Forwarding WTC air monitoring scope for final review, Aug 2002

NYC 9/11 Public Portal Document

Environmental Protection Agency Pt. 763. Subpt. E. App. C (h) Inspectii^ for Mable and non-frlable (1) Regulatory review. The following topics ACM and assessing the condition of friable should be covered: National Emission Stand­ ACM. Procedures to follow in conducting vis­ ards for Hazardous Air Pollutants (NESHAP: ual inspections for friable and non-frlable 40 CFR part 61, Subparts A and M): EPA ACM: types of building materials that may Worker Protection Rule (40 CFR part 763, contain asbestos: touching materials to de­ Subpart G): OSHA Asbestos Construction termine friability: open return air plenums Standard (29 CFR 1926.58): OSHA respirator and their importance in HVAC systems: as­ requirements (29 CFR 1910.134): the Asbestos- sessing damage, significant damage, poten­ Contalning Materials in School Rule (40 CFR tial damage, and potential significant dam­ part 763, Subpart E: applicable State and age: amount of suspected ACM, both In total local regulations, and differences between quantity and as a percentage of the total Federal and State requirements where they area: type of damage: accessibility: mate­ apply, and the effects, if any, on public and rial’s potential for disturbance: known or nonpublic schools or commercial or public suspected causes of damage or significant buildings. damage: and deterioration as assessment fac­ (m) Field trip. This Includes a field exer­ tors. cise. including a walk-through inspection: (1) Bulk sampilngfdocunientation of asbestos. on-slte discussion about Infonmatlon gath­ Detailed discussion of the "Simplified Sam­ ering and the determination of sampling lo­ pling Scheme for Friable Surfacing Mate­ cations: on-slte practice in physical assess­ rials (EPA 560/5-85-030a October 1985)": tech­ ment: classroom discussion of field exercise. niques to ensure sampling in a randomly dis­ (n) Course review. A review of key aspects tributed manner for other than friable sur­ of the training course. facing materials: sampling of non-friable ma­ terials: techniques for bulk sampling: Inspec­ 4. Management Planner tor’s sampling and repair equipment: patching or repair of damage from sampling: All persons who prepare management plans discussion of polarized light microscopy: for schools must be accredited. All persons choosing an accredited laboratory to analyze seeking accreditation as management plan­ bulk samples: quality control and quality as­ ners shall complete a 3-day Inspector train­ surance procedures, EPA’s recommendation ing course as outlined above and a 2-day that all bulk samples collected from school management planner training course. Pos­ or public and commercial buildings be ana­ session of current and valid inspector accred­ lyzed by a laboratory accredited under the itation shall be a prerequisite for admission NVLAP administered by NIST. to the management planner training course. (j) Inspector respiratory protection and per­ The management planner course shall in­ sonal protective equipment. Classes and char­ clude lectures, demonstrations, course re­ acteristics of respirator types: limitations of view. and a written examination. respirators: proper selection. Inspection: EPA recommends the use of audiovisual donning, use, maintenance, and storage pro­ materials to complement lectures, where ap­ cedures for respirators: methods for field propriate. testing of the facepiece-to-face seal (positive TSCA Title II does not require accredita­ and negative-pressure fit checks): quali­ tion for persons performing the management tative and quantitative fit testing proce­ planner role In public and commercial build­ dures: variability between field and labora­ ings. Nevertheless, such persons may find tory protection factors that alter respiratory this training and accreditation helpful In fit (e.g., facial hair): the components of a preparing them to design or administer as­ proper respiratory protection program: se­ bestos operations and maintenance programs lection and use of personal protective cloth­ for public and commercial buildings. ing: use, storage, and handling of non-dlspos- The management planner training course able clothing, shall adequately address the following top­ (k) Recordkeeping and writing the inspection ics: report. Labeling of samples and keying sam­ (a) Course overview. The role and respon­ ple identification to sampling location: rec­ sibilities of the management planner: oper­ ommendations on sample labeling: detailing ations and maintenance programs: setting of ACM inventory: photographs of selected work priorities: protection of building occu­ sampling areas and examples of ACM condi­ pants. tion: Information requir^ for Inclusion in (b) Evaluation/interpretation of survey re­ the management plan required for school sults. Review of TSCA Title 11 requirements buildings under ’TSCA Title II, section 203 for inspection and management plans for (1)(1). EPA recommends that States develop school buildings as given In section 203(1) (1) and require the use of standardized forms for of TSCA Title II: interpretation of Held data recording the results of Inspections in and laboratory results: comparison of field schools or public or commercial buildings, Inspector’s data sheet with laboratory re­ and that the use of these forms be incor­ sults and site survey. porated into the curriculum of training con­ (c) Hazard assessment. Amplification of the ducted for accreditation. difference between physical assessment and

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