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901 Task 3 Summary

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Mr. Nooner,

In accordance with Reg. 21.901 Work Procedure Compliance (F)(1), wetting may not be required because to comply with Arkansas Asbestos Abatement Regulation (Reg. 21) would present a safety hazard. In the attached email response, you requested approval for dry removal due to a possibility of a safety hazard (fire). The email also contained a letter from EnergySolutions explaining that the hazard exist due to the possibility of the presence of sodium metal outside the system piping and components, as sodium reacts exothermically with water to form sodium hydroxide and hydrogen gas, which could pose a fire hazard. The Department grants approval for dry removal renovation operations prior to wetting. In addition, Reg. 21.901 (F)(2) requires in such instances that the …show more content…

The system must exhibit no visible emissions to the outside air. The owner or operator may alternatively use air cleaning and shall, for fabric filter collection devices installed after January 10, 1989, provide for easy inspection for faulty bags. After January 10, 1989, if the use of a fabric filter creates a fire or explosion hazard, or the Director determines a fabric filter is not feasible, the Director may authorize as a substitute the use of wet collectors designed to operate with a unit contacting energy of at least 9.95 kilopascals (or 40 inches water gage pressure), or use a HEPA filter that is certified to be at least 99.97 percent efficient for 0.3 micron particles. The Director may authorize the use of filtering equipment other than described in Reg. 21.901(F) if the owner or operator demonstrates to the Directors satisfaction that it is equivalent to the described equipment in filtering particulate asbestos material. A copy of any authorization from the Director must be retained at the

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