40 CFR § 61.145 Standard for Demolition and Renovation § 61.145(a) - Applicability § 61.145(b) – Notification requirements § 61.145(c) – Emission control Introductory slide for section on demolition and renovation. These copies will be covered.

§ 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 This section begins the discussion for demolition/renovation activities. Please consult the student manual in advance of presentation if you are unfamiliar with this subject matter. This slide describes applicability. Thorough inspection; the accredited asbestos inspector should have made an effort to find all asbestos in the facility in advance of the demo/renovation work This implies that walls are opened, floors are separated (tiles under carpet) etc. No asbestos inspection is 100% perfect, but a reasonable attempt should always be made.

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 Describes thresholds that are significant to demolition and renovation operations.

Measurements Don’t just count the pieces! 2 halves = 1 length Improper measurements and calculations can result in inaccurate determinations of compliance status For regulatory inspectors, this point is important! Inaccurate measurement during inspections can invalidate compliance determinations and result in losing an enforcement case!

§ 61.145(b) Notification Requirements Notification responsibility Notifications timing Notification content Title/lead-in slide for the next 4 slides.

Demolition Thresholds Amount or Type Requirements ≥260/160/35 Notification, emission control procedures <260/160/25 Notification (or no asbestos) Ordered Notification, emission This slide defines the requirements for demolitions.

Demolition Notifications Notifications are required for ALL demolitions, whether asbestos is present or not including demolishing a building, taking out load-bearing structural member, 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. The notifications are most often sent to a designated local or state asbestos program. Notifications must be provided for all demolitions. It is important for regulatory agencies to know that an asbestos inspection has been performed. Demolitions can involve more than just razing a building. Burning of a building/structure may require additional notices and permits from local or state authorities (forestry, fire department, etc.) All ACM must be removed prior to demolition, including burning. For partially burned buildings, the regulatory agency may have to advise the facility owner of its requirements for handling ACM, since the requirements vary from one jurisdiction to the next.

Renovation Thresholds Amount or Type Requirements >260/160/35 Notification, emission control procedures <260/160/35 None Planned … individual Notification, emission non-scheduled control procedures Emergency Notification, emission This slide defines the requirements for renovations.

Renovation Notifications Renovation notification required if the following quantities are met or 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. Notification of renovation is required

Notification Responsibility The owner or operator must: provide written notification update notification if scope of work changes; e.g., > 20% change in amount of RACM properly deliver notice U.S. Postal Service postmark Commercial delivery service Hand delivery provide required information Most often notifications are sent in on behalf of the property owner by the asbestos removal contractor. In many local/state programs, the demolition contractor also has to send in a separate notification even if the asbestos contractor has done so. All information on forms must be present. Of primary importance is information on asbestos inspections and planned work schedules. Improperly filled out forms are most often rejected by regulatory agencies. Many large entities that have scheduled work throughout the year file annual notifications. Local/state programs often vary on how this is accomplished and the necessity to re-notify (often without additional fees) when the work is to commence.

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 Notifications are required for all demolitions regardless of whether asbestos may be present or not. They must be made 10 days in advance. Renovations involving less than 260/160/35 do not require notification. 10-day notifications are required for other renovations.

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 Discuss notification requirements when changes in the original work schedule are made. Earlier work dates reset the 10 day waiting period. Expectations of most regulatory agencies are very clear on this issue.

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) It is up to the entity providing the notification(s) to properly submit updates. Many local/state programs will cite contractors if they arrive on site and conditions do not match the original notification information. Also, many agencies specifically require separate notifications from the asbestos removal contractor and the demolition contractor.

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 Additional notification contents listed on slide.

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. Describe notification requirements when changes are made in project scope and schedule. NOTE: Electronic notification is permitted under the Cross Media Electronic Reporting and Recordkeeping Rule. 40 CFR 3.2000 Identifies the 6 key components any electronic system must have. Before a State begins building a web-based system, it needs to be reviewed and approved by EPA. Once approved, the State can establish the system.

Notification Content Ordered Demolitions Name, title, authority of government representative Date order issued Date demolition will begin Copy of order An ordered demolition is one ordered by a government entity.

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!! An ordered demolition is one ordered by a government entity. Often contractors (demolition and asbestos removal companies) find themselves in a time bind, but this does not constitute an emergency. “Poor planning on their part does not constitute an emergency on our part!” Agencies can allow for emergencies, but it’s their call, not the contractor’s!

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. The NESHAP was written before newer notification technologies were employed and specifies only three notification methods. Some agencies today are using more efficient approaches including e-mail and on-line notification templates. States can implement Internet based Notification submissions so long as the system has been reviewed and approved by EPA under the Cross Media Electronic Reporting and Recordkeeping (CROMERR) rule. Agencies must meet the minimum requirements and intent of the NESHAP in whatever systems are designed.

§ 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 This slide details lists expectations and special circumstances that are covered in the NESHAP.

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. This slide details removal requirements. Many agencies are very conservative with the judgment of Category I & II friability during demolition/renovation. Often all materials have to be removed in advance as most materials become friable during demolition and often during renovation.

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. This slide details exceptions to removal requirement.

Encased in Concrete Insulation may be applied to structural members before the floor is poured Asbestos is inaccessible Insulation may be found in areas that are virtually inaccessible such as around steel structural beams where concrete has been subsequently poured.

Double Wall Pipes may be hidden by walls Asbestos in such cases IS NOT inaccessible! It is very common when demolishing large pipe systems to wrap pipes with 2 layers of 6 mil sheet plastic, remove ACM (often by glovebags) at the 2 ends and then cut the pipe down with the remaining ACM intact. Many State/Local programs also require that these “bundles” need to be labeled in the same manner as asbestos waste bags

Unit or Section Removal Adequately wet all RACM exposed during cutting/disjoining operations Carefully lower unit/section to floor and to ground level Special requirements for wetting and handling of RACM in unit and section removal. Be sure to make the wetting of a partition stand out. This implies the removal of a building section with ACM wet and intact. This is not common, but does occur.

Wetting Techniques Pump-up-type garden sprayer (small projects) Garden hose Hydrant source Airless paint sprayer Amended water/surfactant Use of wetting procedures is extremely important. For large asbestos removal projects, an airless paint sprayer is necessary for delivering a sufficient amount of amended water to properly wet the ACM. A sprayer with a hand pump will most likely deliver an insufficient amount of amended water for large removal projects but such a sprayer is appropriate for small projects. Surfactants are readily available in the asbestos control industry. It’s not uncommon to find asbestos removal projects where they are not mixed into the water. These chemicals aid significantly in the penetration of the liquid into the ACM and adsorption to the surface.

Wetting Illustrations Adequately wetting ACM will eliminate most emissions of asbestos fibers. Note the dust haze in the picture on the right. NOTE: Wetting alone does not mean you have complied with the requirements of the rule. If Visible Emissions are observed, it indicates that the material was not adequately wet. Not Adequately Wet Adequately Wet

Wetting Exceptions Equipment damage or safety hazard Wrapped RACM 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 EPA requires written approval in advance of work for DRY REMOVAL. Special care must be used when wetting is not feasible. Records must be maintained for cold weather removals.

Evaluation of Wetting Procedures To determine if RACM is being adequately wetted, evaluate the following as applicable: 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? This is not an official nor all-inclusive list but covers common observations used to evaluate adequate wetting.

Facility Component Covered, Coated or Contains RACM Strip Adequately wet during stripping or Use Local Exhaust Ventilation Control (LEVC) system Contain in leak-tight wrapping

Wrapped ACM Wrapping has become a standard practice for large scale It is very common when demolishing large pipe systems to wrap pipes with 2 layers of 6 mil sheet plastic, remove ACM (often by glovebags) at the two ends and then cut the pipe down with the remaining ACM intact. Many agencies also require that these “bundles” need to be labeled in the same manner as asbestos waste bags Wrapping has become a standard practice for large scale removal of pipes with ACM insulation

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

Handling of RACM Adequately wet Carefully lower to the ground/floor Use leak-tight chutes or containers if >50’ Wetting of RACM is important. Take a few minutes to explain the difficulty of wetting the wide variety of materials - hydroscopic (water absorbing, ex. fireproofing) - hydrophobic (water repelling, ex. asbestos cement)

Options to Wetting of RACM in Stripping Operations Due to Equipment Damage or Safety Hazard LEVC system; Glove bag system; or Contain in leak-tight wrapping RACM must be wetted during stripping unless one of the options noted is utilized. LEVC is also referred to more commonly as “negative air.”

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 The NESHAP requires an on-site individual trained in NESHAP requirements if RACM is being removed. Refresher training is required every two years and evidence of that training is to be posted at the job site. Some regulatory programs such as those under OSHA and in some states may be more stringent. Demolition contractors need to be trained, even if there is no asbestos on a specific site. They need to know the NESHAP requirements and to be able to recognize and react to discovered asbestos if not originally identified in a facility survey. Training programs can be uniquely developed for these purposes but often these individuals attend a approved 5-day asbestos contractor/supervisor courses. Fraudulent training certificates are commonly found in the US, especially at the worker and supervisor level.

Job Board Companies should have a record of notifications, certifications and accreditations posted at their places of business indicating that training is up-to-date.

Special Demolitions Ordered Demolitions Intentional Burning 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 Define terms. Intentional burns – all ACM must be removed. Some agencies allow wallboard/joint compound composite results to deem the wall system less <1%. Others may not! Fire department staff may have had little or no training about hazards such as asbestos. Many times, fire departments will conduct “practice burns” or “bona fide fire training” as a convenience to a building owner who is wanting to get rid of a building without having to dispose of the materials at considerable cost. Fire departments will notify agencies that they are conducting fire training, but it may be elective and not required. Agencies have the ability to prohibit such burning in many cases.

Alternative Asbestos Control Method Work to develop an alternative asbestos control method (AACM) was underway starting in 1999 through 2010. This is not an approved EPA method Demolitions purported to be using the AACM are subject to enforcement action and resulting fines There is no approved method of asbestos removal apart from the methods described in the Asbestos NESHAP The Alternative Asbestos Control Method (AACM) was an EPA research effort to evaluate whether certain ACM’s could remain in place during building renovation and demolition (above and beyond what is currently permitted in the Asbestos NESHAP – good condition Category I nonfriable materials). This was never adopted as regulation and therefore is not a permissible practice.