1 Asbestos NESHAP Inspection and Safety Procedures Course
Chapter 4 Asbestos NESHAP Regulation Version 2012.1
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2 Topics Introduction History Asbestos NESHAP 40 CFR Part 61,
Subpart M Appendix A Roof Removal Operations
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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
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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
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5 Asbestos NESHAP Overview Examples of substances regulated by
EPAs NESHAP program: Asbestos Benzene Chlordane Formaldehyde Future
references to the NESHAP in this course mean the asbestos
NESHAP
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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
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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
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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
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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
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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
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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
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12 61.140 - Applicability Asbestos mill operations Roadway
surfacing Product manufacturing Demolition/renovation operations
Spraying of ACM Fabricating operations Use of insulating
materials
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13 61.140 Applicability (cont.) 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
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14 40 CFR 61.141 Definitions 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 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
Selected definitions to be highlighted in the course.
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15 Adequately wet To sufficiently mix or penetrate with liquid
to prevent the release of particulates EPA 340/1-90-019
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
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18 Category I Nonfriable ACM asbestos-containing packings,
gaskets, resilient floor covering, and asphaltic roofing products
containing >1% asbestos
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19 Category II Nonfriable ACM any material excluding Category I
nonfriable ACM containing >1% asbestos TM
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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
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21 Emergency Renovation Operation 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
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22 Facility 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
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Sec. 10 23 Friable Asbestos Material > 1% asbestos When dry,
can be crumbled, pulverized, or reduced to powder by hand pressure
If
30 Nonfriable ACM A material with >1% asbestos that, when
dry, cannot be crumbled, pulverized or reduced to powder with
hand-pressure
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31 Outside Air Air outside buildings and structures This
includes air under bridges at open-air ferry docks
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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
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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.
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34 Renovation Altering a facility or one or more facility
components in any way Includes stripping or removal of RACM from a
facility component
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35 Visible Emissions Emissions coming from RACM or ACWM that
are visually detectable without the aid of instruments Excludes
condensed uncombined water vapor
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36 Waste Shipment Record Must originate with, and be signed by,
the waste generator Tracks and substantiates disposition of ACWM
See Figure 4-4 in the student manual.
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37 Working Day Weekdays Monday through Friday Includes holidays
falling on weekdays
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38 40 CFR 61.145 Standard for Demolition and Renovation
61.145(a) - Applicability 61.145(b) Notification requirements
61.145(c) Emission control
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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
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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
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41 Measurements Dont just count the pieces! 2 halves = 1 length
Improper measurements and calculations can result in inaccurate
determinations of compliance status
43 Demolition Thresholds Amount or TypeRequirements
260/160/35Notification, emission control procedures
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44 Demolition Notifications Notifications are required for ALL
demolitions, whether asbestos is present or not i ncluding
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.
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45 Renovation Thresholds Amount or TypeRequirements
>260/160/35Notification, emission control procedures
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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.
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47 Notification Responsibility 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
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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
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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
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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)
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51 Notification Content - General (cont.) Facility
address/worksite location Starting/completion dates (removals,
demolitions, renovations) Planned demolition/renovation work Work
practices/engineering controls Waste disposal site information
Supervisor certification statement Procedures for dealing with
unexpected RACM
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52 Notification Content Updates Name of contractor (operator)
Start date and finish dates Amounts of RACM, Category I or Category
II Any other substantive changes Note: Some local/state programs
have more detailed notification requirements. Note: Some agencies
are now developing on-line capabilities for notifications and
change notices.
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53 Notification Content Ordered Demolitions Name, title,
authority of government representative Date order issued Date
demolition will begin Copy of order
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54 Notification Content Emergency Renovations Date and hour
emergency occurred Description of emergency event Description of
circumstances Unsafe condition Equipment damage Unreasonable
financial burden Note: Poor planning IS NOT an emergency!!
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55 Notifications - Miscellaneous Some local/state programs may
have more detailed notification requirements. Some agencies are now
developing on-line capabilities for notifications and change
notices. Adherence to minimum requirements of the original NESHAP
is still required with any modern systems that are deployed.
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56 61.145(c) Emission Control Removal of ACM Removal of
units/sections Stripping from in- place component Treatment of
removed units/sections Treatment of large facility components
Handling of RACM Below freezing temperatures Training requirements
Special demolitions
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57 Removal of ACM All RACM must be removed from a facility
being demolished or renovated before any activity begins that would
break up, dislodge, or similarly disturb the material or preclude
access to the material for subsequent removal.
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58 Exceptions to Removal Requirement Ordered demolition
structurally unsound, danger of imminent collapse, etc. Cat I NF
not in poor condition, not friable Cat II NF low probability of
becoming RACM Encased in concrete Not accessible for testing Found
at demolition Note: All asbestos-contaminated wastes from the
bottom two bullets are treated as ACWM.
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59 Encased in Concrete Insulation may be applied to structural
members before the floor is poured Asbestos is inaccessible
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60 Double Wall Pipes may be hidden by walls Asbestos in such
cases IS NOT inaccessible!
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61 Unit or Section Removal Adequately wet all RACM exposed
during cutting/disjoining operations Carefully lower unit/section
to floor and to ground level
63 Wetting Illustrations Adequately Wet Not Adequately Wet
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64 Wetting Exceptions Equipment damage or safety hazard Request
written approval Use of emission control methods local exhaust
ventilation glove bag leak-tight wrapping Wrapped RACM Below
freezing temperatures Unit/section removal to maximum extent Record
temperatures Retain records for two years
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65 Evaluation of Wetting Procedures Is an amended water supply
on site/in use? Is water being applied to the material? Is
condensation visible in the waste bag? Is water visible in the
waste bag? Does the waste bag feel heavy? Does the bag feel cool?
Does the material look wet? Does the material feel wet? To
determine if RACM is being adequately wetted, evaluate the
following as applicable:
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Treatment of Removed Units/Sections Strip Adequately wet during
stripping or Use LEVC system Contain in leak-tight wrapping 66
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67 Wrapped ACM Wrapping has become a standard practice for
large scale removal of pipes with ACM insulation
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Exemptions from Stripping (Large Facility Components) Remove,
transport, store, dispose of, or reuse without disturbing or
damaging RACM AND Encase component in leak-tight, properly labeled
wrapping during loading, unloading, and storage 68
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69 Handling of RACM Adequately wet Carefully lower to the
ground/floor Use leak-tight chutes or containers if >50
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70 Options to Wetting of RACM in Stripping Operations Local
exhaust ventilation control system (LEVC); Glove bag system; or
Contain in leak-tight wrapping
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71 Training Requirements NESHAP At least one on-site individual
trained in the provisions of NESHAP is required if RACM is to be
stripped, removed, handled, or disturbed Refresher training every 2
years Evidence of training posted at job site OSHA and states may
be more stringent Fraudulent training programs are a national
problem! A trained on-site person is recommended regardless of
confirmed presence of asbestos
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Job Board 72
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73 Special Demolitions Ordered Demolitions Keep affected
portions of facility containing RACM adequately wet during
demolition Intentional Burning Remove all RACM including Categories
I and II nonfriable ACM before burning Common deficiency during
fire department training Fire personnel are often not trained in
pre-burn NESHAP requirements Building owners may not want to remove
ACM
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74 61.150 Waste Disposal 61.150(a) Visible Emissions 61.150(b)
Deposition of ACWM 61.150(c) Vehicle Marking 61.150(d) Offsite
Transport
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75 ACWM Waste Disposal Friable asbestos waste material RACM
waste material Contaminated packaging or bags Materials
contaminated with asbestos Control device filters
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76 Visible Emissions Control Discharge no visible emissions to
the outside air during collection, processing, packaging or
transporting of ACWM OR Use one of the following control methods
Adequately wet ACWM Process ACWM into nonfriable forms Use an
approved emission control alternative
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77 Wetting Procedures for ACWM Mix control device waste to form
a slurry Adequately wet other ACWM Ensure no visible emissions
discharged to outside air Seal wetted ACWM into leak-tight
containers or wrapping Label packaged waste with OSHA warning label
For offsite waste disposal, attach generator label (name of
generator, location of waste generation) RACM not removed before
demolition adequately wet ACWM at all times after demolition keep
wet during handling and loading for transport leak-tight
containers/wrapping not required
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78 Waste Containerization Leak-tight: Means that solids or
liquids cannot escape or spill out. It also means dust-tight.
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79 Labeling 3 labels on each bundle/bag: 1. OSHA Danger 2. DOT
(NA 2212) 3. EPA Waste Generator Label For bundles; adhesive labels
Lack of Generator labels is an often cited violation! Typical waste
bag seen on asbestos control projects
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80 Disposal of ACWM Disposal of ACWM is required as soon as
practical Asbestos is not regulated like hazardous waste; i.e., no
holding time limits, etc. ACWM must be deposited at an appropriate
waste disposal site or conversion site Most states have landfills
that are approved for asbestos many are municipal solid waste (MSW)
landfills Conversion technology exists but is rarely used due to
cost
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81 Vehicle Marking Required only during loading and unloading
Visible signage may include: OSHA danger signs Red barrier tape Is
this legal?
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82 Vehicle Marking Is this legal? Required sign
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83 Off-site Transport Generator must maintain waste shipment
records (WSRs) at least two years Transporter must provide WSR to
disposal site upon arrival If WSRs are not returned within 35 days,
generator must make inquiries to the transporter or disposal
facility. If WSRs are not returned after 45 days, generator must
notify the asbestos NESHAP enforcement agency responsible for waste
generators and advise of missing records.
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84 61.153 Source Reporting Requirements 61.153(a) New and
existing sources 61.153(b) Active waste disposal sites (WDSs)
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85 Source Reporting Requirements 61.153(a) New and Existing
Sources Report within 90 days of startup Provide: description of
control equipment for each process. filter specifications other
information as applicable Note: These requirements do not apply to
demolition/renovation sources.
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86 Source Reporting Requirements 61.153(b) Active Waste
Disposal Sites Owner/operator name and address Source location
Hazardous pollutants emitted Method of operation of stationary
source Average weight of asbestos processed per month for past 12
months
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87 61.154 Active Waste Disposal Sites 61.154(a-d)Site operation
61.154(e) Site operation recordkeeping and reporting (R&R)
61.154(f-h)Site closure R&R 61.154(i)Record availability
61.154(j)Excavation notification
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88 Waste Disposal Site Operation No visible emissions 61.154(a)
Six inch cover of compacted non-asbestos-containing material within
24-hr period 61.154(c)(1) Cover with a resinous petroleum- based
dust suppression agent within 24-hr period 61.154(c)(2) Alternate
control method receiving prior approval 61.154(d) Warning signs and
fencing Natural barrier that deters public access Warning signs and
fencing Natural barrier that deters public access Natural barrier
that deters public access Warning signs and fencing OR AND
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89 Active Waste Disposal Sites Site Operation Recordkeeping and
Reporting Maintain waste shipment records Notify regarding any
improperly enclosed or uncovered waste ASAP, but not later than 30
days after receipt of waste, send WSR to generator Resolve
discrepancies within 15 days Retain records and reports at least 2
years
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90 Active Waste Disposal Sites Site Closure Recordkeeping and
Reporting Maintain records of location, depth/area, quantity of
ACWM Comply w/closure provisions Submit records to
Administrator
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91 Active Waste Disposal Sites Record Availability Furnish
records upon request Make available during normal business
hours
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92 Active Waste Disposal Sites Requirements for notification of
disturbance of interred ACWM Notify 45 days before disturbance
Provide projected start and completion dates Provide reasons for
the disturbance Provide emission control methods to be used Provide
locations of temporary and final disposal site(s) Note:
Administrator can require changes in emission controls
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93 61.151 Inactive Waste Disposal Sites 61.151(a) Site
operation 61.151(b) Site demarcation 61.151(c) Control alternatives
61.151(d) Excavation notification 61.151(e) Deed notation
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94 Inactive Waste Disposal Sites Inactive Site Operation
Options Discharge no visible emissions to the outside air OR Cover
ACWM with: 6 of compacted non-ACM and maintain vegetative cover or
2 feet of compacted non-ACM and provide continuing maintenance OR
Use resinous or petroleum-based suppressant or other approved
agent
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95 Inactive Waste Disposal Sites Deed notation File within 60
days of site inactivation Describe land used for ACWM disposal
Provide survey plot, record of location and quantity of ACWM
disposed Note that site is subject to asbestos NESHAP
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96 Inactive Waste Disposal Sites Excavation notification Notify
45 days before disturbance Advise of starting and completion dates
Provide explanation of purpose of excavation Describe emission
control methods used/in use Identify locations of temporary and/or
final disposal sites
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97 61.157 Delegation of Authority Authorities retained by the
EPA Administrator and not delegated to states
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98 Interpretive Rule Governing Roof Removal Operations
(Appendix A to Subpart M) Applicability Notification Emission
Control Practices Waste Disposal
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99 Category I Nonfriable Asbestos- Containing Roofing Material
Use of a rotating blade (RB) roof cutter to remove at least 5,580
SF of roofing subjects activity to NESHAP Smaller removals and
those using equipment that does not create RACM are not subject to
the NESHAP Photo provided by Panther East Contractor Tools &
Equipment
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100 Roof Removal Issues Asbestos-cement (A/C) shingles and
other Cat II nonfriable ACM SUBJECT if removal method will crumble,
pulverize or reduce to powder or contaminate with RACM an area of
at least 160 SF NOT SUBJECT if methods are used that do not create
RACM and materials are properly handled
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101 Roof Removal Issues- Summary Roof blade cutters SUBJECT
Methods that do not create RACM NOT SUBJECT Power removers and
tear-off machines NOT SUBJECT
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102 Roof Removal Notifications Are notifications required?
Demolitions YES Demolitions always trigger notification
requirements Many removals (including most roof removals) are
renovations rather than demolitions Renovations - Depends If manual
methods or slicing of Category I NO If Category II (RACM not
anticipated) NO If a RB cutter is used and meets applicability and
threshold amounts (5,580 SF) YES
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103 Roof Removal Issues Emission control requirements and
exemptions for regulated roof removal operations Adequately wet, no
visible emissions An RB cutter equipped with a blade guard AND
functioning spray mechanism meets these requirements Wetting
exemptions Building structure damage, building equipment damage and
safety hazards require written approval Freezing temperature
requires recordkeeping Alternative control methods are
required
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104 Roof Removal Issues Waste collection and handling No RACM
generated - NOT SUBJECT RACM generated - SUBJECT Determination of
whether RACM is generated is key decision
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105 Is this Category I NF or RACM? Its your call!
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106 Roof Removal Issues Waste Disposal and Recordkeeping
Collected dust/debris from cutting and any contaminated roofing
squares must be taken to a compliant landfill or EPA- approved
conversion site. 61.150(b) Waste Shipment Record requirements
previously reviewed apply. 61.150(d)
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107 Roof Removal Training Onsite supervisor required for
regulated roof removal operations Supervisor MUST have: NESHAP
training Roof specific training or other courses covering areas
specified in the regulation; e.g., AHERA courses Worker training
NESHAP Not required OSHA Required Local/state agencies Sometimes
required
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108 The Asbestos NESHAP The NESHAP regulation is lengthy and
there are many interpretations - EPA, states, local agencies It
takes time and work experience to understand it all!! Read Chapter
4 of the manual. Read the NESHAP regulation. Ask questions!
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109 Further Help A Guide to Normal Demolition Practices Under
the Asbestos NESHAP EPA-340/1-92-013 September 1992 Applicability
of the Asbestos NESHAP to Asbestos Roofing Removal Projects
EPA-340-B-94-001 August 1994 Guideline for Asbestos NESHAP
Demolition and Renovation Inspection Procedures EPA-340/1-90-007
Rev. November 1990