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INDUSTRIAL HYGIENE DIRECTIVE July 27, 1988 ASBESTOS DEMOLITION AND REMOVAL It is the policy of Reynolds Metals Company that all employee exposures to asbestos be kept as low as possible. Consequently, where feasible, all asbestos demolition/removal work should be performed by qualified outside contractors. A list of qualified contractors and a Performance Audit Form are enclosed. The Performance Audit Form should be returned to the attention of R. E. Benton, Industrial Hygiene, upon the completion of each job. For small-scale asbestos demolition/removal jobs, where time is critical and a contractor cannot be obtained, properly trained RMC employees may perform the asbestos demolition/removal work. These employees, however, must be thoroughly trained on proper work practices for handling asbestos. (See Appendix A.) Part of the training program should include videotapes which are available from Corporate Industrial Hygiene. Employees must also be advised about the types of asbestos present and their potential health effects. At least one supervisor should attend an asbestos training course, if the plant anticipates using Reynolds' employees for any asbestos demolition/removal work. Training courses are sponsored by the Environmental Protection Agency (EPA) Asbestos Training Centers and other groups. (See enclosed list of training centers in Appendix B.) The supervisor who attends the course would then be responsible for training all affected plant personnel, to ensure that proper work practices are used during all asbestos demolition/ removal jobs. Air sampling is also required on all asbestos demolition/ removal jobs, to assure the effectiveness of the controls and work practices. This requirement may necessitate the purchase of air sampling equipment. (See Appendix C.) Should the plant wish to purchase equipment, please contact Ron Benton (Ext. 2265) or me (Ext. 3506), regarding the type of equipment recommended and its proper use. From an environmental standpoint, EPA's National Emission Standard for Hazardous Air Pollutants (NESHAP) for asbestos dictates: 1) agency notification of planned demolition and renovation activities, 2) adherence to specified procedures for asbestos emissions control during removal activities, and 3) proper handling and disposal of the asbestos materials at the landfill site. These standards are applicable to the renovation and/or demolition of friable asbestos. Please notify C. R. Bent (extension 2918) of the Corporate Environmental Control Department, when asbestos removal activities are planned, to determine the applicability of the NESHAP regulations and/or to discuss the specifics of these requirements. Homer M. Cole Director Industrial Hygiene an^Toxico1ogy PLAINTIFFS EXHIBIT 7XTINER RMC0086298 003614 1 LV INDUSTRIAL HYGIENE Dist.: EH-1 July 27, 1988 In past years, we have issued Industrial Hygiene Bulletins covering safety, health, and environmental matters. There has been some confusion regarding those bulletins, as often they have been treated as information al, rather than as a reflection of company policy and/or approaches to industrial hygiene matters. Henceforth, such information will be released in the form of Industrial Hygiene Directives, which should be considered mandatory. Attached is an Industrial Hygiene Directive deal ing with asbestos demolition/removal procedures. Att. Homer M. Cole Director Industrial Hygiene and Toxicology R-IOO-M TX TIMER RMC0088299 003615 APPENDIX A WORK PRACTICES AND ENGINEERING CONTROLS FOR ASBESTOS REMOVAL/DEMOLITION ACTIVITIES --Wari. Practical nd EapaOTriBf CeatroU far Small ScaU fcort-Duratioa Aabustoa Ronovatioo and Maintenance Activities Dt fmtinn ofSmoll-Scale. Short-Duration Activities Fur thr purposes or this appendix, smellcale. shurt-duru`.ion renovation and maintenance activiuca are Utki ouch no. but noi limned to; Removal of asbestos-containing insulation on pipea: Removal of email quaniitiea of asbestoscontaining insulation on beam* or above ceilings: Replarxment of an asbestos-containing gaskei on a valve: Installation or removal of a small tertion of drywall: installation of electrical conduits through or proximate to ssbesto<onieining materials. Evidence in the record Isee the Summary and Explanation section of the preamble for paragraph (|I Methods of Compliance, for specific citationsJ suggests that the use of certain engineering and work practice controls is capable of reducing employee exposures to asbestos to levels below the final standard s action level (0.1 f/ce). Several controls and work practices, used either singly or in combination, can be employed effectively to reduce asbestos exposures during small maintenance and renovation operations These include. Met methods: Removal methods --Use of Clone begs --Remove) of entire asbestos Insulated pipes or structures --Use of mini-enclosures Enclosure of asbestos materials^ and Maintenance programs. This appendu describes these controls and work practices in detail Preparation ofthe Area Before Henovotion or Maintenance Activities The firs' step in preparing to perform o omall-scelt. short-duration asbestos renovation or maintenance task, tegardlaas of the abatement method that will be used, it the removal from the work area of all objects that are movable to protect them from atbertos contamination Obiecu that cannot he removed mutt be covered completely with a t-mil-thick polyethylene plastic abetting before the tek begins if objects have already been contaminated, they ehould be thormifhlv cleaned with a High Efficiency Psrticulaie Air IIIEPA) filtered vacuum or be wet wiped bef.ve they ere removed from the work area or compieiely encased in the plastic. It'cr Methods Whenever feasible, and regardlets of the abatement method to be used (e.g . removal, enclosure use of glove bags), wet methods must be used during small-scele. short duration maintenance end renovation activities that involve disturbing asbestoscontaining materials Handling asbestos materials wet is one of the most mliabls methods of ensunng that asbestos fibers do nut become airborne, and this practice should therefore be used whenever feasible. At discussed in the Summery and Foiplanation section of the preamble for paragraph (g). Me thods of Compliance, wet methods can be used in the greet meionty of workpiece equations Only in casts where asbestos work must be performed on live electncal equipment, on live etetm lines, or in other areas where water will seriously damage materials or equipment may dry removal be performed. Amended water or another wetting egent ehould be applied by means of on airless sprayer to minimise the extent to which the asbestos-conttining material is disturbed. Asbestos-containing materials should be wetted from the initiation of the maintenance Clave Beg Installation Clovs bags ere approximately SO-inch-wide limes M-inchlong begs fitted with arms through which the work can be performed (see Figure &>l(A)l When properly instilled and used, they permit workers to remain completely isolated from the asbestos material removed or replaced inside thr bag Clove bags cart thus prov ids e flexibilc. easily installed, end quickly dismantled temporary small work area anclotuie that is idsal for small-scale asbestos renovation or maintenance yobs. or renovation operation and wetting agents should be used continually throughout the work penud to ensure that any dry asbestoscontaining material exposed in the course of the work it wet and remains wei until final disposal. Brmoval of Small Amount ofAsbestos Containing Materials Several methods can be used to remove small amounts of asbestos-containing materials dunng small-scale, ehort-duraiion renovation or maintenance leeks These include the use of glove begs the removal of an entire asbastos-cevered pipe or structure, and the construction of mini-enclosures. The procedures that employers must use for each of these operations if they wish to avail themselves of the final rule's saemptions are described in the following sections. Clove Bags As discussed in the Summary end Explanation section of the preamble for paragraph (g). Methods of Compliance, evidence in the record indicate that the use ef glove bags to enclose the work area during emell-scale. short-duration maintenance or renovation activities will result in employee exposures to asbestos that are below the final standard s action level of o.l f/ec This appendix provides requirements for glovebag procedures to be followed by employers wishing to avail themselves of ths standard s exemptions for osch activities. OSHA has determined that the use of these procedures will reduce the hour lime weighted avenge (TWA] exposures of employees involved in these work operations to levels below the action level end will thus provide s degree of employee protection equivalent to that provided by compliance with all provisions of the final nils. TXTINER RMC0086300 003616 A-l INDUSTRIAL HYGIENE DIRECTIVE July 27, 1988 ASBESTOS DEMOLITION AND REMOVAL It is the policy of Reynolds Metals Company that all employee exposures to asbestos be kept as low as possible. Consequently, where feasible, all asbestos demolition/removal work should be performed by qualified outside contractors. A list of qualified contractors and a Performance Audit Form are enclosed. The Performance Audit Form should be returned to the attention of R. E. Benton, Industrial Hygiene, upon the completion of each job. For small-scale asbestos demolition/removal jobs, where time is critical and a contractor cannot be obtained, properly trained RMC employees may perform the asbestos demolition/removal work. These employees, however, must be thoroughly trained on proper work practices for handling asbestos. (See Appendix A.) Part of the training program should include videotapes which are available from Corporate Industrial Hygiene. Employees must also be advised about the types of asbestos present and their potential health effects. At least one supervisor should attend an asbestos training course, if the plant anticipates using Reynolds' employees for any asbestos demolition/removal work. Training courses are sponsored by the Environmental Protection Agency (EPA) Asbestos Training Centers and other groups.' (See enclosed list of training centers in Appendix B.) The supervisor who attends the course would then be responsible for training all affected plant personnel, to ensure that proper work practices are used during all asbestos demolition/ removal jobs. Air sampling is also required on all asbestos demolition/ removal jobs, to assure the effectiveness of the controls and work practices. This requirement may necessitate the purchase of air sampling equipment. (See Appendix C.) Should the plant wish to purchase equipment, please contact Ron Benton (Ext. 2265) or me (Ext. 3506), regarding the type of equipment recommended and its proper use. From an environmental standpoint, EPA's National Emission Standard for Hazardous Air Pollutants (NESHAP) for asbestos dictates: 1) agency notification of planned demolition and renovation activities, 2) adherence to specified procedures for asbestos emissions control during removal activities, and 3) proper handling and disposal of the asbestos materials at the landfill site. These standards are applicable to the renovation and/or demolition of friable asbestos. Please notify C. R. Bent (extension 2918) of the Corporate Environmental Control Department, when asbestos removal activities are planned, to determine the applicability of the NESHAP regulations and/or to discuss the specifics of these requirements. Homer M. Cole Director Industrial Hygiene and Toxicology TXTINER RMC0088301 003617 (A) (8) (C) (D) npnC-I Da* *T Glen bp n ill-Scai*. tbaH-DwHaa Maia These bag* arc tingle uac control device* that ere disposed of at the end of each job. The bag* ate Bade of transparent S-mil-thick polyethylene plaatie with arm* ofTyvek * material (the acme material uaed to make the diapotable protective auft* uaed tn major asbestos removal, renovation, and demolition operation* and in protectiva (love*). Clove bef* are readily available from aafety aupply atorc* or apecialty aabeatoa removal aupply bouses. Clove bag* come pie-labeled with the aabeatoa warning label preacribed by OSHA and EPA for bags uaed to dtapoac of aabeatoa watt*. Clor* Bag Equipment and Supplies. Supplie* and material* that are necessary la use glove bap* affectively Include: (1) Tape to aaal the glove bag to the area from which ababeato* * to be removed; (2) Amended water or other wetting agent*: (3) An airleaa aprayer for the application of tbe wetting agent Mention at trade name* or ocmmerciel product* doee not snaiiiuit andoraaaest er lecomaendation lor m*. (4) Bridging encapaulant (a paate-like aubatanee for coating aabeatoa) to eeal tbe rough edge* of any aabeatoa-containmg matenala that remain within the glove beg at the point* of attachment after tbe teat of the aabeatoa ha* be rentovod: (5) Tool* aucb a* roxor knivea. nipt, and wire bniahea (or other tool* amiable for cutting wire, etc.): () A HEPA filler-equipped vacuum for evacuating the glove bag (to minimise the raleaae of aabeatoa fiber*) during removal of the bag from the work area and for cleaning any matenal that nay have eacaped during tbe inatallation of the glove bag: and |T) HEPA-eqmpped dual cartridge reapirator* for uae by the employeea involved in the removal of aabeatoa with the glove bag. Clove Bag Work Practice* The proper uae of glove bags require* the following atapa: (1) Clove bag* muat be inatalled *o that they completely cover the pipe or other atrueturt where atbeaio* work i* to be done. Clove bagi art inatalled by cutting the tide* of the glove bag to fit the alee of the pipe from which aabeatoa i* to be removed. The glova b*l n attached to the pipe by foldinc the open edge* together and aecurely act ling them with tape AU opening* in the glove beg mutt be aeaied with duct tape or equivalent matenal The bottom team of the glove bag muat alto be aeaied with duct tape or equivalent to prevent any leakage from the bag that may result from a defect in the bottom team (Figure ^l(B)). (2) The employee who * performing the atbeaio* removal with the glove bag mutt don a half m**k dual-cartndgc HEPAequipped respirator, respirator* should be worn by employee* who are in dot* contact with the glove bag and who may thus be exposed a* a result of small gaps in the aeamt of the bag or holes punched through the bag by a rasor knife or a piece ofwire mesh. (3) The removed aabeatoa matenal from the pipe or other surface that has fallen into the enclosed bag muat be thoroughly wetted with a wetting agent (applied with an airless aprayer through the pre-cut port provided in most glove* bags or applied through a small hole cut in the bag) (Figure G-1(C)) (4) Once the asbestos material has been thoroughly wetted, it can be removed from the pipe, beam or other surface The choice uf tool to use to remove the atbestoe-conteining matenal depende on the type of matenal to be removed Atbetto*<onttining materials are generally covered with painted canvas and/or wire mesh Fainted canvas can be cut with raior knife and peeled away from the asbestos-containing matenal underneath. Once the canvas has been peeled away the asbestos-containing matenal underneath may be dry. in which case it ahould be re-spreyed smth e wetting egent to ensure thai it generates a* litlie dust at possible when removed. If the aabeatoa-containing material it covered with wit* mesh, tht meah ahould be cut with nip*, tin snips, or other appropriate tool and removed A wetting agent must then be used to spray any layer of dry metenal that it exposed beneath the mesh, the surface of the ttnpped underlying structure, and th* inaide of th* glove bag (5) After removal of the layer of asbestoscontaining matenal. the pipe or surface from which aabeatoa hat been removed muai be thoroughly cleaned with e wire brush end wet wiped with e wetting agent until no traces of the aabeatoa containing matenal can beaten. () Any aabeatoa containing insulation adget that have been exposed at a resuh of the removal or maintenance activity mutt be encapsulated with bndging encapaulant to ensure that the edge* do not relaaae aabeatoa fiber* to the atmosphere after the glove bag baa bean removed. (7) When the aabeatoa removal and encapsulation have been completed, a vacuum boa* from a HEPA filtered vacuum muat be inserted into the glove bag through the port to remove any air in the beg that may contain asbestos fibers When the air bo* been removed from the beg. the beg should be squeezed tightly (at dote to the top et potaiblc). twitted, and taaled with tope to keep the atbeaio* malarial* safely in the bottom of the bag Th HEPA vacuum can txtiner RMC0086302 003618 A-2 then be removed from the bag and the glove bog itself can be removed from the work area to be diepoaed of property (Figure G-I(DJ) TP f1# Slit fit Work Arts I I II II II II I I I FUstic (irulf Vi. la curtain Vietti Itott Milt CirU Mtitie Curtain CkH III! II I Caution I iCtntgUll Mthtstos I II o-ti ate all Vac kbit Uini-Enehntm In aome liutaneea. such as removal of asbestos from a amall ventilation system or from a short length of duct, a glove bag may not be either large enough or of the proper ahape to enclose the work area In such cases, a mini-enclosure can be built around the ares where small-scale, short-duration asbestos maintenance or renovation work is to be performed (Figure C-2) Such aa enclosure ehouiu oe conatnietad ofO-muthick potyathylana plastic sheeting and can be small enough to restrict entry to the asbestos work area to one worker. For example, a mini-enclosure can be built ta a small utility closet when asbestos* containing duct covering is to be removed. The enclosure is constructed by: (1) Affixing plastic sheeting to the walla with spray adhesive and tape: 003619 TX TIMER RMC0086303 A-3 |n Cnnn| the Hw' "ttk plastic and Moling the plastic >tn*| the Dm so tttt plastic an tht wall*. fll Scaling an) penetrations such a* pipe* m ebdnsal conduits with tape, and ((] Constructing a mall change mow (epprenm*tfl\ ) foe' aquara) mad* of bmilAid polyethylene plastic Supported by XAdt by 4-neh lumber (the plamc should lie ttacJwd la the lumber supports with daplea m spray adheaitt and tape) TV dang* room should be centguous to At in> andosur*. and it neeeasan la allow Ac warier la vacuum efT hit protective Mvrr*llt and rrmo theai lie Tor* lac ring th* wori area While inaidc (he enclosure. the mortar should wear Tyvok' ditpoaable onvemtls and aae (he appropriate HEPA (Mitred dual canndg* respiratory protection. TV* advantage* af mini-enclosure* are that Aey limn the apread of atbetiot onismuvaiton. reduce the potential exposure f bystander* and other aroriere who may be worirng in adjacent areas. and are puick and Mt> te mttall TV* ditadvantage *f mininrlosures it that the) ma> be too email la contain the equipment twruir) te create a Mfiure pr*aurc withm the endaeurc: however, (he double layer of plastic cheering rill aeri e to reetntr the releate of atbetiot fiber* la the area outside the enclosure. Rrmorvt t Ettiip Errvervror When pipe* arc Inaulated with asbestoscontaining matenalt. removal of Ihe entire pipe may be mere protective, aatier. and ar cost-effective than atripping the atlx rot insulation from the pipe fiefare ouch a pipe la cut. the asbestos-containing Insulation atuti be wrapped with hmil polyethylene plattit and aeeurel) aaalad with duct up* ar equivalent Thu platuc covering will prevent atbetiot fiber* from becoming airborne a* a roauJt of the vibration ceoaied b> the power aawt need te cut the pip* If possible. the pipe* should be cut at location* Act are net miniated to avoid disturbing the tbn iot- If a pipe ta completely insulated with atbe*iotmt*inmg matenalt. email aoctioni should be stripped ucing (he glovebaj method detsnixd above before the pipe A act at the atnppad aochona. A a irnance Pryprym An atbe*to* ctamtenanee prwgtam wutt hi toitiuted in aU fadltiiet that have athrsto*. ontotning materials. Such a program ahould Adude: Development af an Inventory ef alt aebettot-containing materials in the lacihtr: Periodic rtantmauan af all asbitetantaimng matenalt la detect detmorsunn: Written procedure* far handling aib**toe utenalt dunng the performetter of amallcate, ahanduretton maintervawi: and aenovattan activities: Written precede*** far esheetoa disposal and Written procedmee lor dealing with cbaataa-related amerganoea. Member* af the buildmgs maintern*rw Mginoenng tuff (elaetnoani. beauag/atr ondi turning engineer*, plumber*, eu.) who may be required la handle atbcttoaconiaimng matenalt iheuid be trained in aafe procedure*. SoA trotawg ahould iodide at a uniaturn: Information regarding type* af aalmataa aad it* veneut uae* and forme: Mfurmstion on the health eflecta oeodatrd with aabeetoa tepoaure: Description* af the proper methods nf handling etlMSteeoBntsiBiRg material* and Infatuation an the ua* of HEPAQuipped dual cartridge respiratory and other personal protactioo durwtg maintanarux Uiviues. PmhibimdAaMbm TV* (raining prowsm fat the maintenance amgmrenag ttafT should describe methods of handling asbestos-containing matenalt at wall at routine maintenance ecttvmr* that aae prohibited when aabaaioa-coniauung malerialt am involved Per aaemplc. maintenance staff employees abnulii be Xm ta drill bales in aafaewe* containing Mienala. AVrr lu hang plants or pictures on structures covered with atbntua-mntaming mater isle. .#/ tu send asbestos-canumii^ finer Mle: Sot to damage aabettm-emnuinina matenalt while otovtng lumuurc or other htecit: .Vpr to install curtains, drape* or At (tier* in such wav that they Amage abestnaxnntatning matenalt: Aar te dust floor* ceiling*, meldings e* Other surfaces in s*hesto*-entuammaied environment* with a dry bruah ar sweep with dry broom. Xoi to cae an ordinary vacuum to dean op atSettiisenlaining debnr Xoi ta remove ceiling tile* below atbi-sto*.containing matenalt without wearing the proper respiratory proiectiom. clearing the aura af ether people, and observing atboatet removal waste Aspnaal pmcadwoa: AVx ta remove ventflaUco system filler* Ay and ASBESTOS DEMOLITION AND REMOVAL July 27, 1988 OVERVIEW OF THE GLOVEBAG PROCEDURE A glovebag is a 6-12 ail bag fitted with long-sleeved gloves, a tool pouch, and a two-inch opening for water. Although glovebags can be fabricated by the user for each project, most contractors prefer to purchase readymade bags. The size, quality, style, and cost vary depending on the manufacturer. In addition to the glovebag, several other tools and materials are commonly required to perform the project successfully. These materials, listed below, are readily available from most asbestos abatement contractor suppliers. MATERIALS 1. Glovebag (one or more, depending on project size) 2. Pump-up garden sprayer (2-3 gallon size) 3. Amended water (surfactant, availble from local garden shop or safety supply company) 4. Duct tape (3-inch width) 5. Polyethylene disposal bags (6 mil) 6. Smoke tubes with aspirator bulb 7. HEPA-filtered vacuum cleaner 8. Bone saw 9. Utility knife with retractable blade 10. wire cutters 11. Tin snips (if aluminum jacket is present) 12. Polyethylene plastic (roll of 4 or 6 mil) 13. Dual cartridge respirators with high efficiency cartridges 14. Disposable full-body suits with hood and feet covering 15. Small scrub brush 16. Stapler 17. Several rags 18. Wettable cloth 19. Asbestos caution signs and labels 20. Reinsulation materials, as necessary BEFORE STARTING A GLOVEBAG PROJECT Two persons are required to perform a glovebag removal project. Also, a third person is sometimes available, to assist with supplies, to keep unwanted visitors out of the area, and to conduct air monitoring. Each of the team members should be trained on the use and limitations of glovebags. They should also be included in the respiratory protection and medical surveillance programs. Before any work begins, all necessary materials should be brought into the work area. The work area should be roped off and warning signs should be posted on the perimeter to minimize the chance of visitors entering the area. Barrier tape (3-inch) with a pre printed asbestos warning is recommended. If applicable, the HVAC supplying the work area should be shut down. Employees should also be trained about emergency procedures, in the event of a glovebag rupture. The emergency training should cover wet cleaning, HEPA vacuuming procedures, and shower use. The following guidelines may be used for most pipe lagging projects: 003621 TXTINER RMC0086305 A-5 ASBESTOS DEMOLITION AND REMOVAL July 27, 1988 REMOVAL PROCEDURES 1. Follow the manufacturer's directions and mix the surfactant with water in the garden sprayer. 2. Each employee should wear a cartridge respirator and check the face-fit. 3. Each employee should wear a disposable full-body suit, being mindful that the hood goes over the respirator straps. 4. The pipe on which the work will be performed should be checked. REMEMBER. . .NEVER PERFORM GLOVEBAG REMOVAL ON HOT PIPES OVER 150F. This may cause the bag or gloves to melt over the workers' hands and arms. If the pipe is damaged (broken, lagging, hanging, etc.), the entire length of the pipe should be wrapped in polyethylene plastic and "candystriped" with duct tape. A common problem with glovebag work is that loose pipe lagging several yards from the glovebag may be jarred during the work, causing a release of asbestos into the air. Another problem is failure to clean up debris on the floor and other surfaces. If the pipe is undamaged, it is still necessary to place one layer of duct tape around the pipe at each location where the glovebag will be attached. This serves two purposes. First, it gives a good surface on which to seal the ends of the glovebag. Second, it minimizes the chance of releasing fibers when the tape at the ends of the glovebag is peeled off at the comple tion of the job. 5. Slit the top of the glovebag open (if necessary) and cut down the sides to accommodate the size of the pipe (about two inches longer than the pipe diameter). One brand has a zipper top and straps at each end facilitating installa tion of the bag on the pipe. 6. Place the necessary tools into the pouch located inside the glovebag. This will usually include the bone saw (flexi saw), utility knife, rags, scrub brush, wire cutters, tin snips, and wettable cloth. Note: It is easiest to pre-cut the wettable cloth at this point. Cut out a donut shape with the inner diameter 1/2-inch smaller than the diameter of the pipe beneath the in sulation. The outer diameter of the donut should be three inches longer than the diameter of the pipe in sulation being removed. Finally, cut a slit in each of the two donuts, so they can be slipped around the pipe. 7. Place one strip of duct tape along the edge of the open top slit of the glovebag for reinforcement. TX TIMER KMC0086306 003622 A-6 asbestos demolition and removal July 27, 1988 8. Place the glovebag around the section of pipe to be worked on and staple the top together through the reinforcing duct tape. Staple at intervals of ap proximately one inch. This should provide an ade quate seal along the top. Next, duct tape the ends of the glovebag to the pipe itself, previously covered with plastic or duct tape (See Step 4). 9. A smoke tube and aspirator bulb are needed to test the glovebag. Place the tube into the water sleeve (two-inch opening to glovebag). By squeezing the bulb, fill the bag with visible smoke. Remove the smoke tube and twist the water sleeve closed. While holding the water sleeve tightly, gently squeeze the glovebag and look for smoke leaking out, especially at the top and ends of the glovebag. If leaks are found, they should be taped closed, using duct tape, and the bag should be retested with smoke. 10. Insert the wand from the water sprayer through the water sleeve. Using duct tape, tape the water sleeve tightly around the wand, to prevent air leakage. 11. One person should place his hands into the long-sleeved gloves, while the second person directs the water spray at the work. 12. If the section of pipe is covered with an aluminum jacket, it should be removed by first using the wire cutters to cut any bands and then using the tin snips to remove the aluminum. It is important to fold in the sharp edges to prevent cutting the bag when it is placed in the bottom. Use caution to prevent cuts - these edges flre.pftasRj 13. With the insulation exposed, use the bone saw to cut the insulation at each end of the section to be re moved inside the glovebag. Note: A bone saw is a serrated heavy-gauge wire with ring-type handles at each end. Throughout this process, water is sprayed on the cutting area to keep dust to a minimum. 14. Once the ends are cut, the section of insulation should be slit from end to end, using the utility knife. The cut should be made along the bottom of the pipe and water continually supplied. Again, care should be taken, when using the knife, not to puncture the bag. Some insulation may have wire to be clipped, as well. 15. Spray all tools with water inside the bag and place back into pouch. 16. The insulation can now be lifted off the pipe and gently placed in the bottom of the bag. TX TIMER RMC008K07 003623 A-7 ASBESTOS DEMOLITION AND REMOVAL July 27, 1988 17. Using ths scrub brush, rags, and vater, scrub and wipe down the exposed pipe inside the glovebag. Note: The inexpensive horse rub-down mittens work veil for this. 18. Wet the donut-shaped pieces of vettable cloth over the exposed ends of insulation remaining on the pipe. Wettable cloth is a plaster impregnated fiberglass webbing available at many hardware and/or plumbing supply stores. 19. Remove the water wand from the water sleeve and at tach the small nozzle from the HEPA-filtered vacuum. Turn on the vacuum only briefly to collapse the bag. 20. Remove the vacuum nozzle, twist the water sleeve closed, and seal it with duct tape. 21. From outside the bag, pull the tool pouch away from the bag and twist it to separate it from the bag. Place duct tape over the twisted portion and then cut the tool bag from the glovebag, cutting through the twisted/taped section. 'This will allow the contami nated tools to be placed directly into the next glovebag without cleaning. Alternatively, the tool pouch with the tools can be placed in a bucket of water, opened underwater, and the tools cleaned and dried without releasing asbestos into the air. Note: Rags and the scrub brush cannot be cleaned in this manner and should be discarded with the asbestos waste. If more than one adjacent section of pipe is to be removed, the glovebag may be loosened at each end and slid along the pipe to the next section. In this case, the tools would remain in the bag for continued use. 22. With the removed insulation in the bottom of the bag, twist the bag several times and tape it to keep the material in the bottom during removal of the glovebag from the pipe. 23. Slip a 6 mil disposal bag over the glovebag (still attached to the pipe). Remove the tape, open the top of the glovebag, and fold it down into the dis posal bag. 24. Remove the disposable suits and place these into the bag with the waste. 25. Twist the top of the bag closed, fold this over, and seal it with duct tape. Then put a warning label on the bag. 26. Using a clean damp rag, wipe the exterior of the respirator and leave the work area. Then, remove the respirator. 003624 A-8 TXTINER RMC0088308 ASBESTOS DEMOLITION AND REMOVAL July 27, 1988 27. Asbestos-containing material must be disposed of at an approved landfill in accordance with EPA regulations. TXTINER RMC0088308 003625 A-9 ASBESTOS DEMOLITION AND REMOVAL July 27, 1988 APPENDIX ASBESTOS TRAINING CENTERS INSTITUTION Southeast Asbestos Info. Center GEORGIA INSTITUTE OF TECHNOLOGY Atlanta, GA 30332 Asbestos Information Center TUFTS UNIVERSITY Medford, MKA 02155 Natioal Asbestos Info. Center UNIVERSITY OF KANSAS Shawnee Mission, KS 66207-3398 MEDICAL COLLEGE OF VIRGINIA Dept, of Preventive Medicine Richmond, VA 23298-0212 PACIFIC ASBESTOS INFORMATION CENTER UNIVERSITY OF CALIFORNIA, EXTENSION DIV. 2223 Fulton St. Berkeley, CA 94720 MIDWEST ASBESTOS INFORMATION CENTER School of Public Health UNIVERSITY OF ILLINOIS 2035 West Taylor St. Chicago, IL 60612 TELEPHONE 404/894-2400 617/381-3531 913/648-5790 804/786-9785 804/786-0494 415/643-7143 312/996-5762 003626 B-l TX TIMER RMC0086310 PERFORMANCE AUDIT axnraCIGR ASBESTOS FBXJJXL/FEPHR DAZE DEPARTMENT NAME CF ACDUCR PLANT TYPE UGOIATICN Tb ensure that the cxntxactar is applying with the axitract, please answer the following guesticns. Any question which is answered "lb" should be explained in '**-*' i cn the back of this form. YES IP K/fr 1. D O HAS A REGULATED AREA WITH WARNING SIGNS BEEN ESTABLISHED?* 2. O O O IS AN ENCLOSURE BEING USED (CONTAINMENT ROOM OR A GLOVE BAG)? S. IF THE ENCLOSURE IS A CONTAINMENT ROOM, IS IT KEPT UNDER WGATIVE PRESSURE WITH A VENTILATION SYSTEM EQUIPPED WITH HEPA (HIGH EFFICIENCY PARTICULATE AIR) FILTERS? 4. IF THE ENCLOSURE IS NOT BEING USED, HAS THE CONTRACTOR ESTABLISHED BORDERS TO HIS REGULATED AREA BASED ON AIR SAMPLING RESULTS? S. 6. a 7. a a . O IS ACCESS TO THE REGULATED AREA LIMITED TO THOSE INVOLVED IN THE REMOVAL/REPAIR PROJECT? ARE PERSONS ENTERING THE REGULATED AREA PROVIDED WITH RESPIRATORY PROTECTION AND PROTECTIVE CLOTHING (RUBBER FACEPIECE RESPIRATOR, HEAD, HAM), WHOLE BODY, AND FOOT COVERINGS)? ARE PERSONS LEAVING THE REGULATED AREA REQUI RED TO DECOMTAMI NATE THEMSELVES? ARE WET METHODS MATERIAL? TO REMOVE AND CLEAN UP TW ASBESTOS'CONTAINING CONTAINING WASTE PLACED IN I LABELED PLASTIC BAGS?1 E. 10. ODD AFTER TW ASBESTOS*CONTAINING MATERIAL HAS BEEN REMOVED OR REPAIRED, IS A IEPA VACUUM CLEANER USED TO CLEAN ALL CONTAMINATED SURFACES? It o a AFTER THE VACUUMING, ARE THESE SURFACES WET WIPED/MOI D? * Warning Sign language: ranger Asbestos TXTINER RMC0086311 and Lung Disease Hazard Authorized Personnel Gnly Respirator and Protective Clothing -- `v^e Area. AUDITOR'S S1LMA1UHK 003627label language: Contains Asbestos Fibers Avoid Creating IXst r^nr*r and Lung Disease Hazard B-2 QimgricH # BCLAmmON ocpmenis TX TINER RMC0088312 003628 B-3 ASBESTOS DEMOLITION AND REMOVAL July 27, 1988 APPENDIX RECOMMENDED SAMPLING PROCEDURE TOR ASBESTOS - 1. The preferred collection device shall be the 25mn nixed cellu lose ester filter in a cassette with an open-faced 50nm extension cowl. The 37nn cassette nay be used in those situations where dust loadings reduce the sanpling tine to less than one hour. (See Iten 3, below.) 2. An airflow rate between 1.5 liter/nin. and 2.5 liters/nin. shall be used for either the 25mm or 37mm cassette. 3. If, during sampling, the filter darkens noticeably (i.e. changes color), or if loose dust is seen on the filter, a second sample shall be started. 4. All pumps should be calibrated with a bubble flow meter before and after each day's use. An inverted 500ml buret will suffice as the bubble neter. 5. Before starting the sampling, record the date, plant name, sample number (written on the white shrinkband), pump number, employee's name, work description, and controls used on the enclosed sampling data sheet. Also, note the type of protective clothing and respirator worn by the employees. 6. The tubing from the pump should be attached to the end of the cassette that has the "ribbed" appearance. The cassette should be sampled with an open face (i.e. entire cap removed from the end of the cassette, rather than the small plug) and attached to the worker's shirt collar. 7. After the pump is turned on, ensure that it is functioning properly and has an 8-hour charge. The tine the pump is started is also recorded on the sampling data sheet. 8. Unless the filter darkens, as in Iten 3, the sampling period should be a series of 4-hour samples until the project has been finished and clean-up completed. At the end of each sampling period, the cassette should be removed fron the tubing, the end cap and bottom plug replaced, and the time pump stopped should be recorded on~the sampling data sheet. 9. During sanpling, any conditions which night affect the results should be noted on the sampling data sheet (e.g. glovebag rupture, insulation not kept wet, etc.). 10. After sampling has been completed, each cassette should be taped around the ends, to prevent accidental opening during shipment, and returned to Corporate Industrial Hygiene in a rigid container, along with the completed sanpling data sheets. (Note: One unused cassette should be returned as a blank, for every 6 filters used.) *** 003629 C-l TX TIMER RMC0086313