Asbestos NESHAP Inspection and Safety Procedures Course

1. Asbestos NESHAP Inspection and Safety Procedures Course Chapter 4 Asbestos NESHAP Regulation Version 2012.1

2. Topics • Introduction • History • Asbestos NESHAP • 40 CFR Part 61, Subpart M • Appendix A – Roof Removal Operations

3. A note before we begin… • This section is an overview of the asbestos NESHAP requirements. • For a full understanding and more detail of the NESHAP read: • Chapter 4 in the course manual and • the asbestos NESHAP regulation

4. EPA Legal Authority - Asbestos • Statute: Clean Air Act – Section 112 National Emission Standards for Hazardous Air Pollutants (NESHAP) • Regulation: 40 CFR Part 61, Subpart M Asbestos NESHAP

5. Asbestos NESHAP Overview • Examples of substances regulated by EPA’s NESHAP program: • Asbestos • Benzene • Chlordane • Formaldehyde • Future references to the “NESHAP” in this course mean the asbestos NESHAP

6. Brief Asbestos NESHAP Overview • Applies to all facilities except single residential buildings having 4 units or less • Requires a thorough inspection before disturbance • Requires controlled removal of Regulated Asbestos Containing Materials (RACM) to avoid disturbance during demolition or renovation

7. Brief Asbestos NESHAP Overview(cont.) • Usually requires prior notification to EPA or the designated local/state NESHAP program • Requires proper management during disturbance of RACM and disposal to avoid release of fibers

8. NESHAP Information • Asbestos NESHAP policy information: • Applicability Determination Index (ADI) • http://cfpub.epa.gov/.adi • Stationary source compliance/guidance • Technology Transfer Network (TTN) • http://www.epa.gov/ttn

9. Asbestos NESHAP History • 1973 – Addressed demolitions and banned spray-applied asbestos such as fireproofing • 1975 – Addressed renovations and banned wet-applied such as pipe/boiler insulation and pre-molded insulation • 1978 – Addressed work practices and banned application of decorative uses such as textured ceilings

10. Asbestos NESHAP History(cont.) • 1984 – Repromulgation to address work practices • 1990 – Repromulgation to address notification and waste/disposal • 1994 – Addition of Appendix A to address roof removal

11. Asbestos NESHAP Sections • § 61.140 - Applicability • § 61.141 - Definitions • § 61.145 – Standard for Demo/Renovations • § 61.150 – Waste disposal • § 61.151 – Inactive waste disposal sites • § 61.153 – Source reporting requirements • § 61.154 – Active waste disposal sites • § 61.157 – Delegation of authority

12. Asbestos mill operations Roadway surfacing Product manufacturing Demolition/renovation operations Spraying of ACM Fabricating operations Use of insulating materials § 61.140 - Applicability

13. Waste disposal for asbestos mills Waste disposal for other ACWM Inactive waste disposal site closure and maintenance Air-cleaning device operation Information reporting Active waste site disposal operation Conversion operations § 61.140 – Applicability(cont.)

14. 40 CFR § 61.141 Definitions • Adequately wet • Asbestos • Asbestos-containing waste materials • Category I nonfriable ACM • Category II nonfriable ACM • Demolition • Emergency renovation • Facility • Friable asbestos material • Glove bag • Inactive waste disposal site • In poor condition • Installation • Leak-tight • Natural barrier • Outside air • Owner or operator • Regulated asbestos-containing material • Renovation • Visible emissions • Waste shipment record • Working day Selected definitions to be highlighted in the course.

15. Adequately wet To sufficiently mix or penetrate with liquid to prevent the release of particulates EPA 340/1-90-019

16. Asbestos • Serpentine (chrysotile) • Amphiboles • Riebeckite (crocidolite) • Cummingtonite-grunerite (amosite) • Anthophyllite • Actinolite-tremolite

17. Asbestos-Containing Waste Materials ACWM – waste containing commercial asbestos generated by a source regulated by the NESHAP • Friable asbestos waste material • Control device filters • Contaminated bags/packaging • Contaminated materials; e.g., disposable equipment and clothing

18. … asbestos-containing packings, gaskets, resilient floor covering, and asphaltic roofing products containing >1% asbestos … Category I Nonfriable ACM

19. … any material excluding Category I nonfriable ACM containing >1% asbestos … Category II Nonfriable ACM TM

20. Demolition • The wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations • The intentional burning of any facility

21. An unplanned, sudden, unexpected event that could, if not immediately attended to: present a safety or public health hazard damage equipment impose an unreasonable financial burden Emergency Renovation Operation

22. Any institutional, commercial, public, industrial, or residential structure, installation or building Excludes residential buildings with ≤ 4 dwelling units Ships - common interpretation – commercial vessels, not pleasure craft Active or inactive waste disposal sites Previously regulated structures regardless of current use Facility

23. Sec. 10 Friable Asbestos Material • > 1% asbestos • When dry, can be crumbled, pulverized, or reduced to powder by hand pressure • If <10%, verify with point counting using polarized light microscopy (PLM)

24. Sealed compartment Attached inner gloves Allows handling of ACM inside work area enclosures Glove Bag

25. A disposal site where no ACWM has been deposited within the past year. Inactive Waste Disposal Site

26. … the binding of the material is losing its integrity … peeling, cracking or crumbling … In Poor Condition

27. Any building or structure or any group of buildings or structures at a single demolition/renovation site that are under the control of the same owner or operator (or owner or operator under common control) Installation

28. Solids or liquids cannot escape or spill out Dust-tight Leak-Tight

29. Natural object that precludes or deters access Lakes or other large bodies of water Deep/wide ravines and cliffs Mountains The remote nature of a site DOES NOT constitute a natural barrier Natural Barrier

30. A material with >1% asbestos that, when dry, cannot be crumbled, pulverized or reduced to powder with hand-pressure Nonfriable ACM

31. Air outside buildings and structures This includes air under bridges at open-air ferry docks Outside Air

32. Owner or Operator A person who owns leases, operates, controls or supervises: • a facility being demolished or renovated and/or • a demolition or renovation operation

33. RACM Regulated Asbestos Containing Material • Friable ACM • Category I nonfriable ACM which has become friable • Category I nonfriable ACM which has been/will be sanded, ground, cut or abraded • Category II nonfriable ACM which has a high probability to become or has become friable Note: Some local/state programs define RACM more stringently; e.g., wallboard joint compound can be regulated as RACM.

34. Altering a facility or one or more facility components in any way Includes stripping or removal of RACM from a facility component Renovation

35. Emissions coming from RACM or ACWM that are visually detectable without the aid of instruments Excludes condensed uncombined water vapor Visible Emissions

36. Must originate with, and be signed by, the waste generator Tracks and substantiates disposition of ACWM See Figure 4-4 in the student manual. Waste Shipment Record

37. Weekdays – Monday through Friday Includes holidays falling on weekdays Working Day

38. 40 CFR § 61.145Standard for Demolition and Renovation • § 61.145(a) - Applicability • § 61.145(b) – Notification requirements • § 61.145(c) – Emission control

39. § 61.145(a) Applicability • Depends on presence, amounts and condition of asbestos in the facility • Determined by a THOROUGH INSPECTION of the affected facility or part of the facility for the presence of asbestos including Category I & II nonfriable ACM

40. Demolitions/Renovations • 260 linear feet on pipes • 160 square feet on other facility components • 35 cubic feet of facility off facility components where the length or area cannot be measured Note: Some local/state programs may have more stringent thresholds than those found in the NESHAP

41. Measurements • Don’t just count the pieces! • 2 halves = 1 length • Improper measurements and calculations can result in inaccurate determinations of compliance status

42. § 61.145(b) Notification Requirements • Notification responsibility • Notifications timing • Notification content

43. Demolition Thresholds Amount or TypeRequirements 260/160/35 Notification, emission control procedures <260/160/25 Notification (or no asbestos) Ordered Notification, emission control procedures

44. Demolition Notifications • Notifications are required for ALL demolitions, whether asbestos is present or not including demolishing a building, taking out load-bearing structure, or burning. • Regulatory agencies should be consulted about handling ACM from burned or partially burned buildings. • Requirements can vary significantly from one jurisdiction to the next.

45. Renovation Thresholds Amount or TypeRequirements >260/160/35 Notification, emission control procedures <260/160/35 None Planned … individual Notification, emission non-scheduled control procedures Emergency Notification, emission control procedures

46. Renovation Notifications • Renovation notification required if the following quantities are exceeded: • 260 linear feet (LF) for pipes (TSI etc.) • 160 square feet (SF) on other facility components (fireproofing, etc.) • 35 cubic feet (CF) taken from facility components where the length or area cannot be measured. • Some local/state programs have more stringent notification thresholds than those found in the NESHAP.

47. The owner or operator must: provide written notification update notification if scope of work changes; e.g., > 20% % change in amount of ACM properly deliver notice U.S. Postal Service postmark Commercial delivery service Hand delivery provide required information Notification Responsibility

48. Notification Timing – Demo/Reno • All demolitions with or without asbestos • 10 working days • Renovations • < 260/160/35 – notification not required • > 260/160/35 • Normal - 10 working days • Planned and involving individual nonscheduled operations – 10 working days before end of the year (annual notifications) • Ordered demolitions and emergency renovations • As early as possible before, but not later than, the following working day

49. Notification Timing - Updates • Later starting date • Notify via telephone ASAP • Notify in writing no later than the original starting date • Earlier starting date • Notify in writing • At least 10 working days before stripping, demolition, or removal begins

50. Notification Content - General • Whether an initial or revised notification • Information on responsible parties • Whether a demolition or renovation • Description of facility or affected part • Detection/analytical procedures • Amount of RACM to be removed • Amount of nonfriable ACM to remain (demolitions)