MCM window removal system

Abstract

The new technology introduced in this process is the innovative combination of equipment, tool and plumbing, that is, providing “point of contact” water spray, while complying with other provisions of EPA and OSHA required procedures, including training. Combining existing technologies in a new and innovative technique which will reduce worker exposures to health and safety hazards as well as satisfy the environmental concerns generally associated with this procedure, represents a cutting edge enhancement of an existing industry practice. Mechanical removal in the past violated the “no visible emissions” and the OSHA requirement to maintain material in a wet condition. Manual removal introduces significant worker health and safety issues.

1 . The applicant, David H. Mardigian, claims that the foregoing Specification describes a “new use of a known process, machine, manufacture, composition of matter, or material.” specifically, 
 (1.) Use of mechanical means to remove metal window units where the caulk is found to be an “asbestos containing material” as defined at 29 CFR 1926.1101 (b) being the OSHA Asbestos Standard.    (2.) Use of “point of contact” water spray fog to maintain material in an “adequately wet” condition as required by 40 CFR Part 61 Subpart M being the National Emissions Standard for Hazardous Air Pollutants-Asbestos (NESHAP).    (3.) Use of accepted regulatory practices in combination with the above, including training, pre-cleaning, wetting, dropcloths, positioning of rolloff, signage, intact removal, and prompt clean-up and disposal.    Applicant claims that he believes that he is the original and first inventor of the described process to combine existing technology in such a manner as to satisfy the regulatory requirements of the above-cited regulations and in so doing invented a new and unique technology not previously used:    This process was first used at the property of General Motors Corporation, Flint NAO North facilities in Flint Mich., following approval of the concept by the Michigan Department of Consumer and Industry Services on Aug. 23, 2001. The process was later found to be “in compliance with NESHAPS” by representatives of the Michigan Department of Environmental Quality.