Asbestos NESHAP Inspection and Safety Procedures Course Chapter 8 Abatement Techniques This section is a very detailed description of the asbestos removal procedures If the instructor is not familiar with this this topic, it will take some review of the materials to be able to present this section These concepts are those that are taught in EPA/AHERA Contractor/Supervisor training programs There are many picture-type slides in this section Be sure to describe the points that are germane; but don’t get bogged down in the details or allotted time will slip away! 2014

TOPICS Important Terms Regulatory Requirements Negative Pressure Enclosure Abatement (wet & scrape) Glovebags Floor Tile Abatement Roofing Abatement An overview of the topics in this section

Important Terms Aggressive Air Sampling Amended Water Asbestos Containing Material Class I Asbestos Work Class II Asbestos Work Clean Room Critical Barrier Decontamination Area Equipment Room This and the next slide are important terms that will be used in this section Some have been described previously Briefly review each They will be discussed throughout this and remaining sections

Important Terms, cont. Glovebag High Efficiency Particulate Air (HEPA) HVAC System Local Exhaust Ventilation (LEV) Mil Polyethylene (“poly”) Project Designer Regulated Area All of these terms will be discussed and examples give later in this chapter

Regulatory Requirements EPA – Asbestos NESHAP OSHA – Construction Industry Standard Lead-in for the next 2 slides

Regulatory Requirements, cont. NESHAP Emission Controls Adequately wet Seal in leak-tight containers No visible emissions Do not drop, throw, slide or otherwise damage RACM A brief overview of NESHAP issues Discuss briefly

Regulatory Requirements, cont. NESHAP Emission Controls, cont. Use dust-tight chutes if > 50 feet (often with roof work) Use emission control systems: Local exhaust ventilation and collection system Glovebag systems Leak-tight wrapping A brief overview of NESHAP issues Discuss briefly

Regulatory Requirements, cont. OSHA Engineering Controls Vacuum cleaners equipped with HEPA filters Wet methods or wetting agents (where feasible) Prompt cleanup and disposal of wastes and debris contaminated with asbestos in leak-tight containers A brief overview of OSHA issues Many discussed in the last section Discuss briefly

Regulatory Requirements, cont. OSHA Engineering Controls, cont. Local exhaust ventilation equipped with HEPA filter dust collection systems Enclosure or isolation of processes Ventilation of the regulated area to move contaminated air away from the employees and toward a HEPA-filtration or collection device A brief overview of OSHA issues Many discussed in the last section Discuss briefly

Various types of removal activities. These will be discussed later in this chapter. Glovebag technique Class I “wet and scrape” These are asbestos removal techniques described in this section We’ll principally be discussing Class I issues Flooring is OSHA Class II Glovebags can be used for Class I & III work We’ll also look at roof removal, Class II Floor treatment removal

Asbestos Removal OSHA Class I (TSI & surfacing material) “Wet & Scrape” Topics Pre-abatement activities/considerations Decontamination System Work area preparation Negative Pressure Enclosures (NPE) Asbestos removal (confining and minimizing) Work area cleaning NPE issues; colloquially called “wet and scrape” Topic list Note; this section has many situational slides They are important, but don’t get bogged down with them, there are many slides in this section!

Pre-Abatement Considerations This slide and the next four slides deal with issues that should be considered well in advance of actual removal work The worst scenario is that a contractor bids and wins a project without ever seeing it in advance; this can spell a disaster! “Walk-throughs” are a must to assure that all bidders are bidding on what they’ve observed, not a guess!! Contractors should NEVER accept a project without doing a “walk through”. It’s often required to even bid the project.

Pre-Abatement Considerations Sky lights & lighting fixtures Ceiling height High walls are difficult to prepare with poly Light fixtures (Hg in lamps and PCB in ballasts) Other items like basket ball goals or other large items can make work area prep more complicated Hard to prep items

Pre-Abatement Considerations Wiring bundles can be a nightmare; impediment to access, electrical hazards and service interruption if damaged Very tight spaces are very difficult for workers and their safety Productivity is often over estimated which can lead to shortcuts and poorly performed removal work Productivity – How difficult will the material be to remove? Metal pan roof decks, rusted metal, wiring bundles and a maze of pipes can drastically affect the project time line.

Pre-Abatement Considerations All pre-existing contamination must be cleaned before work area prep Contaminated carpets should be removed (they cannot be sufficiently cleaned) Work area water leaks (typical) can contaminate carpets; they are most often removed in advance of work Pre-existing contamination and carpeted floors

Pre-Abatement Considerations This is not only an asbestos issue There is a roof leak issue and perhaps mold damage to structural wood Those issues are probably not in the asbestos contractors scope of work Water damage; is roof breach to be fixed? Mold issues?

Decontamination Units Often referred to as the “decon” OSHA Requirements For all Class I work area > 25LF or 10ft2 3 Chamber decontamination system must be attached to the regulated area Clean room, shower, and equipment room Shower room must comply with 29CFR1910.141(d)(3) “Sanitation” One of the first items to be erected when performing Class I work is the “decon” An operating 3 chamber decon is a MUST for OSHA Class I work Some State/Local programs and many job specifications may have particular issues here Shower “sanitation” issues enumerated on the next slide

Decontamination Units OSHA Requirements for Showers - 1910.141(d)(3) Showers. (d)(3)(i) Whenever showers are required by a particular standard, the showers shall be provided in accordance with paragraphs (d)(3)(ii) through (v) of this section. (d)(3)(ii) One shower shall be provided for each 10 employees of each sex, or numerical fraction thereof, who are required to shower during the same shift. These issues apply to Class I showers The items in yellow are important issues Many times there is insufficient space for multiple decons For mixed gender crews, it is a common practice for women and men go through the decon separately

Decontamination Units OSHA Requirements for Showers, cont. (d)(3)(iii) Body soap or other appropriate cleansing agents convenient to the showers shall be provided as specified in paragraph (d)(2)(iii) of this section. (d)(3)(iv) Showers shall be provided with hot and cold water feeding a common discharge line. (d)(3)(v) Employees who use showers shall be provided with individual clean towels. These issues apply to Class I showers The items in yellow are important issues Many times there is insufficient space for multiple decons For mixed gender crews, it is a common practice for women and men go through the decon separately

Shower In most local jurisdictions, and as an industry practice, all shower water must be filtered before disposal. Typical requirement is to filter to a maximum of 5 microns. All shower water must be filtered through a filtration system Often a multi-filter system; a 5 µm filter being the final filter Water should be disposed through sanitary drainage; local codes may dictate here

Decontamination Units - Plan View Water heater Airlock 3-5’ Airlock 3-5’ Poly Door Flaps Equipment Room (Dirty Room) Clean Room Shower Air Flow Work Area Worker Decon Unit Shower Water Filtration Unit This is the same work area diagram from the previous lecture Discuss the 3 separate rooms Clothing is removed and protective equipment donned in the clean room When leaving the area protective equipment is removed in the equipment room Proceed through shower with respirator on; remove when wet Dry and redress in clean room Air flow into the work area is through the decon Larger projects may have a separate decon for waste to save wear and tear on the worker decon Load Out Room Wash Down Room Air Flow Waste Load Out Unit For waste bags etc. - NOT workers Orange denotes contaminated area Airlocks are a recommendation

Built In Place The next 3 slides are decon examples This slide shows a decon erected outside the building, but connected to the work area These must be weatherproof! Note the rental toilet, this is a necessity if facilities are remote of the work area

Mobil Decon Some contractors have mobile decons These are only useful if work area is immediately adjacent This would not work if the work area was on a floor above etc…

Decon Inside Building Sometimes available space dictates that the decon is built inside the work area In this case they used scaffold framing to support the poly Any framing can work…

Work Area Preparation Purpose Protect the building surfaces and fixtures from asbestos contamination and water damage. Confine the airborne asbestos within the work area. Protect the people outside the work area from asbestos exposure. This slide through slide 37 deal with the erection of poly and other protective measures to prepare an area for asbestos removal See slide points

Prep Materials The Basics: 6 mil poly Duct tape (heavy duty, 4-6” wide) Spray glue OSHA danger signs Work areas are prepared with a few simple materials 6 mil (mil = 1/1000”) poly is most common; especially for floors 4 mil is often used for walls; a weight issue Duct tape is used by the case Spray glue helps seal seams The contractor may have to use a wide variety of inventive methods to hold up poly on walls There is no “the” way to do this…the contractor may have to be creative

Pre-Clean All surfaces that are suspected to be contaminated should be wet wiped and/or HEPA vacuumed before prep work can begin! Leaving pre-existing contamination can make final cleaning and passing final clearance (inspections & air sampling) much more difficult. A formal treatment of pre-cleaning Note points on slide

All electrical components are to be de-energized and locked out! Critical Barriers Install 2 separate and individual layers of 6-mil poly on all openings to the work area: Doors HVAC Windows Heating units Electrical panels Thermostats Toilets Etc. All electrical components are to be de-energized and locked out! Critical barriers are a very important, are an industry standard and often a state/local requirement See slide See picture, next slide

Critical Barriers In this picture you can see that there are 2 layers over the each window Then poly is placed over the wall

Critical Barriers HVAC must be shut off in the area where work is to commence; this is a must If not the work area can be pressurized and drive asbestos out of the work area This can also lead to duct contamination 2 layers of 6 mil is an OSHA requirement For Class I, OSHA requires 2 layers of 6 mil on HVAC duct openings.

Temporary Electrical Power 3 wire-12 gauge cords often needed extension For negative air machines (NAMs) Often power needs to be brought in This needs to be enabled by a qualified electrician All circuits used in the work area must be protected by a GFCI (more info, next slide) NAM’s – Negative Air Machines All circuits must be ground fault circuit interrupter (GFCI) protected.

Electrical Power Ground Fault Circuit Interrupter (GFCI) OSHA requires that electrical circuits in the enclosure shall be deactivated unless equipped with GFCIs. 29CFR1926.1101(g)(5)(i)(B)(2) All circuits supplied by a temporary power box or via extension cords are protected by a GFCI. A GFCI is one of your best protections from electrocution. OSHA requires the use of GFCI for both internal and external power to prevent against electrical shock hazards. The pictured depict several varieties of GFCIs.

Danger Signs OSHA Danger signs must be posted at all entrances and exits to work area This should also include doors that have been locked to the work area to avoid accidental entry They are required to be in the language that can be comprehended by the building occupants When signs are erected, the space within is the “REGULATED AREA” No one can be within this area without training and required to be there for their work There are a wide variety of issues with OSHA regulated areas; the standard has specifics

Wall Poly It is a standard industry practice to cover walls with one (light work) or 2 layers (heavy work, damageable surfaces) of 4 or 6-mil poly. 4 mil is lighter and is used for high walls. Some state/local programs have specific requirements for how work areas are prepared with poly. See slide points

Wall Poly Does this look like safe scaffold use? Here workers are erecting wall poly Scaffolding is insufficient for OSHA compliance (no side rails)

Floor Prep Floors are usually covered with 2 layers of 6-mil poly. The floor poly should extend about 2 feet up on the wall between wall poly to make an air and water tight seal. You will have to seal seams to cover the floor. Make sure that seams are tight with duct tape AND spray glue. Try to make the floor poly as flat and tight as possible. This makes cleaning easier once removal starts. See slide bullets State/Local programs may have requirements here

Wall & Floor Poly Wall Poly Floor This is a standard industry practice for prepping walls and floors Floor poly should lap onto and seal to the wall; ~12-24” It normal is extended the first layer of floor poly a foot or two up the wall and sealed with tape Subsequent layers of floor and wall poly should overlap and be sealed with tape and spray glue OSHA does not specify how many “layers”; most often a job specification, State/Local program issue Floor

Floor Prep Floors will need multiple widths of poly to seal the floor The poly seams need to be sealed securely with spray glue and tape If not, water leaks can occur As note previously, working over carpet is questionable; leaks

Finished Prep This picture is a well prepared work area Note that the poly only extend to the dropped ceiling This is most likely because they will be including the ceiling grid as part of the removal Note that the floor is nice and tight; this helps with cleaning

Finished Prep Another example of a finished preparation Well sealed floor seams Hose coming through wall is for spraying amended water (source is outside) Window in far wall; this is often required by specifications or State/Local programs

Negative Air Machines (NAM) Provide ventilation in the work area by drawing air from outside. Help prevent fibers from escaping by lowering the pressure inside the work area (negative pressure). Continually filter fibers out of the air. The next 8 slides will cover the issue of negative pressure and negative air machines NAM’s are the source of negative pressure and air movement through the work area

Negative Air Machines There are typically 3 filters: A - ½” pre-filter (coarse) B - 2” secondary filter (fine) C - ~12” HEPA filter (rated as 99.97% efficient for particles at 0.3 micrometers) If the coarse pre-filter and fine secondary filter are changed often, the HEPA lasts longer before becoming clogged with dust. The HEPA filter is typically rated in “running hours”. C A B A description of the filtration of a NAM If properly maintained, the exhaust should be free of all but the very finest of dust and asbestos fibers Published data has shown that poorly maintained machines can “leak” contaminated material into the exhaust See slide points

NAM Exhaust It is always preferable to exhaust NAM’s to the outside of the building. This will require windows or other openings that can be sealed. Plywood and aluminum duct stock make a good template in the window frame (or other openings, HVAC opening etc.). If in an office-type building, the windows are often permanently mounted and may have to be removed by a specialty contractor. If the seal is broken on this type of window system, it may be ruined and will have to be replaced…they are expensive!! See slide points Some buildings have windows that cannot be removed In this case exhaust is within the building (every effort should be made to avoid this) Air samples should be obtained to be sure that the exhaust is sufficiently filtered

Negative Air Machines An example of a work are fitted with exterior NAM exhaust The machines should be spread out through the area to provide air movement throughout Work site conditions can vary here

NAM Exhaust Ducts An example of exterior NAM exhaust Note: NAM exhaust often has an odor This is often this is misinterpreted by the public as though the machines are exhausting asbestos Air samples are taken occasionally outside to assure that fiber levels are not increased It would be uncommon to find appreciable fiber counts outside of a building in this scenario

OSHA Requirements Minimum of 4 air changes per hour and a negative pressure of -0.02 column inches of water. Proof of maintaining negative pressure as evidenced by manometric measurements (negative pressure recorder). These are very specific OSHA requirements The competent person is responsible to be sure that enough NAMs are operating to accomplish 4 air changes per hour These calculations are taught in AHERA Contractor/Supervisor programs The work area must maintain -0.02” of “negative pressure” throughout the project What this means is that the NAMs are turned on and remain operating night & day until final clearance air sampling meets project requirements Evidence of “negative pressure” is by using a manometer (see next slide)

Negative Pressure Recorder (manometer) The plastic tube is inserted through the poly; the device measures the pressure differential between the work area and the area outside of the work area. This device should read at least -0.02 It should be placed away from the NAMs if possible This is an OSHA requirement! Often a these devices have a strip chart recorder for evidence of maintained negative pressure

Negative Pressure OSHA requires that you smoke test containment at the beginning of each shift. This is an OSHA requirement; it is not often accomplished It is designed to detect “leaks” If the work area is sufficiently sealed and proper negative pressure is maintained, no leaks should occur Smoke testing is helpful to determine proper air movement through the work area