Document B8a37wkXD1jnpnLQz8L8r9R8E

o ALCOA Engineering Standard Alcoa Safety am Industrial Hygiene ASBESTOS REMOVAL STANDARD :s; lid 18.18 1990 JUNE PAGE 1 ft 1. SCOPE Oj*fS *| This standard covers the precautionary measures to follow when removing imif li asbestos-containing materials as well as legal requirements as mandated by 29 CFR 1926.58, the standard which covers all construction work, involving asbestos. The scope of this engineering standard is limited to those requirements and i}{i P i if recommendations having to do with asbestos removal. Other requirements of 29 CFR 1926.58 such as the labeling of intact asbestos insulation and the general industry requirements from 29 CFR 1910.1001 will not be discussed here. More than half of the states have laws related to asbestos. Those unique state regulations are not covered in this standard, but whenever state or local requirements are more stringent, they ii[ should be followed over the Federal regulations. fa?* ?i* fill Asbestos was used extensively in the past for insulating boilers, furnace linings, steam pipe covering, duct work, gaskets, brake linings, sound insulation, roofing, floor tiles, and for general fireproofing. Vhen materials are suspected of containing asbestos, assume that they do unless current analytical testing confirms ziU otherwise. Samples of bulk material can be analyzed by the Environmental Health Laboratory at Alcoa Technical Center. Additional discussion of sample analysis is included in Section 2.2 on sampling. For purposes of this engineering standard, materials will be classified as asbestos containing materials (ACM) if they contain greater than 0.1* asbestos. vj c5i ASBESTOS REMOVAL CHECKLIST <o SB I rjS III U\ <3! 0! S_ Mtill: isM fill '5*3 1. 2. 3. 4. 5. 6. Industrial hygienist and/or environmental engineer must be contacted prior to removal of any materials suspected of containing asbestos. Obtain current, reliable analysis of materials suspected of containing asbestos. Notification procedures consistent with Federal and local regulations must be followed. Employees involved in asbestos removal operations must have had training or certification where required within the last 12 months. Appropriate medical surveillance as well as employee fitness to wear a respirator must be addressed. Employee respirator fit tests must be current. Appropriate protective clothing must be specified and worn for each job. 7. Regulated areas, with asbestos warning signs, must be established where air concentrations could exceed the PEL. SUPERSEDES 1989-08 PLAINTIFF'S EXHIBIT AL-113 ARD 004481  o l tha m a lh o d t. processes, p ro d u c ts o r procaOu>s d a scn b a d or ra c o m m s n d a d n*an Quaianiaas or roprasantationa a a p m sso v wnpaied a ia m aoa as to in * ui>i<us o a ite c ii a n a it a n d n o i tniandad to bn a m n n f lt llo n lo t any >acpai o ih a i m a n A lc o a N o M a M a m ** > * pu*|>% o l 0>V.0^**'tt Ai.OA* li t angiuacting lia 4 ns iq* fMO**0ed a ALCOA Engineering Standard Ako Safety and Industrial Hyfilono ASBESTOS REMOVAL STANDARD 18.18 1990 JIHB PAGE 2 8. Large Asbestos Demolition/Renovation Projects must be done in negative pressure enclosures vhenever feasible. 9. Develop a written contingency plan for dealing with any asbestos release emergencies which might occur. 10. Competent persons must supervise activities within regulated areas of large scale jobs. 11. Initial personal exposure monitoring is required at the beginning of each job. 12. Daily exposure monitoring is required for large scale demolition renovation projects. 13. Vork area must receive a thorough visual inspection after the clean-up phase to insure adequate clean-up. Air monitoring may also be warranted to document safe exposure levels. 14. All waste materials including used disposable protective clothing must be properly containerized and labeled as asbestos. 15. Placard vehicles carrying asbestos waste on public roadways per D.O.T. requirements. 16. Use Alcoa Form HS-8702 Non-Hazardous Vaste Manifest except in states or municipalities where more stringent requirements are in effect. 17. All asbestos waste must be deposited in a permitted landfill with state approval for asbestos disposal. Notification of the disposal facility prior to asbestos waste shipment is recommended. All local regulations concerning asbestos waste disposal must be followed. 2. REQUIREMENTS 2.1 Notification Procedures. The plant industrial hygienist and/or environmental engineer must be contacted prior to removal of any materials suspected of containing asbestos to insure the lmplementatin of adequate health protection measures and also to arrange for required notification and proper waste disposal. Federally mandated notification rules for asbestos Demolition/Renovation work are found in the USEPA National Emission Standards for Hazardous Air Pollutants (NESHAPs) Asbestos Regulations 40 CFR 61, Subpart M. Some states, cities, and counties have notification rules in addition to the NESHAPs notification. All legally mandated notifications are to be made in conjunction with each asbestos job. pai o> used o n D a n a ii o l oih#< th a n A lu m in u m c o m p a n y o Us aubtK)<a*tas. Ol A lu m in u m Com pany o l Ame<lc and m u tt s h a ll n o i ba rpoducaa o* cop*d. In w fto ia o in ii fqwi w iih o u i pem.ss>on Itt.4i * *li'o#d on ARD 004482 a ALCOA Engineering Standard Alcoa Salaly and Industrial Hyftana it ti Mf rfl| S|5* i|ti tidilli ASBESTOS REMOVAL STANDARD 18.18 1990 JUS PAGE 3 NESHAP regulations require the ovner/operator to notify the Program Administrator before beginning any renovation or demolition involving asbestos removal. Typically, State Pollution Control Agencies have authority for EPA Clean Air Programs Including the NESHAPs Program. EP Regional office can be contacted to determine vhat agency has NESHAPs authority in your location. Notification of Scheduled Renovation/Demolition (prior to start of job) Quantity of Friable ACM Being Removed Advisory i2t |sli il i i If *1 Mr 20 < 260 ft. or < 160 ft.2 or < 35 ft.3 10 > 260 ft. or > 160 ft.2 or > 35 ft.3 If there are no standard notification forms required by local regulations, the following form, designed by Pittsburgh Environmental Control, is recommended (Attachment 1). NESHAPs require the following information as a minimum. - Company name and address, contact name and phone number. - Contractor name and address, contact name and phone number. - Location of renovation or demolition. - Scheduled starting and completion dates of renovation or demolition. - Description of facility to be renovated or demolished (including size, age, prior use, estimated of friable asbestos.) - Nature of the renovation or demolition and aethod(s) to be used. - Procedures to be used to insure compliance with Emission Standards (40 CFR 61.22d and Vaste Disposal Standards 40 CFR 61.22j). - Scheduled starting and completion dates. - Name and address of vaste disposal site. - Name, title, and authority of government agent, if demolition is a result of government order. 2.2 Sampling . This section describes sampling to be conducted during all phases of asbestos jobs from planning, through removal as well as after cleanup. Some of this sampling is required by the 0SHA Standard while other aspects of sampling are highly recommended as good practice during conduct of asbestos removal. 2.2.1 Bulk Sampling During planning phases of asbestos removal jobs, it is essential that asbestos bulk sampling be conducted to determine the extent of asbestos containing materials (ACM). Bulk sampling conducted previously is sufficient to serve this purpose if the results of that previous sampling vere conducted using methods sufficiently sensitive to detect the presence of asbestos at 0.1X and the results are considered by the location Industrial Hygienist to be reliable. Recommended test methods are polarized light microscopy (40 CFR Part 763, Appendix A, Subpart F), or other methods of equal or greater precision. Alcoa's ARD 004483 a ALCOA Engineering Standard Alcoa Safoty and Industrial Hyfl larva ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PACK 4 Environmental Health Laboratory has the capability of conducting this analysis and is involved in an N.B.S.(National Bureau of Standards) quality assurance program to maintain analytical accuracy. Arrangements can be made vith EHL to analyze rush samples by contacting them prior to sampling and by sending samples via overnight express mail. Any outside laboratory used for bulk asbestos sample analysis must use comparable analytical methods and maintain a quality assurance program. / 2.2.2 Air Monitoring - Personal Exposures Personal air samples are required by the construction standard. Appendix A, a mandatory appendix to the Asbestos Standard, describes NIOSH Method 7400 including both sampling and analytical procedures. NIOSH Method 7400 utilizes a 25 mm diameter open face cassette vith a 50 mm extension covl. Written justification must be made if another method is used. Additionally, the Asbestos Standard mandates a laboratory quality assurance program to be instituted by laboratories conducting analysis of samples required by this standard. ATC's EHL has instituted a quality assurance program to meet the specific requirements of 29 CFR 1926.58. If other laboratories are used, they must also have acceptable QA programs. I1I*1I Is? ! (j Hi is e -I* i!f ?il ISIgIS!? I*!J iii All personal air samples are required to be taken in the employees breathing zone. For comparison vith the PEL and action level, sufficient samples should be taken to be representative of each employee's 8-hour (full shift) exposure. Personal Exposure Sampling Minimum Sample Volume Action Level 0.1 f/cc Permissible Exposure Level 0.2 f/cc Short Term Exposure Limit 1 f/cc 190 minutes 380 liters 90 minutes 180 liters 20 minutes 40 liters (vith 25 mm filter) Reference IH Technical Bulletin 89-03 Effected employees, or their designated representatives, have the right under the 0SHA regulation to observe any monitoring of employee exposure to asbestos. Written results of personal asbestos monitoring are required to be made available to effected employees vithin 15 days of the receipt of such results. Just as vith all personal sampling results, 0SHA Record Retention Requirements, 29 CFR 1910.20, mandate that they be kept for the duration of the individual's employment plus 30 years. Initial monitoring is required at the beginning of each asbestos job to determine the asbestos concentrations to vhich employees will be exposed. Exceptions to this requirement are when there is objective data to indicate that the ACM cannot release fibers in concentrations exceeding the action level or vhen there is historical data for closely resembling conditions. ARD 004484 0 ALCOA Standard Alcoa Safety anc Industrial Hyqlana ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PAGE 5 111! fl! e3 e8 aa .5 *s Is s PiS8 Daily monitoring is required for large scale demolition renovation projects. Large scale demolition renovation projects are defined by examples under Section 2.6 Work Practices. The definition of large scale demolition renovation projects pre-supposes that the employee exposures vill exceed the action level of 0.1 fibers per cubic centimeter of air (0.1 f/cc). There must be sufficient samples to represent exposures of each employee assigned to vork in the . .regulated vork area. Regulated vork areas are also explained further in Section 26 2.2.3 Air Sampling - Area Sampling Vhile area sampling is not required by the asbestos regulations, it may be prudent in some circumstances. Area sampling is recommended in the non-mandatory Appendix E of the OSHA Construction Standard for Asbestos for large scale asbestos removal projects vhich utilize negative air pressure enclosures. Area samples are recommended in the vork area, in the clean change room at the periphery of the restricted area, and in the area of the portable ventilation unit exhaust. Additional area samples are recommended in the asbestos removal area folloving cleanup. The enclosure should not be dismantled unless final clearance samples are belov the OSHA action level of 0.1 f/cc. EPA reconmends that these clearance samples be less than 0.01 f/cc for schools. Areas such as offices, lunchrooms, and control rooms should meet the EPA's recommended "clearance level" of 0.01 f/cc. Clearance sampling for the purpose of determining the adequacy of cleanup is done after surfaces in the vork area have been alloved to dry thoroughly. Use of forced air equipment is sometimes used to conduct aggressive sampling in order to dislodge any stray fibers from surfaces and thereby represent vorst case conditions. Minimum Sample Times for Area Samples Clearance Level Minimum Sample Volume 0* I** 55 0-? .?g*|!8is5s ill! .3li 1 y-J Sil 0.1 f/cc 120 1 0.01 f/cc 270 1 (540 1 is preferable) 2.3 Employee Training Training shall be provided annually to all employees involved in asbestos removal operations. All Alcoa employees and outside contractors exposed to asbestos > 0.1 f/cc must have completed required training at some time vithin a 12 month period prior to assignment to any asbestos job. If asbestos vork occurs infrequently during the year, JSAs and/or training materials should be available to employees for their reviev prior to the job. The plant industrial hygienist can offer assistance in employee training programs. Attendance at these training sessions should be documented. OSHA requires that records of asbestos training be kept for a period of one year. This should be considered a minimum requirement. The training program should include the folloving: ARD 004485 a ALCOA Engineering Standard Alcoa Safely and Industrial Hygiene ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PAGE 6 (a) Recognition of asbestos. (b) Health effects associated vith asbestos exposures including the relationship betveen asbestos and smoking. (c) Nature of job which could result in exposure. (d) Protective measures including engineering controls, work practices, housekeeping, and personal protective equipment used to reduce potential exposures. (e) Respirator fitting and use. (f) Medical surveillance requirements. Some states have adopted additional regulations requiring standardized training and licensing of asbestos removal contractors. In locations vhere this additional requirement is in effect, appropriate licenses and certifications must be obtained. 2.4 Medical Surveillance. Employees wearing negative pressure respirators and employees exposed at or above the action level of 0.1 f/cc for 30 or more days a year are required to be in a medical surveillance program as outlined in 29 CFR 1926.58. Vs For Alcoa employees, this periodic evaluation will be conducted according to Alcoa Medical Protocol B7, Occupational Medical Evaluation, Asbestos. Medical records made in accordance with the OSHA Asbestos Standard are subject to record keeping requirements as set forth in 29 CFR 1910.20. Medical records are required to be maintained for the duration of employment plus 30 years. Is 5 ESi 2.5 Personal Protective Equipment. 2.5.1 Respirators. Respiratory protection used for employees involved in asbestos jobs must be used in accordance with Alcoa Engineering Standard 18.1.1 as well as OSHA regulations (29 CFR 1910.134 (b), (d), (e), and (f). This engineering standard describes minimal requirements of a Respiratory Protection Program including medical evaluation of respirator users, training, and fit testing. Pit testing under the Construction Standard is required prior to the initial Job assignment and every six months thereafter. All respirator fit testing done in conjunction with this standard must be carried out according to the provisions of Appendix C to the OSHA asbestos standard for construction, which is mandatory. f|I, 1**1 hii ;e 4 2 5j i !rf 2 a! The plant industrial hygienist can assist in the selection of appropriate respiratory protection. OSHA does not allow single use disposable respirators to be used to meet respiratory protection requirements of the asbestos standard. The selection of appropriate respiratory protection depends upon the concentration of asbestos in the work environment. An additional consideration in respirator selection is that the OSHA standard gives employees a choice of using a powered air purifying respirator (PAPR) rather than a negative pressure regulator so long as the PAPR provides adequate protection. Although OSHA would not require respiratory protection for employees exposed to less than the PEL, it is a good practice to use respiratory protection in any work situation where accidental exposure might occur due to some event such as rupturing of a glove bag or breakage of an asbestos waste container. ARD 004486 a ALCOA Engineering Standard Alcoa Safety ar Induttfia Hy^iana ASBESTOS REMOVAL STANDARD <Sic Ilf ?}if un * Si K oi!l i*tS *U\ 5Sl fiH If I8f5 iMf!i SS i Hi Ml Exposure Level (X) PEL = 0.2 f/cc Respirator Type X < 10 (PEL) 1/2 mask HEPA 10 (PEL) < X < 50 (PEL) 50 (PEL) < X < 100 (PEL) Pull facepiece HEPA PAPR HEPA 1/2 mask supplied air (positive pressure mode) 100 (PEL) < X < 1000 (PEL) Full face supplied air (positive pressure mode) X > 1000 (PEL) Full face supplied air with auxiliary SCBA HEPA - High efficiency particulate absolute SCBA - Self contained breathing apparatus 18.18 1990 JINB PAGE 7 t5j >n |s-: Iff s| .! Hill | f II5 s8? Ilii -Isj s-i ni Reusable respirators should be thoroughly washed to remove any asbestos contamination prior to sanitization and storage (refer to Engineering Standard 18.1.1). 2.5.2 Clothing Appropriate work clothing is required to be provided to employees vhen they are exposed to asbestos above the PEL and when the possibility of eye irritation exists. The purpose of special clothing for asbestos jobs is to prevent the contamination of street clothing that vill be worn home by the employee. The type of work clothing which is necessary depends on the type of work that will be done. For large removal operations, vhere there is a greater possibility of contamination, employees vill need whole body coverings including: Coveralls or Vork Clothes - These can be either disposable garments or reusable garments which are dedicated to asbestos vork. Footwear - Molded rubber boots with safety toes can be washed or viped clean of asbestos contamination following the job. Disposable rubber shoe coverings can be used to protect vork shoes from contamination and they are available in styles of sufficient durability to withstand use in the work environment. Tyvek shoe covers would only be adequate under the most controlled conditions and they do present a greater slipping hazard than rubber shoe coverings. Pant legs should be worn outside any boots or shoe coverings and taped to them around the ankles. ARD 004487 a ALCOA Engineering Standard Alcoa Safety and Industrial Mygfena Ilf Jtil j*!i S|3* *hl -!1SS ;9f Hi [s; iiSifjl r5S ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PACK 8 Work Gloves - Work gloves to be used should be selected on the basis of hand protection required. Inexpensive cotton vork gloves are a good choice because they can be laundered during the job and disposed of at the job's completion. Sleeves of coveralls should be brought dovn over gloves and taped at the vrists. Head Coverings - Disposable head coverings are recommended vhen jobs involve removal of overhead asbestos or are excessively dusty. Tyvek hoods are available attached to disposable coveralls or as a separate garment. HP o! III! Eye Protection - Safety glasses, faceshields, vented goggles, or other appropriate eye protection must comply vith the provisions of 29 CFR 1910.133. Respiratory Protection - Refer to Section 2.5 Small aspestos jobs such as removal of pipe insulation in a glove bag or removal of an entire asbestos covered pipe or structure also requires some protective clothing. Due to the nature of these jobs, appropriate protective clothing may not need to be as extensive as that required for large scale asbestos jobs. s Coveralls - Even though exposures during these small jobs should not exceed the I 8 PEL, disposal coveralls are recommended as a precaution against !l! contaminating vork clothing vith asbestos fibers. !:: Gloves - Disposable vork gloves may be necessary for some small scale asbestos jobs depending on the need for hand protection from sharp or abrasive objects. Shoe Coverings - The need for protecting vork shoes from asbestos contamination vill depend on the nature of the job. If there is a risk of contamination, disposable shoe coverings or deanable vork boots are recommended. Eye Protection - Facility requirements for eye protection must be met. Respiratory Protection - Half mask, negative pressure respirators should be used during glove bag jobs. 2.5.3 Disposal of Personal Protective Equipment. Before leaving the vork area, specific procedures should be folloved for removal of protective garments so as not to contaminate the employee or the surrounding areas. Section 2.7 of this standard discusses personal hygiene practices and hygiene facilities in more detail. All disposal protective equipment (garments, gloves, etc.) is to be treated as asbestos-containing material and disposed of accordingly. (See Section 2.8). ARD 004488 a ALCOA Engineering Standard Alcoa Safety and Industrial Hyglena ASBESTOS REMOVAL STANDARD 18.18 1990 Jlfffi PAGE 9 2.6 Work Practice and Engineering Controls. Work practices and engineering controls should be used to achieve compliance vith the PEL of 0.2 f/cc. 2.6.1 Restricted Areas. OSHA regulations require the establishment of regulated areas whenever concentrations of airborne asbestos exceed or could reasonably be expected to exceed the PEL. The regulated area is meant to keep the number of employees in the work area to a minimum, to restrict access to authorized persons vho are properly trained and outfitted in adequate personal protective equipment as veil as to protect persons outside the work area from I is exposure to asbestos. Varning signs are required to be posted around the perimeter of the regulated area so that employees have the opportunity to read them and take appropriate measures before entering the work area. Unless local regulations require more stringent measures, signs must conform to OSHA Regulation 29 CFR 1926.58 (k)(l), and read as follows: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA 2.6.2 Large Asbestos Demolition/Renovatlon Projects. All requirements in 29 CFR 1926.58 (g) (1) apply to asbestos removal, renovation, and demolition projects. Exceptions to these requirements are made in the case of small scale short duration operations which are discussed in Section 2.6.3 of this standard. Engineering and work practice requirements for large scale asbestos demolition/renovation projects include the following: (a) Negative pressure enclosures must be constructed in the regulated area whenever feasible. Feasibility is not determined by cost, rather it relates to factors such as space limitations or greater hazards. It is recommended that this enclosure comply vith guidelines in the Appendix F to the Asbestos Construction Standard. This non-mandatory Appendix is entitled "Work Practices and Engineering Controls for Major Asbestos Removal, Renovation, and Demolition Operations". Enclosures may be temporary structures lined vith a double layer of 6 mil flame retardant polyethylene sealing all of the seams and penetrations through the plastic sheeting. A single means of access and egress should be provided with all other doors sealed. This doorway should be covered vith a double flap of ARD 004489 a ALCOA Engineering Standard Alcoa Safety and Industrial Hygiene ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PAGE 10 };t! }y* 5 J*5? ?f st ;"<i-n:5 -*?35*1j Mis iff* l?Ss iifl 1 Hi I? J5 Iff| iS.-i s! I; Flf*ssili lift till idi plastic sheeting to separate the work area from the hygiene facility which will be discussed further in Section 2.7. Ventilation is to be provided using a number of HEPA filter units sufficient to achieve three to four air changes per hour in the enclosure. OSHA also recommends a pressure of -0.02 inches of water within the enclosure. By definition, HEPA filters must be capable of removing 99.97X of the asbestos particles from the air. HEPA units are to be operated 24 hours a day during the entire project. Exhaust air must be adequately filtered for asbestos removal and should go, if possible, to the outside of the building where the asbestos project is being conducted. (b) Competent persons must supervise activities vithin regulated areas, including setting up negative pressure enclosures and ensuring its integrity, ensuring that engineering controls are functioning, controlling access to the regulated area, ensuring that employees entering regulated areas are properly outfitted vith PPE, ensuring that employees are adequately trained, sampling exposures, inspecting employees work clothing for rips and tears, ensuring that employees follov decontamination procedures. Responsibilities of competent persons are described in 29 CFR 1916.58 (b),(e) (ii) (A)-(H), and (e) (6) (iii). 5s? ESj ?s ;* iI?ss? 0& s#f n ill {3 Ii\ -0sl5. m Ia:". if! t?S* * s6 ? -:?5s rlsl (c) Only authorized persons are to be allowed within the restricted area. All such persons must comply vith training requirements (Section 2.2), medical surveillance requirements (Section 2.4), and the personal protection requirements including respiratory protection (Section 2.5). 2.6.3 Small-Scale Short Duration Asbestos Jobs. Engineering controls and safe work practices are required to be used to control exposures during small scale asbestos jobs to levels below the action level of 0.1 f/cc. OSHA does not require negative pressure enclosures, supervision by a "competent person" or decontamination facilities for small-scale, short duration tasks. Examples of such tasks include pipe repair, valve replacement, installing electrical conduits, installing or removing dryvall, roofing, and other general building maintenance or renovation involving only limited exposure to asbestos. Any asbestos removal which can be accomplished in a glove bag is considered to be a small-scale job. Controls and work practices which can be used to control exposures during small-scale jobs Include: (a) Vet methods - Amended water or removal encapsulants. (b) Removal methods such as carefully cutting asbestos from pipes or other surfaces. (c) Glove bags. (d) Removal of entire asbestos insulated pipe or structure. (e) Hini-enclosures. ARD 004490 a ALCOA Engineering Standard Alcoa Salaty and Industrial Hyglana ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PAGE 11 Sml 9 E88 s ss gl i m is j sii 2.6.4 Dust Suppression Techniques. Wherever feasible, vet removal methods are required to be utilized. In a very limited number of situations vet removal is not feasible such as: 1. Situations vhere electrical hazards exist such as removal of asbestos from a "live" electrical box. 2. Removing asbestos insulation from a live steam pipe. Where it is not possible to disconnect electricity or to turnoff the steam, asbestos material can be removed in a dry state. Prior to removal, asbestos material should be sprayed vith vater containing a vetting agent to enhance penetration. Airless sprayers are recommended for application of vetting agents. The vetting agent should consist of SOX polyoxyethylene ester and 50X polyoxyethylene ether in a concentration of one ounce in five gallons of vater. The material should be kept vet during all stages of vork to minimize exposure to employees and emissions to outside air. Vater should not be used if this vould introduce other hazards (i.e., electrical, generation of toxic gases, etc.). 2.6.5 Work Practices. Written asbestos removal plan is recommended for large scale asbestos renovation/demolition vork in Appendix F. Such a plan vill describe the vork practices as veil as control methods. Such a plan vould have information that is also required to be reported as part of the NESHAPS requirements <40 CFR 61, Subpart M). Asbestos material should be removed in small sections and handled very carefully. While still vet, the pieces of material should be carried and lovered to ground level rather than dropped, and then placed into appropriate vaste containers. Section 2.8 has more information on vaste disposal. If the vork is regulated under U.S. EPA Clean Air Act regulations, and vater cannot practically be used for dust control, a dust collection/exhaust system is required. Such a dust control system may be necessary even if not mandated by regulation, depending on the specifics of the job, and potential for airborne emissions and employee exposure. 2.6.6 Housekeeping and Clean-Up. (a) All surfaces in the vork area must be cleaned using vacuum cleaners equipped vith HEPA exhaust. (b) All vaste materials should be placed promptly into labeled containers to reduce asbestos dust hazard in the vork area. ARD 004491 a ALCOA Engineering Standard Alcoa Salaly and Induttrtal Hyylana ASBESTOS REMOVAL STANDARD 18.18 1990 JIHB PAGE 12 (c) When asbestos removal job is complete, all surfaces should be cleaned vith a HEPA-filtered vacuum or vith damp rags. Do not dry sveep asbestos materials, as this will create airborne dust. The asbestos vork area must receive a thorough visual inspection after the clean-up phase to insure adequate clean-up. Industrial hygiene monitoring may also be warranted to document safe exposure levels. The EPA recommends that a "clearance level" of 0.01 f/cc be achieved for schools. Clean-up in areas vhich vill be reoccupied by people for more than eight hours a day such as offices, lunchrooms, and control rooms should meet the EPA "clearance level". All plastic sheeting, cleaning materials, clothing, and all other disposable items used in the vork area shall be packed into vater impermeable containers and properly disposed of as described in Section 2.8. l?!l 2.6.7 Prohibitions. The folloving vork practices are specifically prohibited during asbestos jobs. (a) Employee rotation is not considered by OSHA to be an acceptable vay to reduce employee exposures to asbestos. (b) High speed abrasive disk savs are not permitted to be used for asbestos vork unless they are equipped vith HEPA exhaust. (c) Compressed air is not permitted to be used to remove asbestos unless it is used in conjunction vith an enclosed ventilation system. 2.6.8 Contingency Plans. Written asbestos emergency plans are recommended for dealing vith asbestos release emergencies and for unexpectedly encountering ACM during jobs, CERCLA RQ 1 lb. (0.454 kg.) 2.7 Personal Hygiene Practices and Hygiene Facilities. I1 o ?Ms !sM IlH m 11 i 2.7.1 Smoking and eating are not permitted in the vork area. Employees should thoroughly vash their hands, faces, and arms before smoking or eating during breaks and upon job completion. Lunchrooms vith airborne concentrations less than the action level must be available to employees vorking in regulated areas. 2.7.2 Decontamination Facilities. Use of decontamination facilities for employees in jobs vhere they are exposed to concentrations of asbestos greater than the PEL is mandatory. These facilities are comprised of a clean room, a shower room, and an equipment room which is directly connected to the work area. The design of these hygiene facilities is described in non-mandatory Appendix P to the Construction Standard. ARD 004492 0 ALCOA Engineering Standard Alcoa Safety and Induitrlal Hygiene ASBESTOS REMOVAL STANDARD 18.18 1990 JUNK PAGE 13 assy :i * (a) Equipment Room - The equipment room, also known as the dirty room, is the area connected directly to the vork area with a double flap type doorway. This is the area in which the workers remove contaminated work clothing before proceeding to the shower room. It also serves as an equipment storage area. Asbestos waste containers may also be decontaminated and moved out of the work area via the equipment room. Separated from the equipment room by a double flap is the shower room. (b) Shower Room - Shower facilities should be contiguous vith both the equipment room and the clean room. All workers leaving the work area are required to shower. Showers can also be used to clean contaminated equipment and materials such as respirators and work boots which are being taken out of the restricted area for further sanitization. Shower facilities could also be used to decontaminate the outside of asbestos waste containers. Separated from the shower room by a double flap is the clean room. The subject of contaminated shower water is addressed in Section 2.8.4. (c) Clean Room - Clean rooms or change rooms should provide for storage of workers' street clothes and personal belongings. They should also be equipped with towels (disposable towels are available) and Clean PPE needed for the job. Vhen it is not feasible to construct decontamination facilities adjoining the worksite because of space limitations or the lack of water, the Construction Standard allows for some alternative procedures to prevent spread of asbestos contamination between the job site and remote shower facilities. (a) HEPA vacuum protective clothing at the worksite, then proceed to showers or (b) Change into new disposable suits at the worksite before proceeding to the showers. (c) Exposed skin areas should be wiped clean vith vet toweling or premoistened tovelettes. 2.7.3 Exceptions. Small scale asbestos jobs do not require the use of decontamination facilities, however, practices must be adopted to prevent spread of asbestos away from the job site. HEPA vacuuming disposable clothing is strongly recommended as such a practice. Following this, disposable clothing can be removed and properly discarded vith other asbestos waste. 2.7.4 Laundering. Reusable asbestos vork clothing or other personal protective equipment (PPE) should be stored in containers labeled vith asbestos warning labels. Any person who launders or cleans contaminated PPE or vork clothing is required to be informed of the potential harmful effects of asbestos and protective measures that should be taken. Contaminated vork clothing should not be shaken or handled in a way that is likely to create airborne fibers. ARD 004493 0 ALCOA Engineering Standard Alcoa Safety and Industrial Hyglena -5 m mi Hi! m *** S =1 HI! !ii if Hi till mhit ;-i* "Si! ASBESTOS REMOVAL STANDARD 18.18 1990 Jlfffi PAGE 14 2.8 Vaste Disposal. Federal regulations which deal with asbestos waste are contained in the NESHAPS (40 CFR 61, Subpart M 61.145 - 61.147). As part of the notification procedure described in Section 2.1, generators of asbestos waste from renovation/demolition projects are asked to describe the Method of containing asbestos waste as well as the name of the waste site to which waste will be taken for disposal. 2.8.1 Containers To reduce generation of airborne fibers, asbestos waste should be placed into disposal containers while wet. The type of container which is appropriate for asbestos waste is dependent upon the type of waste. All asbestos waste containers shall be free of asbestos dust before leaving the restricted area. OSHA regulations require that asbestos waste containers be labeled with the following: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD (a) Recommended containers are 6 mil thick polyethylene bags. (b) Asbestos waste containing metal or other sharp objects should be packaged in sturdier waste containers such as metal drums, fiber drums, or poly-lined plywood boxes. (c) Pipes and equipment insulated with asbestos being removed in large sections can be wrapped in 6 oil plastic to create leak-tight containers. HI 2.8.2 Transportation. In the United States, containers should be transported with proper D.O.T. shipping documents and identification. Shipping Name: Vaste Asbestos RQ ORM-C. Pittsburgh Environmental Control recommends the use of Form HS-8702 Non-hazardous Vaste Manifest except in states or municipalities where asbestos has been designated as a hazardous waste and manifests are required. There are no Federal regulations concerning the type of vehicles which should be used to transport asbestos waste, however, some state regulations specify that asbestos waste be transported in closed vehicles. As a minimum, the load must be well secured and transported in such a way to prevent damage to containers during transport. 2.8.3 Landfills. Vaste asbestos is a "non-hazardous" solid waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA). All asbestos waste must be deposited in a permitted landfill with state approval for asbestos disposal. ARD 004494 0 ALCOA Engineering Standard Alcoa Valaty and Induatrtal Hyglana ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PAGE 15 (a) Before using a landfill for asbestos disposal, it is recommended that the site be visited and investigated to confirm that it is permitted, operating in accordance vith Part 61.25 of the Clean Air Act regulations, and is being operated by reputable management. (b) Notification of the disposal facility prior to asbestos vaste shipment is recommended. (c) To minimize air emissions during disposal, the EPA recommends that the landfill designate a special area for asbestos vaste vhich is separate and preferably isolated from other activities. It is also recommended that asbestos vaste be deposited in trenches or at the "toe" of the slope and covered vithin 24 hours of disposal vith at least six inches of material. Asbestos vastes should be compacted only after being covered. 2.8.4 Other Vaste. Contaminated vater from asbestos renovation demolition jobs may be regulated in some locations. It is recommended that asbestos levels in 3 any vater discharged from an asbestos renovation or demolition site be controlled to less than EPA's recommended Maximum Contaminant Level (HCL) of 7.1 million fibers per liter in drinking vater. The generally recommended disposal procedure is to filter the contaminated vater through a tvo stage disposable cartridge type filtering system (20 micron filter folloved by a 5 micron filter). 3. OOTSHg CONTRACTORS All asbestos contracts for Alcoa facilities vill be vritten by Pittsburgh Procurement in close cooperation vith field procurement offices. Outside contractors shall be required to follov the provisions of this standard, as veil as all Federal, state, ft 9 I Hi and local regulations vhere applicable for the removal of asbestos-containing materials. 3.1 Contractor Requirements (a) The Construction Standard for Asbestos also requires that contractors/employers inform other employers on the vorksite of the nature of asbestos vork and the requirements pertaining to regulated areas. (b) Other Hazard Communication issues relevant to contractors vorking in Alcoa facilities are covered in Engineering Standard 33.052.4 "Application of the OSHA Hazard Communication Standard for Outside Contractors". (c) The contractor must supply Alcoa vith copies of all documents (notifications, air monitoring results, landfill approvals, etc.) generated by the contractor in accordance vith regulatory requirements. (d) It is recommended that the contractor afford Alcoa the opportunity to reviev the landfill to be used for disposal of the material. ARD 004495 0 ALCOA Engineering Standard Alcoa Safety and Industrial Hygiene ASBESTOS REMOVAL STANDARD 2*c 18.18 1990 JUNE PAGE 16 J}i* !*!f r*i ill* I!Ii -i!!sssl -MI i!ss -,!C:i.s3 Iffl:f-! ftUl IM Imfff! llil ii M (e) Some local asbestos regulations require third party oversight of contracted asbestos removal vork. While asbestos contractors are responsible for conducting asbestos removal in compliance with all applicable regulations, Alcoa location Industrial Hygienist should be given the opportunity to evaluate asbestos control during removal vork as deemed necessary by their professional judgement. 4. REFERBICKS For further information, you may find the following references helpful: 1. Bureau of National Affairs 49 BSP-57, "BNA Special Report, Asbestos Abatement: Risks and Responsibilities", 1987. (800)372-1033 2. EPA Report Number 530-SV-85-007 "Asbestos Waste Management Guidance: Generation, Transport, Disposal", 1985 May. 3. EPA Report Number 560/5-85-024, "Guidance for Controlling Asbestos-Containing Materials in Buildings", 1985 June. EPA publications are available by contacting EPA at following toll free number: (800)424-9065. 4. I.H. Technical Bulletin No. 86-4. Available through Pittsburgh Safety and Industrial Hygiene Division. I 5j 5. 0SHA Safety & Health Standard 29 CFR 1926.58 - Asbestos for the Construction Industry. 6. U.S. EPA Regulations for Asbestos (CFR Title 40, Part 61, Subparts M.) The following references are not an endorsement of vendors, but may be of assistance: 1. Vacuum Cleaners -- m Euroclean 0 1186 Stratfield Road Fairfield, CT 06432 (203)336-5432 Hako Minuteman, Inc. Ill South Route 53 Addison, IL 60101 (312)627-6900 Nilfisk of America, Inc. 300 Technology Drive Malvern, PA 19355 (215)647-6420 ARD 004496 H ALCOA Engineering Standard Alcoa Safety and Industrial Hygiene o l ih o m a lh o d * P c m i m p m d u c is o r fw ocaoura* d n c r iM d o (c o m m tm M d h * a m Q uaiam aat o n p n tn W io n t. aapmaa o m piii*d am m ada to m o u M iiia i o a iia cin a n a a i*x o n n s n t*i o r* g At, cos -ftctosm if~ *i nr *d lf itftoofn iio in ot ip p rt ioi ilia r~r n solelyV < (* o k m o r l ltA itm angina* vigi fli ASBESTOS REMOVAL STANDARD 18.18 1990 JUNE PAGE 17 2. Dust Collection/Exhaust System -- Abatement Technologies 3305 Breckenridge Blvd. Suite 118 Duluth, GA 30136 <404)925-2761 Asbestos Control Technology, Inc. P.0. Box 183 North Pine Avenue Maple Shade, NJ 08052 (609)779-1300 (Micro-Trap Asbestos Filtration System 2 models available. Capacity 600 - 1,700 CFM) Global Consumer 1721 N. Highland Los Angeles, CA 90028 (312)426-6980 GPAC Inc. (Ovns patent for negative pressure enclosures) P.0. Box 662 Maple Shade, NJ 08052 (609) 486-1555 Sentry Equipment 2676 Sunset Lane Allison Park, PA 15101 (800)255-3362 (outside PA) 3. Vetting Agents -- Aquatrols Corporation of America Pennsauken, NJ BVE/Better Working Environment 380 Stevens Road, Suite 206 Solana Beach, CA 92075 1(800)654-6792 (Asbestos removal encapsulant BVE 5000 recommended for amosite) EPA recommended vetting agent: SOX polyoxyethylene ester, 501 polyoxyethylene ether Ethylene glycol is the vetting agent recommended for amosite asbestos. Liquid dishvashing detergents such a liquid Joy make effective and economical vetting agents. Rohm & Haas V. Philadelphia, PA ARD 004497 int w ftota o* in ftu O ftA jia iie ft. ahaN n o t M MfMOduCdd o> coptad.l i pihr inad A lum inum com pany o* ftu n d *> 0 i* ih * p to p w ly o4 A lu m in u m C om pany o l A m * tea and m u fti it ol <aquasi J**^*'* in o u i pm m isfton on* t iu<n#d P* V 0 ALCOA Engineering Standard Alcoa Safaty and Industrial Hyflana ASBESTOS REMOVAL STANDARD m hn 18.18 1990 JUNE PAGE 18 8*| fill 4. HI! ifil III IP?!: if Is 1 !i ills rill 1-I 5. Disposable Protective Garments -- Dupont Type 14 "Tyvek"; available through area distributors. Kimberly Clark Corp. 1400 Holcomb Bridge Road Rosvell, GA 30076 (404)587-8114 (Disposable coveralls, hoods, towels and vipers) MSA P.0. Box 426 Pittsburgh, PA 15230 (412)273-5000 (Protective clothing, gloves and headwear) Decontamination Units -- Aerospace America, Inc. 900 Truman Parkvay Bay City, MI 48706 (517)684-2121 (Shovers and vater filtration) Creative Innovations P.0. Box 3257 Vest Chester, PA 19381 (215)696-4952 (Decon Chamber, Spot Shot Shover, and Vater Filtration) Evergreen Safety Systems, Inc. 14045 V. 66th Ave. P.0. Box 1207 Arvada, CO 80001 (303)422-2185 (Portable decontamination units) Personal Protection, Inc. P.0. Box 737 Crystal Lake, IL 60014 (312)658-2321 (Contaminent and decontaminatin systems) Pezanni & Reid Equipment Co. 3960 Vest Ford Street si. Detroit, MI 48216 (313)554-4000 (Decontamination trailers) ARD 004498