance activities under 763.91, and a plan for periodic surveillance under 763.92, a description of the recommendation made by the management planner regarding additional cleaning under 763.91(c)(2) as part of an operations and maintenance program, and the response of the local education agency to that recommendation. (10) A description of steps taken to inform workers and building occupants, or their legal guardians, about inspections, reinspections, response actions, and post response action activities, including periodic reinspection and surveillance activities that are planned or in progress. (11) An evaluation of the resources needed to complete response actions successfully and carry out reinspection, operations and maintenance activities, periodic surveillance and training. A-5 (12) With respect to each consultant who contributed to the management plan, the name of the consultant and one of the following statements: (i) If the State has adopted a contractor accreditation plan under section 206(b) of Title II of the Act, a statement that the consultant is accredited under such plan. (ii) A statement that the contractor is accredited by another State which has adopted a contractor accreditation plan under section 206(b) of Title II of the Act, or is accredited by an EPA-approved course developed under section 206(c) of Title II of the Act. 40 CFR 763.99 Exclusions (a) A local education agency shall not be required to perform an inspection under 763.85(a) in any sampling area as defined in 40 CFR 763.103 or homogeneous area of a school building where: (1) An accredited inspector has determined that, based on sampling records, friable ACBM was identified in that homogeneous or sampling area during an inspection conducted before December 14, 1987. The inspector shall sign and date a statement to that effect with his or her State of accreditation and if applicable, accreditation number and, within 30 days after such determination, submit a copy of the statement to the person designated under 763.84 for inclusion in the management plan. However, an accredited inspector shall assess the friable ACBM under 763.88. (2) An accredited inspector has determined that, based on sampling records, nonfriable ACBM was identified in that homogeneous or sampling area during an inspection conducted before December 14, 1987. The inspector shall sign and date a statement to that effect with his or her State of accreditation and if applicable, accreditation number and, within 30 days after such determination, submit a copy of the statement to the person designated under 763.84 for inclusion in the management plan. However, an accredited inspector shall identify whether material that was nonfriable has become friable since that previous inspection and shall assess the newly-friable ACBM under 763.88. (3) Based on sampling records and inspection records, an accredited inspector has determined that no ACBM is present in the homogeneous or sampling area and the records show that the area was sampled, before December 14, 1987 in substantial compliance with 763.85(a), which for purposes of this section means in a random manner and with a sufficient number of samples to reasonably ensure that the area is not ACBM. (i) The accredited inspector shall sign and date a statement, with his or her State of accreditation and if applicable, accreditation number that the homogeneous or sampling area determined not to be ACBM was sampled in substantial compliance with 763.85(a). A-6 r1 (ii) Within 30 days after the inspector's determination, the local education agency shall submit a copy of the inspector's statement to the EPA Regional Office and shall include the statement in the management plan for that school. (4) The lead agency responsible for asbestos inspection in a State that has been granted a waiver from 763.85(a) has determined that, based on sampling records and inspection records, no ACBM is present in the homogeneous or sampling area and the records show that the area was sampled before December 14, 1987, in substantial compliance with 763.85(a). Such determination shall be included in the management plan for that school. (5) An accredited inspector has determined that, based on records of an inspection conducted before December 14, 1987, suspected ACBM identified in that homogeneous or sampling area is assumed to be ACM. The inspector shall sign and date a statement to that effect, with his or her State of accreditation and if applicable, accreditation number and, within 30 days of such determination, submit a copy of the statement to the person designated under 763.84 for inclusion in the management plan. However, an accredited inspector shall identify whether material that was nonfriable suspected ACBM assumed to be ACM has become friable since the previous inspection and shall assess the newly friable material and previously identified friable suspected ACBM assumed to be ACM under 763.88. (6) Based on inspection records and contractor and clearance records, an accredited inspector has determined that no ACBM is present in the homogeneous or sampling area where asbestos removal operations have been conducted before December 14, 1987, and shall sign and date a statement to that effect and include his or her State of accreditation and, if applicable, accreditation number. The local education agency shall submit a copy of the statement to the EPA Regional Office and shall include the statement in the management plan for that school. (7) An architect or project engineer responsible for the construction of a new school building built after October 12, 1988, or an accredited inspector signs a statement that no ACBM was specified as a building material in any construction document for the building, or, to the best of his or her knowledge, no ACBM was used as a building material in the building. The local education agency shall submit a copy of the signed statement of the architect, project engineer, or accredited inspector to the EPA Regional Office and shall include the statement in the management plan for that school. r APPENDIX B SAMPLE REINSPECTION FORM 1: ORIGINAL AHERA INSPECTION INFORMATION ABSTRACTED FROM THE MANAGEMENT PLAN AND INSTRUCTIONS FOR USING REINSPECTION FORM 1 B-: o O) to CL c 0C. *c* 3 Eo 2 CD 2 5 Eo 3 o <0 < co 5 c co 2? i1 Vc) <ac LU X < 2 o E uo. co o<aVu) i) IX s si 3i if l 1| 1 *i If cS si i! IwVs 1 I Homogeneous sampling areas Material description Material category 1i 0 wc % Friability '-- - -- AHERA assessment category (1-7. X. None) n9 | ^ s * U. X " z x u. ^ X * a x u. ^ x ? 11 ]" _r % 33 fit 2I1 S ||5 ell e- 3r s8 ]M 11 2s 1 I ! a * s C - -AMERA assessment category: t = Damaged or significantly damaged TSI ACBM, 2 Damaged triable surfacing ACBM, 3 Significantly damaged triable surfacing ACBM, 4 - Damaged or significantly damaged friable miscellaneous ACBM, S - ACBM with potential for damage. 6 ACBM writ) potential for significant damage. 7 - Any remaining friable -ACBM or friable suspected ACBM. X not applicable (material fa non-ACBM or nonfriable surfacing or miscellaneous material). None No aasesament category provided In original Inspection. r SAMPLE REINSPECTION FORM 1: ORIGINAL AHERA INSPECTION INFORMATION ABSTRACTED FROM THE MANAGEMENT PLAN Instructions for Use Assemble the management plan and all related documentation, e.g., removal records and periodic surveillance reports, for the school. It is best if the inspector who will perform the reinspection completes this form, but anyone familiar with inspection and reinspection protocols may do so. A completed example of Form 1 is presented on page B-6 to illustrate the process. School Enter the name of the school whose AHERA management plan you are reviewing. Building Enter the name of the first building whose inspection information you are reviewing. If there is more than one building at the school, complete a separate Form 1 for each building. Date(s) of Original AHERA Inspection Locate the date(s) on which the original AHERA inspection occurred in the building and record. Homogeneous sampling areas - ID number Scan the management plan for a list or other description of homogeneous sampling areas, including all non-ACBM homogeneous sampling areas. As you find each one, record the identification number assigned to the material. If an identification number was not assigned, enter "X" in this block. Homogeneous sampling areas Material description Record the complete, word-for-word description of each ACBM and non-ACBM homogeneous sampling area next to the appropriate ID number. An example is "2x4 white lay-in ceiling tile" or "2x4 off-white ceiling tile." Small variations in descriptions can be important in differentiating homogeneous sampling areas during subsequent fieldwork. Fill in the quantity of the material where that could help in differentiating between similar materials. Check the list of bulk samples collected and the laboratory report for possible non-ACBMs. Material category Find the assigned material category for each material identified (TSI, surfacing material or miscellaneous material) and circle the corresponding category in this column. Asbestos content Find the asbestos content of each homogeneous sampling area. Circle "Assumed" if the material was assumed to contain asbestos, "Yes" if the material is known to contain asbestos based on laboratory analysis of bulk samples, or "No" if the material is known to be non-asbestos-containing based on laboratory analysis of bulk samples, or non-ACBM by definition (e.g., metal, wood, fiberglass, or rubber). Friability Find the AHERA inspection's friability determination for the known and assumed ACBM. Circle "P if the material was rated as friable, "NP if the material was rated as nonfriable, or "X" if the material was determined to be non-ACBM. AHERA assessment category (1-7, X, None) Find the assessment category(ies) assigned to the friable homogeneous sampling areas of ACBM and the asbestos-containing TSI. If they were assigned as AHERA category 1-7, record in this column. Examine the original assessments carefully as the correct number may not have been used, or numbers may have not been used at all. Refer to the definitions on the bottom of Sample Form 1 if words are used in the original management plan. If more than one category was assigned, write each of these in a separate row next to the appropriate locations (see the two pipe elbow insulation entries on the completed example of Sample Form 1). If the original AHERA inspection did not use the AHERA 17 categories, record the original insepction's actual words in this column. If the material is non-ACBM or was rated nonfriable surfacing or miscellaneous material, no assessment was required. Enter "X" in this column. If no assessment category is provided for friable ACBM as required, record "none" in this column. Recorded locations of material for each assessment category Scan the management plan for all listed or otherwise described locations of the material. Be sure to check bulk sample collection locations, especially for non-ACBMs. Record each room/area in which the material is present. If a floorplan shows the locations of the material in the management plan, a copy of the floorplan can replace the listing of all rooms/areas in this column. In this case, simply write "see attached floorplan" in the space provided. You should list the rooms/areas by assessment category and general location in the school on this form. For example, if pipe elbow insulation in the boiler room was reported as assessment category 1, list the boiler room in a separate row next to assessment category 1. If the pipe elbow insulation above ceiling tiles was reported as assessment category 5, list these areas in a separate row next to assessment category 5 (see the completed example of Sample Form 1). Response Actions Taken/Renovations/Other Comments Review the management plan for all completed response actions. In addition, consult the designated person about response actions taken and renovations which have occurred in the building. Renovations, in particular, may not be indicated in the management plan. Summarize response actions and renovations in the space provided. If a material is non-ACBM, AHERA regulations do not require response actions. Enter "X" in this column (see row 3 of completed example of Sample Form 1). If an ACBM is nonfriable, response action recommendations are not required but were often recommended or performed. Enter "X" or a brief summary, as appropriate. Row 1 of Sample Form 1 shows an example of this latter situation where floor tile rated as nonfriable was included in the O&M program. Information Abstracted By Date Sign the form and record the date on the lines provided. Continue to the next blank row for each homogeneous sampling area reported in the management plan until you have described all materials in the building. Use more than one Form 1 when there are more than six materials with different assessment categories in a building. Number all pages when inspection information has been abstracted for all materials in the building. For example, number two pages, page 1 of 2 and page 2 of 2. If there is more than one building to be reinspected at the school, complete one or more Form Is for each building. B-5 oc 3 co u. Z 3 3* 3 Al (ERA assessment category-. t = Damaged or significantly damaged TSI ACBM, 2 Damaged friable surfacing ACBM, 3 = Significantly damaged friable surfacing ACBM, a Damaged or significantly damaged friable miscellaneous ACBM. 5 *= ACBM with potential for damage, 6 - ACBM with potential for significant damage. 7 = Any remaining friable ACBM or friable suspected ACBM. X not applicable (material Is non-ACBM or nonfriable surfacing or miscellaneous material), None No assessment category provided In original inspection. APPENDIX C SAMPLE REINSPECTION FORM 2: REINSPECTION OF ACBM: FINDINGS AND MANAGEMENT PLANNER RECOMMENDATIONS AND INSTRUCTIONS FOR USING REINSPECTION FORM 2 C-! pin I!<`inspection Form 2. Reinspection ol ACBM. Findings and Management Planner Recommendations Faye SAMPLE REINSPECTION FORM 2: REINSPECTION OF ACBM FINDINGS AND MANAGEMENT PLANNER RECOMMENDATIONS Instructions For Use Use Form 2 to record information about a single homogeneous sampling area of ACBM. Complete a separate Form 2 for each different ACBM observed. Note, however, that this form does not fulfill all requirements for a reinspection under AHERA. The inspector, management planner, and designated person each have a role in completing this form. The inspector completes the left-hand portion of the form as described below on pages C-3 to C-6. The management planner completes the right-hand portion of the form as described on pages C-7 to C-8. The designated person completes the bottom row of the form as described on page C-9. A completed Form 2 is presented on page C-10 to aid in understanding these instructions. School Enter the name of the school to be reinspected. Building Enter the name of the first building to be reinspected. If there is more than one building at the school, complete a separate set of forms for each building. Date(s) of Reinspection Enter the date(s) during which the building reinspection occurs. Homogeneous Sampling Area: Material Description Refer to the original inspection information on Form 1 (or other similar source). On Form 2, write the complete, word-for-word description of one asbestos-containing homogeneous sampling area observed in the first room. It is important to differentiate similar homogeneous areas of material at this point, e.g., 2x4 white lay-in ceiling tile (or panels) versus 2x4 off-white ceiling tile. Homogeneous Sampling Area ID Number If the management plan assigns identification numbers to the asbestos-containing homogeneous sampling area, record the number in the space provided. If identification numbers were not assigned, enter "X" in this block. C-3 Inspector Locations of ACBM by assessment category Record each room/area where you observe the material during the reinspection. It is preferable to list each individual room/area where the material is present, one to a row, in this column. However, grouping rooms is acceptable as long as it is dear which rooms are included in the grouping. Each room/area in a group must receive the same assessment category. For example, recording "Rooms #101-110" is acceptable if (1) all 10 rooms contain the material, (2) all material is in the same condition, and (3) all material has the same potential for damage. Maintaining the same groupings of rooms as used in the original inspection may ease comparison between assessments and reassessments. If the designated person has requested that the inspector mark a floorplan with the location of each material, do that now. Quantity If the reinspection will re-estimate material quantities or report them on a room by room basis, measure the dimensions of the material in the room/area and record in the space provided. If the reinspection will not re-estimate quantities, enter "X" in the space provided. Friability Touch the material as required to make the friability determination for the room/area. Circle "P if the material is friable, or "NP if it is nonfriable. Assessment category Assign the appropriate assessment category 1-7 to friable ACBM. and all asbestoscontaining TSI. Enter the number in this column. If you are segregating the material into two or more assessment categories, write each number in a separate row adjacent to the room/area descriptions appropriate to the assessment (note the three assessment categories assigned the lxl ceiling tile on the completed example of Sample Form 2). If the material is nonfriable surfacing or miscellaneous ACBM, enter "X" in this column (see row 1 on the completed example of Sample Form 2). Justification of assessment category Briefly describe the rationale for assigning the assessment category, mentioning the cause of any damage or potential for damage. The justification is particularly important if a change in the assessment has occurred. L -- I^r>ector Some inspection companies use specialized assessment forms to record the factors they consider in assigning the assessment category. Many have a decision tree leading the inspector to the assigned assessment category based on the information from the assessment form. These forms are acceptable alternatives to the written justification used on Form 2. If you use these forms, write "see assessment form(s)" in this column and attach the completed forms. Change in assessment Compare the AHERA inspection assessment data on Form 1 (or equivalent) for the material in the location selected. If there is a difference between the original and the reinspection assessment, circle "Yes". If no difference was noted, circle "No". If different spatial units are used for the reassessments, consider whether substantive changes have actually occurred to the material in the selected location and circle "Yes" or "No" accordingly. When all ACBM in the selected room/area has been reinspected, go to the next room/area and repeat as above until each room listed in the original EPA inspection as having ACBM has been reinspected. Continue to the next row on Form 2 and record each location in which an ACBM is observed. Use more than one Form 2 when there are more than three locations of an ACBM with different assessment categories in a building. Number all pages when all rooms/areas have been reinspected. Count the number of pages for each ACBM, then number page 1 of 2, page 2 of 2, and so forth. Before leaving a room/area, perform an inspection for previously unidentified materials if designated person has requested one. Were additional samples of this ACBM collected? If additional bulk samples of the ACBM are collected, circle "Yes". This is a flag to the management planner and designated person to look for the bulk sample records and laboratory analysis results. If no bulk samples of the ACBM were collected, circle "No." C-5 i *15 Inspector name Clearly print your name. Inspector signature Sign your name. Accreditation #/State Record your AHERA inspector accreditation number and state of accreditation, if applicable. Expiration date Record the expiration date of your accreditation. This date must be later than the date of the reinspection. Submit the reinspection form(s) to the designated person who will submit it to the management planner for recommendations for response actions. <~.f. Inspecro' The management planner completes the right-hand portion of Sample Form 2. The management planner may need to visit the building or take other actions to determine appropriate response actions. This should be done before completing the form, as required. Preventive measures, response actions and initial/additional cleanings Review the results of the reinspection of each ACBM in each room/area and recommend the appropriate response actions including preventive measures. Consider whether initial cleaning should be performed around newly friable ACBM and whether additional cleaning is required for materials which remain friable. Schedule/Begin Specify a schedule for beginning the recommended response action. You may have to discuss the best time for activities, such as removal, with the designated person. Schedule/Complete Specify a schedule for completing the recommended response action. You may need to consult the designated person or a project designer to determine a feasible time frame for certain activities, such as removal Date of management planner review Record the date on which you reviewed the reinspection findings and made the recommendations for response actions. Management planner name Clearly print your name. Management planner signature Sign your name. Accreditation #/State Record your AHERA management planner accreditation number and State of accreditation, if applicable. C-~ Manapement Planner Expiration date Record the expiration date of the accreditation. This date should be later than the date of the reinspection. l i J Once the recommended response action for each ACBM in each location is recorded, submit reinspection forms to the designated person. C-8 Management Planner The AHERA designated person fills in the bottom line of Sample Form 2. I, the LEA's Designated Person, have read and understood the recommendations made above: Sign Form 2 where indicated as acceptance of the completed reinspection document. Prepare a separate statement indicating your agreement with the recommendations made and the reason(s) for your determination. Provide the LEA's schedule for implementation in this statement. Date Date your signature. Include the completed reinspection forms in each copy of the management plan for the school. C-9 Designated Person COMPLETED EXAMPLE O CL i J </i Co 15 *2 E cEo<0c)j jow0cc) CL ac> Eao<>o Cw o c(OA5) | 2 COD < o 5 y 6v> c'5c csi c c L. a APPENDIX D ANSWERS TO THE MOST FREQUENTLY ASKED QUESTIONS ABOUT REINSPECTIONS UNDER THE AHERA ASBESTOS-INSCHOOLS RULE D-l Answers to the Most Frequently Asked Questions About Reinspections Under the AHERA Asbestos-In-Schools Rule This document has been prepared in response to the many inquiries that have been received by the Environmental Protection Agency (EPA) concerning the reinspection requirements and related provisions of the Asbestos Hazard Emergency Response Act (AHERA) regulations. The answers developed here represent the Agency's responses to the most frequently asked questions on this subject. We believe most problem areas have been addressed. However, it is likely that additional questions will occur as the reinspection cycle gets underway. This document is not intended to cover every conceivable query about the reinspection process. It should be used as an adjunct to the AHERA rule for additional clarification of the regulations. Any questions not answered by this document can be referred to the appropriate Regional Asbestos Coordinator listed on the last page or the EPA Toxics Hotline in Washington, D.C. at 202/554-1404. Office of Toxics Substances Office of Pesticides and Toxic Substances U.S. Environmental Protection Agency Washington, D.C. 20460 Mav, 1991 REINSPECnONS Questions & Answers Question 1: Answer: Question 2: Answer: Question 3: Answer: Question 4: Answer: By what date must an LEA have had its school reinspected? Under AHERA, school buildings most be reinspected every three years. The first triennial reinspection must occur within three years after a management plan is in effect [See Section 763.85(b)]. Each LEA was required to develop a management plan no later than May 9,1989. Implementation of the plan was required to begin by July 9,1989. Therefore, the first round of three year reinspections must be completed by July 9,1992. If implementation of the management plan began prior to July 9,1989, must the reinspection take place within three years of the actual date the plan was first implemented? YES. The original management plan should have contained reinspection guidelines. These guidelines should have emphasized that as part of implementing the management plan, all reinspection information must be incorporated into the document If implementation of a management plan began prior to July 9,1989, the first reinspection should take place within three years of the date the plan was first implemented. However, since implementation of all management plans had to begin no later than July 9, 1989, if the date when implementation first occurred cannot be specifically ascertained, reinspection must take place no later than July 9,1992. Ifa management plan wasfirst implemented on January 10,1989 and the LEA had a reinspection on January 10,1992, could the second reinspection date be extended to July 9,1995, or would it have to be done by January 10, 1995? Section 763.85 (b) requires reinspections to be done "at least once every three years." Therefore, the next triennial reinspection would have to be done on or before January 10,1995, within three years of the first reinspection. If the original inspection overlooked some asbestos-containing building materials (ACBM) or ifsome areas of the building were not accountedfor in the first inspection, must the reinspection include the inspection, assessment and documentation of these overlooked areas? NOT REQUIRED by regulation BUT STRONGLY RECOMMENDED BY EPA. While it is not an AHERA requirement, we stronpiv urge all schools to reinspect those areas or 1 Question 5: Answer: Question 6: Answer: materials in their buildings that may have been overlooked in their initial school inspections. As a result of an EPA-sponsored AHERA evaluation study and various enforcement activities, it was discovered that, in the original inspections, certain categories of ACBM were frequently missed by inspectors and do not appear in many management plans. Therefore, inspectors conducting reinspections should make sure that materials such as ceiling tile, wallboard, plaster walls, linoleum, fire doors, duct insulation and vibration dampening cloth, which are considered suspect ACBM, are identified and included in the management plan. The regulations regarding reinspections impose no requirement beyond reinspecting the materials and areas covered in the original inspection, plus any additional materials discovered subsequent to the original inspection; that is, reinspection encompasses "all fiiable and nonfriable known or assumed ACBM." [Section 763.85(b)(3)(i)]. EPA strongly recommends, however, that the reinspection be thorough so that any deficiencies in the original inspection will be addressed in the reinspection. Any actual or assumed ACBM not previously identified that is discovered during reinspection (or periodic surveillance) should be included in an update to the management plan. The update must include a management planner's recommendations for appropriate response actions based on an accredited inspector's assessment [See Section 763.88(d)]. If the time interval for a 6 month periodic surveillance inspection should coincide with the date for the reinspection, can the reinspection also satisfy the periodic surveillance requirement? YES, since reinspection includes everything that would be covered in the 6 month surveillance. Is reinspection requiredfor buildings in which no ACBM, known or assumed, was found in the original inspection, or where abatement subsequent to the original AHERA inspection removed all ACBM? NO. Since the AHERA rule confines the reinspection to "all friable and nonfriable known or assumed ACBM," reinspection is not required for buildings which contain no ACBM. However, in accordance with Sections 763.93(d) and (e), management plans should document the asbestos removal as a response action activity in accordance with Sections 763.94(b) and (g); or, if applicable, contain an inspection report or architect's statement that the building is asbestos-free; or that no ACBM was specified in its construction [see Sections 763.99(a)(6) and (7)]. Schools that have conducted asbestos abatement to remove all ACBM should conduct a reinspection in case some ACBM was missed. In addition, LEAs must Question 7: Answer: Question 8: .Answer: Question 9: Answer: continue to appoint a "designated person," retain their management plans indefinitely, and provide annual written notification to parent, teacher, and employee organizations of the availability of the plan. Will areas of newlyfriable ACBM or assumed ACBM be required to undergo initial cleaning in accordance with Section 763.91 ? YES. If upon reinspection (or during a periodic surveillance) the condidon of ACBM or assumed ACBM has changed from the original AHERA inspection to friable from nonfriable, and the building has not been cleaned since the original inspection, the following requirements as stated in Section 763.91(c)(1) will apply: "Initial cleaning. Unless the building has been cleaned using equivalent methods within the previous 6 months, all areas of a school building where friable ACBM, damaged or significantly damaged thermal system insulation ACM, or friable suspected ACBM assumed to be ACM are present shall be cleaned at least once after the completion of the inspection required by Section 763.85(a) and before the initiation of any response action, other than 0 & M activities or repair...." AHERA requires that an an accredited management planner review the results of each inspection and assessment. Is this also requiredfor reinspections? YES. Section 763.88(d) states that "the local education agency shall select a person accredited to develop management plans to review the results of each inspection, reinspection, and assessment for the school building and to conduct any other necessary activities in order to recommend in writing to the local education agency appropriate response actions." The review and response action recommendations are particularly important if assessments of known or assumed ACBM have changed from the initial AHERA inspection, or if known or assumed ACBM, previously identified as nonfriable, has become friable. Must an LEA reinspect a building that is no longer in use as a school? NO. Section 763.85(b)(1) indicates that LEAs shall conduct a reinspection in buildings that they "lease, own, or otherwise use as a school building." However, if the building is not being used as a school at the time its reinspection would have occurred (even if the LEA continues to lease or own the building), the LEA must be able to certify that it is no longer using the building as a school. In addition, if an LEA has stopped using a holding as a school, and later decides to use the building as a school, it must be reinspected in accordance with Section 763.85(b). Question 10: Answer: When must an LEA reinspect a school brought into service after October 12.1988? Section 763.85(a)(2) requires inspection of schools brought into service after October 12.1988 prior to use of a building as a school. Section 763.93(a)(3) requires submission of a management plan for such schools to the Governor prior to use of the building. The management plan of a school building brought into service after October 12,1988 would be in effect 90 days after submission of the plan to the State Governor unless the plan is disapproved. Reinspection must occur within 3 years of the date the plan is in effect, that is, 90 days after submission to the Governor. Question 11: Answer: What reinspection records must be included in the management plan? In accordance with Section 763.85(b)(3)(vii), the following records must be included: The date of the reinspecdon, the name and signature of the person making the reinspecdon. State of accreditation, and, if applicable, his or her accreditation number. Any changes in the condition of known or assumed ACBM. The exact locations where samples were collected during the reinspecdon, a description of the manner used to determine sampling locations, the name and signature of each accredited inspector who collected the samples. State of accreditation and, if applicable, his or her accreditation number. Any assessments or reassessments made of friable material, the name and signature of the accredited inspector making the assessments. State of accreditation, and if applicable, his or her accreditation number. In addition, the written recommendations of the management planner must be included in the management plan (See Section 763.88(d)]. Question 12: Answer: How should assessments or reassessments made as a result of the reinspection be documented? Sections 763.88(a)(1) and (2) require that the accredited inspector provide a written assessment of all known or assumed friable ACBM in the school building, and submit a copy of the assessment to the designated person within 30 days of the assessment If there is no change in the material from the initial inspection, the accredited person can simply refer to the initial assessment Question 13: Answer: What are the necessary components of an AHERA reinspection? An accredited inspector should visually reinspect and reassess the condition of all known or assumed friable ACBM; visually inspect previously considered nonfriable ACBM and touch it to determine if it has become friable; identify homogeneous areas of material that have become friable since the last inspection; develop required records (detailed in the Answer to Question 11) and submit such records to the LEA's designated person within 30 days of reinspection. Question 14: Answer: What are the required qualifications for the persons involved in the reinspection? The person conducting the reinspecnon must be accredited under AHERA as an inspector, and his/her accreditation must be current for the period in which the reinspection takes place. The management planner responsible for the review of the results of the reinspection and recommendations for response actions must be accredited as a management planner under AHERA and his/her accreditation must be current for the period in which the review of the reinspecuon takes place. Question IS:. Answer: When the management plan is revised as a result of the reinspection, does the updated plan have to be resubmitted to the State? NO. A management plan has to be submitted to the Governor of the State when it is first developed. AHERA does not require subsequent updates or other changes to the plan to be submined to the State. APPENDIX E GLOSSARY OF TERMS E-j GLOSSARY OF TERMS ACBM ACBM Condition Administrator (EPA) AHERA AHERA regulation/rule Asbestos-containing building material, which includes surfacing material, thermal system insulation, or miscellaneous material that is found in or on interior structural members or other parts of a building. Good: No visible damage or deterioration, or showing only very limited damage or deterioration. Damaged: Physical injury or deterioration such that the internal structure of the material is inadequate, material which has delaminated such that its bond to the substrate is inadequate, or which lacks fiber cohesion or adhesion properties for any other reason. Thermal system insulation (TSI) is considered damaged when it is lacking part or all of its covering. Such damage may be shown by the separation of ACM into layers; fialong, blistering, or crumbling; water damage or stains; scrapes, mars or gouges; exposed TSI beneath its covering. Significantly Damaged: Damage that is extensive and severe. The person appointed by the President to run the EPA. The Asbestos Hazard Emergency Response Act. This Act was signed into law on Oaober 22, 1986 by President Reagan. It established the framework for a regulation which requires, among other things, that elementary and secondary schools identify asbestos-containing materials in school buildings, institute programs aimed at minimizing the risk of asbestos exposure in those buildings, and reinspect those materials at least every 3 years. 40 CFR 763, Asbestos-Containing Materials in Schools: Final Rule and Notice, U.S. Environmental Protection Agency, February, 1987. AHERA 1-7 Categories AHERA Designated Person/Designated Person Asbestos Asbestos-containing Assessment Assumed ACBM Bulk Sample Seven categories defined in the AHERA regulations, one of which must be assigned to each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI during an inspection or reinspection. 1. Damaged or significantly damaged TSI ACBM. 2. Damaged friable surfacing ACBM. 3. Significantly damaged friable surfacing ACBM. 4. Damaged or significantly damaged friable miscellaneous ACBM. 5. ACBM with potential for damage. 6. ACBM with potential for significant damage. 7. Any remaining friable ACBM or friable suspected ACBM. Person designated by the Local Education Agency to ensure that the AHERA requirements are properly implemented. Naturally-occurring fibrous mineral used in many building materials, primarily for fireproofing, thermal system insulation, sound insulation, and decoration. Any material, when referring to school buildings, which contains more than one percent asbestos. Evaluation of the physical condition and potential for damage of all friable ACBM and asbestos-containing thermal system insulation. AHERA requires classification of each ACBM assessed into one of seven categories based on material type and damage/potential for damage. Suspect building material that has not been sampled and analyzed for asbestos content and must, therefore, be treated as an ACBM by the LEA. A small portion (usually about thumbnail size) of a suspect asbestos-containing building material collected by the inspector for laboratory analysis to determine asbestos content. E-3 Completed Reinspectton Current Accreditation Encapsulation Enclosure EPA Evaluation Study Exclusion Exterior Areas The entire process of the visual examination and assessment of known and assumed ACBM in a school building; recommended response actions by the management planner; and submission of reinspection findings and recommendations to the designated person. Reinspections are required by AHERA every 3 years after management plan implementation. Having successfully completed an EPA-approved accreditation or refresher course within 1 year of the reinspection (for inspectors) or the management plan review (for management planners.) Treatment of asbestos-containing material with a liquid that covers the surface with a protective coating or embeds fibers in an adhesive matrix to prevent the release of asbestos fibers. An airtight, impermeable, permanent barrier around as bestos-containing material to prevent the release of fibers. U.S. Environmental Protection Agency. An EPA report entitled Evaluation of the Asbestos Hazard Emergency Response Act (AHERA) One of several situations which permits the LEA to delete one or more of the items required by AHERA. For example, records of previous sample collection and analysis may be used by the accredited inspector in lieu of AHERA bulk sampling. Subdivision of areas of a building with one or more walls open to the outside, such as covered walkways or porticos. Form Friable Functional Space HEPA Homogeneous Sampling Area HVAC Identified Material Any document the inspector uses to record information for the reinspection, or for inspection of previously unidentified materials. Two forms were developed for this reinspection guide: Sample Reinspection Form 1. Original AHERA Inspection Information Abstracted from the Management Plan. Sample Reinspection Form 2. Reinspection of ACBM: Findings and Management Planner Recommendations. When referring to a school building, material that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Includes previously nonfriable material after it becomes damaged to the extent that, when dry, it may be crumbled, pulverized, or reduced to powder by hand pressure. Under AHERA, a room, group of rooms, or homogeneous area designated by a person accredited to prepare management plans, design abatement projects, or conduct response actions. High efficiency particulate air. A special type of filter used in equipment for removing asbestos fibers, e.g., vacuums, air filtration devices. In accordance with /aHERA definitions, an area of surfacing material, TSI, or miscellaneous material that is uniform in color and texture. Heating, ventilation and air-conditioning systems in a building. Any AHERA-defined suspect material found during the original AHERA inspection that was also recorded in the management plan for the building. Local Education Agency (LEA) Management Plan Material Category Miscellaneous Material NESHAP Nonfliable Operations and Maintenance Program (O&M) Original AHERA Inspection/Original Inspection An educational agency at the local level that exists primarily to operate schools or to contract for educational services for elementary and secondary public and non-profit private schools. For non-profit private schools, this includes the building owner. A document that each Local Education Agency is required to prepare under AHERA regulations. It describes all activities planned and undertaken by a school to comply with AHERA regulations, such as building inspections to identify asbestos-containing materials, response actions, and operations and maintenance programs to minimize the risk of exposure to asbestos in school buildings. Broad classification of suspect materials into TSI, surfacing material, and miscellaneous material. Interior building material on structural components, such as floor or ceiling tiles. Does not include TSI or surfacing ma terial. National Emission Standards for Hazardous Air Pollutants, EPA rules under the Clean Air Act. Material that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Program of work practices to maintain friable ACBM in good condition, ensure cleanup of asbestos fibers previously released, and prevent future release by minimizing and controlling friable ACBM disturbance or damage. Examination of school buildings arranged by Local Educa tion Agency, pursuant to AHERA, to initially identify asbestos-containing materials, evaluate the condition of those materials, and take samples of materials suspected to contain asbestos. Inspections are performed by inspectors accredited by the EPA or by EPA-approved State accreditation programs. Periodic Surveillance A visual examination for any change in material condition of ACBM and assumed ACBM in a school building. AHERA requires a periodic surveillance at least once every 6 months. Previously Unidentified Material Any AHERA-defined suspect material present in a building at the time of the original AHERA inspection that is not reported in the management plan. Recorded Location An area in which a suspect material was present during the inspection, and which is indicated in the management plan as having the material present. Reinspection The re-examination, by an accredited inspector, of a school building for which an original AHERA inspection was previously performed, including a re-evaluation and response action recommendations by an accredited management planner. Reinspection of school buildings containing ACBM is required by AHERA regulations at least once every 3 years. Removal Taking out or stripping ACBM from an area, a functional space, or a homogeneous area. Repair Procedures used to patch or cover damaged asbestoscontaining materials, other than enclosure or encapsulation. Examples include covering the damage with plastic sheeting, duct tape, or plaster. Resilient Sheet Flooring/ Linoleum A type of floor covering which is preformed in long sheets. Generally, the sheets are unrolled and secured to the floor with an adhesive. These commonly have a vinyl-based upper surface. The backing may contain asbestos. Response Actions Methods, including removal, encapsulation, enclosure, repair, and operations and maintenance, that protect human health and the environment from friable ACBM. r Room/Area A well-defined space within a building, generally a distinct room, but also a hall, crawlspace, or other distinct space. This term may refer to the entire homogeneous sampling area or to a functional space but is generally a subset of these. School Building Any structure essential to the operation of a school and under the authority of the LEA, including classrooms, student housing, athletic facilities, administrative areas, garages, and maintenance areas. Several buildings may be present at one school Surfacing Material Material sprayed or troweled onto structural members (beams, columns, or decking) for fire protection; or on ceil ings or walls for fireproofing, acoustical or decorative pur poses. Includes fireproofing, textured plaster, and other tex tured wall and ceiling surfaces. Suspect Material Building material suspected to contain asbestos because of past practices in its manufacture and use. Includes surfacing material gypsum wallboard (also called sheetrock or drywall), floor tile, ceiling tile, thermal system insulation, and miscellaneous other materials. Suspect materials are classified as ABCM or non-ACBM by analyzing bulk sam ples to determine asbestos content. Total Amount Estimated amount (in square or linear feet) of suspect material in a building/s at the time of the original AHERA inspection. TSI Thermal system insulation. Material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes. Underestimated Quantity The difference between the total amount of a suspect material found during the Evaluation Study and the amount of the same material recorded in the management plan, when the latter quantity is less than 80 percent of the former. E-S Vibration Dampening Cloth (VDC) WaUboard Cloth commonly found on ductwork where duct size changes, used to reduce noise. Generic term for any wall surface installed as sheets, rather than applied wet. Includes gypsum wallboard (also called sheetrock or drywall), transite panels, etc. APPENDIX F REFERENCES T REFERENCES These documents can be obtained from the Toxic Substances Control Act (TSCA) Hotline by calling (202) 554-1404. USEPA. 1991. U.S. Environmental Protection Agency. Asbestos in Schools: Evaluation of the Asbestos Hazard Emergency Response Act (AHERA): A Summary Report June, 1991. USEPA. 1990. U.S. Environmental Protection Agency. ManagingAsbestos In Place: A Building Owner's Guide to Operations and Maintenance ProgramsforAsbestos-Containing Materials. July, 1990. ("Green Book") USEPA. 1987. U.S. Environmental Protection Agency. Asbestos-Containing Materials in Schools: Final Rule and Notice. 40CFR763. February, 1987. USEPA. 1988. U.S. Environmental Protection Agency. 100 Commonly Asked Questions about the New AHERA Asbestos-in-Schools Rule. May, 1988. USEPA. 1985. U.S. Environmental Protection Agency. Asbestos in Buildings: Simplified Sampling Scheme for Surfacing Materials. Washington, DC, EPA 560/5-85-030A. ("Pink Book") USEPA. 1985. U.S. Environmental Protection Agency. Guidance for Controlling AsbestosContaining Materials in Buildings. Washington, DC, EPA 560/5-85-024. ("Purple Book") p.' APPENDIX G PULL-OUT COPIES OF: 1. SAMPLE REINSPECTION FORM 1: ORIGINAL AHERA INSPECTION INFORMATION ABSTRACTED FROM THE MANAGEMENT PLAN 2. SAMPLE REINSPECTION FORM 2: REINSPECTION OF ACBM: FINDINGS AND MANAGEMENT PLANNER RECOMMENDATIONS 3. RECOMMENDED REINSPECTION CHECKLIST FOR THE AHERA DESIGNATED PERSON-PLANNING FOR THE REINSPECTION 4. RECOMMENDED REINSPECTION CHECKLIST FOR THE INSPECTOR 5. RECOMMENDED REINSPECTION CHECKLIST FOR THE MANAGEMENT PLANNER 6. RECOMMENDED REINSPECTION CHECKLIST FOR THE AHERA DESIGNATED PERSON-RECORDKEEPING 7. RECOMMENDED SAMPLE REINSPECTION NOTIFICATION LETTER 1 j i I i n.' o o> CO CL 1 2 *c3 9 JcO CL O E o 2(0 2 Eo C s Ato < co o c co i (cA <CO ID X < 1 as O E o LL c o o<D s? ' a: t*re: 9 VC Homogeneous sampling areas ID number Material description Material category Asbestos content Friability AHERA assessment category (1-7, X, None) U- Z * * * TSI Surf. Misc. Assumed Yes No _r 8 S2 3 Assumed Yes No Ii Assumed Yes No F NF X -&x TSI Surf. Misc. Assumed Yes No TSI Surf. Misc. TSI Surf. Misc. Assumed Yes No Assumed | Yes No F NF X F NF X Recorded locations of material for each assessment category Response actions taken/ renovationa/other comments ! ! 5c & >l Uz. 1 3 oC 5 I Sc? co Bm ! a * TcI5I X 5 - -AHERA assessment category: 1 = Damaged or significantly damaged TSI ACBM, 2 Damaged friable surfacing AC8M, 3 = Significantly damaged friable surfacing ACBM, 4 Damaged or -significantly damaged friable miscellaneous ACBM. S - ACBM with potential for damage, 6 ACBM with potential for significant damage, 7 Any remaining friable -ACBM or friable suspected ACBM, X - not applicable (material is non-ACBM or nonfriable surfacing or miscellaneous material), None No assesament category provided In original inspection. Roinspeclion Form 2. Reinspection of ACBM: Findings and Management Planner Recommendations Page Recommended Reinspection Checklist for the AHERA Designated Person-Planning for the Reinspection f~~l 1. Select the inspector(s) and management planner to perform reinspection activities; obtain proof of their current accreditations. |~1 2. Determine the scope of work. | 2a. Clarify which buildings are to be included in the reinspection. Determine whether each building is used as a school building. 2b. Determine whether previously grouped, similar materials (e.g., all floor tile) should be separated into distinct materials. 2C. Determine whether previously assumed ACBM should be bulk sampled. Determine whether other bulk samples should be collected. 2d. Determine whether quantities of ACBM should be re-estimated. 2e. Determine whether the inspector should look for previously unidentified suspect materials. (Highly recommended by the EPA.) |~1 3. Deettcermine how the reinspection results will be reported. I | 3a. Determine whether locations of ACBM should be reported on a room-by-room basis, rather than by a building or homogeneous sampling area basis. 3b. Determine whether a floorplan or written description, or both, will be used to locate ACBM. 3c. Determine whether ACBM will be assessed on a room by room, homogeneous sampling area, or some other basis. 3d. Determine whether photographs or videotape will be used to document material condition. Recommended Reinspection Checklist for the Inspector Planning for the reinspection field activities f~l 1- Review the items on the Reinspection Checklist for the AHERA Designated Person Planning for the Reinspection. [~1 2. Select the field forms to be used (reinspection, reassessment, inspection, bulk sample logs, photograph logs, chain of custody, floorplans). 3. Review the management plan for the school (see Sample Reinspection Form 1 in Appendix B). 3a. Obtain or generate a list of all ACBMs and non-ACBMs (and associated identification numbers, if provided) and material categories reported during the original inspection. 3b. Record the sample results for each homogeneous sampling area of suspect material. 3C. Record all reported locations of material (descriptions and/or location diagrams) for each homogeneous sampling area. 3d. Copy the location diagrams, if possible. 3e. Record the original inspection assessment category assigned to ACBM in each room/area. 3f. Record any response actions which have occurred and the location of each. 3g. Record any renovations which have occurred and the location of each. 3h. Review records of periodic surveillance. 4. Arrange administrative details time of inspection, school escort, and keys. 5. Assemble ail field materials. Sa. A supply of all field forms, pens, calculator, tape measure, flashlight, and tools. 5b. Blank floorplans and inspection location diagrams, if available. 5c. Bulk sample collection tools and clean-up supplies, If required. 5d. Personal protective equipment, if needed. 5e. A ladder, if needed. ~c Recommended Reinspection Checklist for the Inspector (Continued) Performing the field activities Q 6. Meet the school escort. Q 7. Select the first room/area to be reinspected. |~~1 8. Observe and record each ACBM in the selected room/area, referring to the list of homogeneous areas of ACBM and non-ACBM abstracted from the management plan (see Sample Reinspection Form 2). |~| 9. Mark the rooms/areas where each ACBM was observed on the diagram or floorplan (optional). Q 10. Re-estimate the quantity of each ACBM in the selected room/area (if requested by the designated person). | | 11. Touch each ACBM in the room/area to determine whether it is friable. | | 12. Collect additional bulk samples, as instructed by the designated person. [ | 13. Look at the condition and determine the potential for damage or significant damage to each friable ACBM and asbestos-containing TSI in the room/area. Q 14. Assign a reassessment category to each friable ACBM and asbestos-containing TSI in the room/area. |~1 15. Record the justification of the assigned reassessment category (can use assessment form or notes). | | 16. Photograph the material, if requested by the designated person. | | 17. Assess previously unidentified materials in the room/area, if requested by the designated person. Q 18. Move to next room/area, and repeat as above. Recordkeeping 19. Complete all field form data items. Q 20. Record name, signature, date, and accreditation number and State (if applicable) on the reinspection form. Recommended Reinspection Checklist for the inspector (Continued) Recordkeeping (continued) f~1 21. If additional bulk samples were collected, Include the exact locations where they were taken. Also include a description of the process used to select sample locations, and the name, signature, date, and accreditation number and State (if applicable) of the (nspector(s) collecting each bulk sample in each copy of the school's management plan. f~1 22. Submit the results of the reinspection to the AHERA designated person within 30 days after the reinspection is completed. Note, at a minimum, any changes in ACBM assessment G-" Recommended Reinspection Checklist for the Management Planner Recommendations for response actions |~| 1. Review the results of the original AHERA Inspection, periodic surveillance records, and the reinspection. Q 2. Visit the school or take other necessary actions to recommend response actions to the LEA. | [ 3. For each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI reported by the inspector, make written response action recommendations. | | 3a. Describe preventive measures and response actions for each assessment location of the ACBM. n 3b. Consider whether cleaning in accordance with procedures in 40CFR763.9l(c) should be performed in each area and make appropriate recommendations in writing. | | 4. Include a schedule for beginning and completing the recommended cleaning and response actions. ("I 5. Estimate the resource requirements for the recommended response actions. | | 6. Review the adequacy of the O&M Plan. Recordkeeping | | 7. Record name, signature, date, and accreditation number and State (if applicable) on the reinspection form. [~~] 8. Submit written recommendations for the response actions to the designated person. Recommended Reinspection Checklist for the AHERA Designated Person Recordkeeping f~l t|~1 2. |~1 3. f~l 4. I | 5. Include the reinspection report and recommended response actions in each copy of the school's management plan. Include a written statement indicating agreement or disagreement with the management planner's recommendations for response actions, justification for any disagreement, and an implementation schedule for the response actions in the management plan. (Recommended by the EPA.) Include inspection report findings for any previously unidentified materials (and, if ACBM found, include management planner recommendations) In the management plan. Include a copy of a document describing steps taken to inform workers and building occupants, or their legal guardians, about the reinspection in each copy of the school's management plan. Evaluate the effectiveness of the asbestos operations and maintenance (O&M) program and periodic surveillance. Revise, as appropriate. Recommended Sample Reinspection Notification Letter EASTSIDE COMMUNITY PUBLIC SCHOOLS East Park Avenue Eastside, CA 91005 (999) 922-3333 Bob Smith, Superintendent Notification of Asbestos Reinspections TO: FROM: DATE: Parents and Staff of Eastside Middle School Bob Smith, Superintendent of Schools December 15, 1991 In compliance with the U.S. Environmental Protection Agency (EPA) Asbestos Hazard Emergency Response Act (AHERA), in the fall of 1988 we performed inspections of each of our school buildings for asbestos-containing building materials. The inspection findings and asbestos management plans have been on file in each school administrative office since that time. The EPA requires us to perform reinspections of the asbestos materials every three years. During the months of September through November 1991, accredited asbestos inspectors performed these reinspections. An accredited management planner reviewed the results of the reinspections and recommended actions we should take to safely manage each asbestos material in our buildings. Two significant findings were noted during the reinspection of Eastside Middle School: Asbestos-containing water pipe insulation in the Kitchen over the dishwasher is slowly deteriorating due to high humidity. The material is scheduled for removal over the Christmas break. Linoleum in all bathrooms was not included in the original AHERA inspection. The backing (between the vinyl layer and the floor) is assumed to contain asbestos. The vinyl layer is in good condition and provides an effective barrier, preventing asbestos fiber release. This material has been added to our asbestos maintenance program and we will monitor it for any changes in condition. All other asbestos materials in this school are in good condition and we will continue to manage them in place, as recommended by the accredited management planner. The results of the reinspection are on file in the management plan in the school's administrative office. Everyone is welcome to view these anytime during normal school hours (M-F, 8:00 a.m. - 4:30 p.m.). The Asbestos Program Manager, Jill Williams, is available to answer any questions you may have about asbestos in our buildings at (999) 922-3334. APPENDIX H MESSAGE FROM THE ADMINISTRATOR OF EPA H-: * PBO'4' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 6 1991 An Advisory to the Public on Asbestos in Buildings: THE ADMINISTRATOR The Facts About Asbestos in Buildings In recent months, there have been a number of scientific and news reports about asbestos in buildings. Unfortunately, some of these may have confused, rather than enlightened, the public about the potential health risks of asbestos exposure and the Environmental Protection Agency's (EPA) policies regarding asbestos in schools and other buildings. I want to summarize the EPA's policies for asbestos control in schools and other buildings. I am providing this summary in the form of five major facts that the Agency has presented in congressional testimony. FACT ONE: Although asbestos ifi hazardous, human risk of asbestos disease depends upon exposure. Asbestos is known to cause cancer and other diseases if asbestos fibers are inhaled into the lung and remain there. This conclusion is based upon studies involving human exposure, particularly exposure at high levels. A recent Science magazine article indicated exposure to chrysotile (common "white" asbestos) nay be less likely to cause some asbestos-related diseases. Although there is more evidence of hazard for some types of asbestos, EPA believes there is reason to be concerned about other types, such as chrysotile, for which the data are less conclusive. Based on careful evaluation of available scientific evidence, EPA has adopted a prudent approach in its regulations of assuming that all fibers are of equal concern. Various scientific and regulatory organizations, including the National Academy of Sciences, support EPA's more protective regulatory approach. It is important to stress that the mere presence of a hazardous substance, such as asbestos on an auditorium ceiling, no more implies that an asbestos-related disease will develop than a poisonous substance in a medicine cabinet or under a kitchen sink implies that a poisoning will occur. Asbestos fibers must be released from the material in which they are contained, and an individual must breathe those fibers in order to incur any chance of disease. H-2 :mea or Pecyaec Paper 2 While scientists have been unable to agree on a level of asbestos exposure at which we, as public policy makers, can confidently say, "there is na risk," this does not mean that all or any exposure is inherently dangerous. To the contrary, almost every day we are exposed to some level of asbestos fibers in buildings or in the outdoor air. Based upon available data, very few among us, given existing regulatory controls, have contracted or will ever contract an asbestos-related disease from these relatively low levels of airborne fibers found in buildings. The present scientific evidence will not allow us to state unequivocally that there is a level of exposure below which there is a zero risk, but the risk at these low levels in fact could be negligible or even zero. The risks of asbestos disease can be higher from exposures that occur during mining, manufacturing, and use of some remaining asbestos products, for example, in the repair of automotive brakes. FACT TWO: Prevailing asbestos levels in buildings -- the levels that school children and you and I face as building occupants -- seem to be very low, based upon available data. Accordingly, the health risk we face as building occupants also appears to be very low. Indeed, a 1987 EPA study found that airborne fiber levels in a segment of Federal buildings with asbestos management programs were so low that the levels were in a range comparable to levels outside these buildings. While the data are not conclusive and we are seeking more information through a major research effort, the 1987 study appears to suggest that building occupants face only a minimal risk when their buildings have active asbestos management programs. Severe health problems attributed to asbestos exposure have generally been experienced by workers in industries such as shipbuilding, where they were constantly exposed to very high fiber levels in the air, often without any of the worker protections now afforded to them under the law. Of course, some building workers, if they are not properly trained and protected, may disturb asbestos-containing materials and, in so doing, increase the risk to themselves and others. FACT THREE: Removal is often not a school district's or other building owner's best course of action to reduce asbestos exposure. In fact, an improper removal can create a dangerous situation where none previously existed. r 3 It is important to understand that, for most situations, CPA's asbestos regulations for schools under the Asbestos Hazard Emergency Response Act (AHERA) do not require removal of asbestos. These regulations allow the school to decide whether asbestos removal, or some other response action, is the best option to protect the health of school students and employees. In general, asbestos removal is most appropriate when asbestos materials, such as pipe or boiler insulation, are damaged beyond repair. Although we believe most asbestos removals are being conducted properly, asbestos removal practices by their very nature disturb the material and significantly elevate airborne fiber levels. Unless all safeguards are properly applied and strictly followed, exposure in the building can rise, perhaps to levels where we know disease can occur. Consequently, an illconceived or poorly conducted removal project can actually increase rather than eliminate risk. FACT FOUR: EPA only requires asbestos removal in order to prevent significant public exposure to asbestos, such as during building renovation or demolition. Prior to a major renovation or demolition, asbestos material that is likely to be disturbed or damaged to the extent that significant amounts of asbestos would be released must be removed using approved practices under EPA's asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP) regulation. Demolishing a building containing large amounts of asbestos, for example, would likely result in significantly increased exposure and could create an imminent hazard. Clearly, asbestos removal before the wrecking ball swings into action is appropriate to protect public health. However, this cannot be said of arbitrary asbestos removal projects, which, as noted above, can actually increase health risk unless properly performed. This, in part, is why EPA has not mandated asbestos removal from schools or other buildings beyond the NESHAP requirement, which has the effect of gradually and rationally taking all remaining asbestos building materials out of the inventory. FACT FIVE: EPA does recommend in-place management whenever asbestos is discovered. Instead of removal, a conscientious in-place management program will usually control fiber releases, particularly when the materials are not significantly damaged and are not likely to be disturbed. That is why Congress mandated such a program in schools through AHERA. H-3 4 In-place management, of course, does not mean "do nothing." It means, first, that the building owner or manager should identify asbestos. through a building-wide inventory or on a case-by-case basis before suspect materials are disturbed by renovations or other actions. The AHERA program requires an inventory of all asbestos materials in schools by properly accredited individuals. After the material is identified, the school's personnel, building owner or manager can then institute controls to ensure that the day-to-day management of the building is carried out in a manner that prevents or minimizes the release of asbestos fibers into the air. These controls will ensure that when asbestos fibers are released, either accidentally or intentionally, proper management and cleanup procedures are implemented. Another concern of EPA and other Federal, State and local agencies which regulate asbestos is to ensure proper worker training and protection. Maintenance and service workers in buildings, in the course of their daily activities, may disturb materials and can thereby elevate asbestos fiber levels, especially for themselves, if they are not properly trained and protected. For these persons, risk may be significantly higher than for other building occupants. Proper worker training and protection, as part of an active in-place management program, can reduce any unnecessary asbestos exposure for these workers and others. AHERA requires this training for school employees whose job activities may result in asbestos disturbances. In addition to the steps outlined above, an in-place management program will usually include notification to workers and occupants of the existence of asbestos in their building, periodic surveillance of the material, and proper recordkeeping. EPA requires all of these activities for schools and strongly recommends that other building owners also establish comprehensive asbestos management programs. Without such programs, asbestos materials could be damaged or deteriorate, which may result in elevated levels of airborne asbestos fibers. While the management costs of all the above activities will depend upon the amount, condition, and location of the materials, such a program need not be expensive. In many instances, an inplace management program may be all that is necessary to control the release of asbestos fibers, until the asbestos-containing material in a building is scheduled for removal because of renovation or demolition activities. H-5 i 5 In summary, EPA's best advice on asbestos is neither to rip it all out in a panic nor to ignore the problem under the false presumption that asbestos is "risk free." Rather, we recommend a practical approach that protects public health by emphasizing that asbestos material in buildings should be located, that it should be appropriately managed, and that those workers who may disturb it should be properly trained and protected. That has been, and continues to be, EPA's position. If you have questions or need additional information about asbestos in schools and other buildings, please call EPA's Toxics Hotline at (202) 554-1404 or write the Environmental Assistance Division (TS-799), Office of Pesticides and Toxics Substances, 401 M Street, Washington, DC 20460. H-f APPENDIX I POINTS OF CONTACTS AMU NATIONAL ASBESTOS COUNCIL INC. AMU H*nONAl ASKSTOS COUNCA HC 2786 North Decolor Rood, Suite 240 Oecotur, Georgia 30033 : 1-u BULK RATE OS. POSTQE PAID Pwmtt Na 3259 Atlanta, QA I Regional Asbestos Groups CT, MA. ME, NH, Rl, VT DC, DE, MD, PA, VA.WV Regional Asbestos Coordinators 1r. James M. Bryson PA, Region I, (ATC-111) sbestos Coordinator FK Federal Bldg. oslon, MA 02203-2211 SI 7) 565-3836 -- (FTS) 835-3836 !r. Louis Bevilacqua PA, Region II. (MS-500) sbestos Coordinator 390 Woodbridge Ave. arttan Depot. Bldg. 5 dison, NJ 08837 08) 321 -6671 -- (FTS) 340-6671 s. Carole Dougherty PA, Region III. (3AT-33) sbestos Coordinator 11 Chestnut Bldg. -liladelphia, PA 19107 15) 597-3160 -- (FTS) 597-3160 Mr. Terence W. Stanuch EPA, Region V. (SP-l <J) Acting Asbestos Coordinator 77 W. Jackson Btvd. Chicaao. IL 60604 (312) 353-5590 -- (FTS) 886-5590 Mr. Steve Vargo EPA, Region VI, (6T-PT) Asbestos Coordinator 1445 Roes Avenue Dallas. TX 75202-2733 (214) 655-7244 -- (FTS) 255-7244 Mr. Wolfgang Brandner EPA, Region Vfl. (ARTX) Asbestos Coordinator 726 Minnesota Ave. Kansas City, KS 66101 (913) 551-7020 -- (FTS) 276-7020 Mr. David Combs EPA, Region VIII. (8AT-TS) Asbestos Coordinator Denver Place, Suite 500 999 - 18th Street Denver. CO 80202-2406 (303) 293-1442 -- (FTS) 330-1442 Ms. Jo Ann Semones EPA, Region IX. (A-4-4) Asbestos Coordinator 75 Hawthorne Street San Francisco, CA 94105 (415) 744-1128 -- (FTS) 484-1128 Mr. Matt Wllkening EPA, Region X, (AT-083) Asbestos Coordinator 1200 Sixth Avenue Seattle. WA 98101 (206) 553-4762 -- (FTS) 399-4762 s. Rhonda Evans 3A, Region IV sbestos Coordinator ^5 Courtland St., N.E. an;a. GA 30365 04) 347-5014 -- (FTS) 257-5014 11/27/91 AHERA State Designees ALABAMA William Waams AL Safa Stata Program Collaga of Continuing Studias Univarsity of Alabama PO Box 870388 Tuscaloosa. AL 35487-0388 Phone: (205)348-3033 ALABAMA Offica of tha Governor AL Safa Stata Program 11 South Union Straat, Room 217 Montgomery, AL 36104 Phone: (205)242-7100 ALASKA Susan Millar AK Dept of Education (Facilities) 801 West 10th Goidbelt Bldg PO Box F Juneau, AK 99811-0500 Phona: (907)465-2865 AMERICAN SAMOA Pati Faiai American Samoa EPA Offica of tha Governor Pago Pago, AS 96799 Phona: (684)633-2304 ARIZONA Yvette David Dept of Environmental Quality Offica of Air Quality PO Box 600 Phoenix. AZ 85001-0600 Phona: (602)257-2287 ARKANSAS Dan Lovelady AR Dept of Education School Plant Services Arch Ford Education Bldg #4 Capitol Mall, Room 110B Little Rock, AR 72201-1071 Phona: (501)682-4261 BUREAU OF INDIAN AFFAIRS Harman Fisher Bureau of Indian Affairs FMCC PO Box 1248 Albuquerque, NM 87103 Phone: (505)766-2454 CALIFORNIA Sandra Proctor School Facilities Program Analyst Offica of Local Assistance 501 J Street Suite 350 Sacramento, CA 95814 Phone: (916)322-0948 COLORADO Dave Ouimette CO Dept of Health Air Pollution Control Div 4210 E 11th Avenue Denver, CO 80220 Phone: (303)331-8587 CONNECTICUT William SawtckJ Environl Health Services Div CT Dept of Health Service 150 Washington Street Hartford, CT 06106-4474 Phone: (203) 566-1260 CONNECTICUT Michael Ruggles Dept of Education Plan Review Unit Cromwell Commons Bldg 136 Berlin Road, Suite 203 Cromwell, CT 06416 Phone: (203)635-1148 DELAWARE Robert Foster Dept of Administrative Services Div of Facilities Mgmt Short Bldg 21 The Green Dover, DE 19901 Phone: (302) 739-3045 DISTRICT OF COLUMBIA Edgar Kennedy Love Joy Administration Bldg 12th &DNE Washington, DC 20002 Phone: (202) 724-4706 FLORIDA Hal Thomas FL Dept of Education FI Education Center Plant Mgmt & Insurance Rm 1032, 325 West Gains Street Tallahassee, FL 32399-0400 Phone: (904)487-1130 GEORGIA Don Elam GA Dept of Education School Safety & Environl Services 1662 Twin Towers East Atlanta, GA 30334-5050 Phona: (404)656-7059 GEORGIA Don Thornhill Trans Fac & Asbestos Div GA Dept of Education 1670 Twin Towers East Atlanta. GA 30334 Phone: (404)656-2446 I-? GUAM Fred M. Castro GU Environl Protection Agency D-107 Harmon Plaza 130 Rojas Street Harmon, GU 96911 Phone: (671)646-8863 HAWAII KenHaB Clean Air Branch PO Bax 3378 Honolulu. HI 96801 Phone: (808) 586-4200 IDAHO Gary Barnes Dept of Labor & Industrial Services State House Mail Boise, ID 83720 Phone: (208)334-3896 ILLINOIS R. Kant Cook IL Dept of Public Health 525 West Jefferson Street 3rd Floor Springfield, IL 62761 Phone: (217)782-3517 MDtANA Debbie Dubenetzky Office of Air Mgmt Dept of Environl Mgmt 105 South Meridian Street Indianapolis, IN 46225 Phone: (317)232-8373 IOWA C. Milton Wilson School Plant & Facilities Unit Dept of Education Grimes State Office Bldg Des Moines. IA 50319-0146 Phone: (515)281-4743 KANSAS Gary Miller Dept of Health & Environment Forbes Field Bldg 740 Topeka, KS 66620 Phone: (913)296-1547 KENTUCKY Jim Judge KY Dept of Education Div of Bldgs & Grounds 1530 Capitol Plaza Tower 15th Floor Frankfort. KY 40601 Phone: (502)564-4326 2/92 LOUISIANA Chris Roberie Enforcement Program Manager Office of Air Quality 7290 Bluebonnet Road Baton Rouge, LA 70810 Phone: (504)765-0110 MAINE Gene Kaier Bureau of General Services Asbestos Coordinator State House Station 77 Augusta. ME 04333 Phone: (207)289-4000 MARYLAND Mardel Knight MD Dept of the Environment Industrial Operations Program 2500 Broening Hwy Baltimore, MD 21224 Phone: (410)631-3846 MASSACHUSETTS Paul Aboody Div of Occupational Hygiene MA Dept of Labor & Industry 1001 Watertown Street West Newton, MA 02165 Phone: (617)969-7177 MICHIGAN George Howard Dept of Public Health Attn: Asbestos Program 3423 North Logan Street POBox 30195 Lansing, Ml 48909 Phone: (517)335-8246 MINNESOTA Kerry Leider MN Dept of Education 563 Capitol Square Bldg 550 Cedar Street St. Paul, MN 55101 Phone: (612)296-9786 MISSISSIPPI Gerald Pevey MS State Dept of Education Bureau of Sch Bldg & Trans 501 North West Street Suite 1205 Woolfoik Bldg Jackson, MS 39201 Phone: (601)359-1028 MISSOURI Daryl W. Roberts Bureau of Environ'l Epidemiology Health Dept 1730 East Elm Street PO Box 570 Jefferson City, MO 65102 Phone: (314)751-6102 MONTANA Andrea Guthrie Dept of Health & Environ'l Science Cogswell Bldg, Room A107 Helena, MT 59620 Phone: (406)444-2690 NEBRASKA John Hall NE Dept of Health - EHHS 301 Centenial Mall South POBox 95007 Lincoln, NE 68509 Phone: (402)471-2541 NEVADA Douglas M. Stoker NV Dept of Education 1850 E Sahara Ave Suite 200 State Mail Room Las Vegas, NV 89158 Phone: (702)486-6455 NEW HAMPSHIRE Doug Brown Dept of Education State Office Park South 101 Pleasant Street Concord, NH 03301 Phone: (603)271-4609 NEW JERSEY James A. Brownlee NJ Dept of Health Environl Health Services CN 360, 210 S Broad Street Trenton, NJ 08625-0360 Phone: (609)984-2193 NEW MEXICO Dr. Ed Tangman State Dept of Education Education Bldg 300 Don Gaspar Street Santa Fe. NM 87501-2786 Phone: (505)827-6670 NEW YORK Dr. Mae Timer Bureau of Educational Mgmt Svcs NY State Education Dept Room 510 Education Bldg, West Wing Albany, NY 12234 Phone: (518)474-3911 NORTH CAROLINA John J. *Paf Curran Asbestos Hazard Mgmt Branch 441 N Harrington Raleigh, NC 27603 Phone: (919)733-0820 NORTH DAKOTA Dana Mount ND Health Dept & Consolidated Laboratories 1200 Missouri Ave, Box 5520 Bismarck, ND 58502-5520 Phone: (701)221-5188 NORTH DAKOTA Ken Wangler Dept of Public Instruction 600 E Blvd Ave Bismarck, ND 58505-0440 Phone: (701)224-2267 NORTHERN MARIANAS F. Russell Mechem, II Div of Environl Quality Dr. Torres Hospital POBox 1304 Saipan, MP 96950 Phone: ( ) OHIO Marty King OH Dept of Health 35 E Chestnut 7th Floor Columbus, OH 43266-0588 Phone: (614)466-1450 OKLAHOMA Emily Allen OK State Dept of Health Special Hazards Div Consumer Protection Service 0202 1000 NE 10th Oklahoma City, OK 73117-1299 Phone: (405)271-5221 OREGON A! Shannon OR Dept of Education 700 Pringle Parkway SE Salem, OR 97310-0290 Phone: (503)378-8142 PENNSYLVANIA Dean Van Orden Dept of Environment Resources 101 South 2nd Street PO Box 2357 Harrisburg, PA 17105 Phone: (717)787-9257 PUERTO RICO Jesus Santa Environ'l Quality Bldg 6 PO Box 11488 Hato Rey 431 Ponce De Leon Ave San Juan, PR 00910 Phone: (809)767-8071 2^92 REPUBLIC OF PALAU Executive Officer Palau Env Dual Proj Bd POBox 100 Koror, PW 96940 Phone: ( ) RHODE ISLAND Roger P. Marinelli Dept of Health Div of Occupation and Radiological Health 206 Cannon Bldg 3 Capitol Hill Providence, Rl 02908-5097 Phone: (401)277-3601 SOUTH CAROLINA G. Stuart Clarkson SC Dept of Education, School Planning & Bldg Rutledge Bldg 1429 Senate Street Columbia, SC 29210 Phone: (803) 734-8823 SOUTH DAKOTA Bob McDonald Dept of Environment & Natural Resources 319 S Coteau c/o 500 E Capital Ave Pierre, SD 57501 Phone: (605)773-3153 TENNESSEE George Brumett, Jr. Office of Special Initiatives Div of Facilities Mgmt Dept of Finance and Admin Suite 500 Nashville Ctr 511 Union Street Nashville. TN 37243-0300 Phone: (615)741-6319 TEXAS Peter M. Tadin TX Dept of Health Div of Occupational Health 1100 West 49th Street Austin, TX 78756 Phone: (512)834-6600 UTAH Joan Thalmann Dept of Environ'! Quality Div of Air Quality 1950 West North Temple Salt Lake City. UT 84114-4820 Phone: (801)536-4084 VERMONT Alayne Senior VT Dept of Health Asbestos Program 60 Main Street POBox 70 Burlington, VT 05402 Phone: (802) 863-7231 VIRGIN ISLANDS Hugh M. Smith, Jr. Dept of Education USVI 44-46 Kongens Gads, Charlotte Amelia St. Thomas, VI 00801 Phone: (809) 774-8315 VIRGIN ISLANDS Leonard Reid Dept of Planning & Natural Resources Environl Protection 458 Nisky Center Suite 231 St. Thomas, VI 00802 Phone: (809)774-1320 VIRGINIA David Boddy Dept Of Education James Monroe Bldg, 24th Floor 101 N 14th Street. PO Box 60 Richmond, VA 23216 Phone: (804)225-2035 WASHINGTON Terry Michatson Superintendent of Public Instruction Old Capitol Bldg, FG-11 Olympia. WA 98504 Phone: (206)753-6729 WEST VIRGINIA Joseph P. Schock Office of Environl Health Services Capitol Complex Bldg 3 1900 Kanawha Blvd E, Room 550 Charleston. WV 25305 Phone: (304)348-2981 WISCONSIN Gina Cowell Wl Div of Health Asbestos Unit 1414 E Washington Ave, Rm 117 Madison, Wl 53703 Phone: (608)267-2289 WYOMING Dr. Roger Hammer WY Dept of Education Hathaway Bldg, 2nd Floor 2300 Capitol Ave Cheyenne, WY 82002-0050 Phone: (307)777-6198 2/92 : *95? 2" r~S62^5-4 United States Environmental Protection Agency (TS-799) Washington. DC 20460 3S 9* c Q. 0 * | S8 BZ2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, O.C. 20460 OFFICE OF AIR AND RADIATION ASBESTOS NESHAP GUIDANCE MATERIALS The Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR 61, Subpart M, was amended on November 20, 1990 by the U.S. Environmental Protection Agency (EPA) to increase the level of compliance with the demolition and renovation provisions. In order to assist the public and regulated community to understand the requirements under the Asbestos NESHAP, a series of guidance documents were developed and are enclosed with this letter. These documents are intended for information purposes ONLY, and may not in any way be interpreted to alter or replace the coverage or requirements of Subpart M. If you have specific questions on any of these documents, please contact the Asbestos NESHAP Coordinator for your State. A list of coordinators can be found in the document entitled: Asbestos NESHAP National Contact List.