1. § 61.150 – Waste Disposal § 61.150(a) – Visible Emissions
§ (b) – Deposition of ACWM
§ (c) – Vehicle Marking
§ (d) – Offsite Transport
Title slide for the next six slides.

2. ACWM Waste Disposal Friable asbestos waste material
RACM waste material
Contaminated packaging or bags
Materials contaminated with asbestos
Control device filters
ACWM - asbestos-containing waste material - essentially anything that contains, or has been contaminated by, asbestos dust and debris.
All waste materials within an asbestos removal area are ACWM.

3. 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
Visible emissions is not just a “dust cloud” but also visible debris.
Leak-tight containers for asbestos removal is often two 6-mil bags (“double bagged”). This can be an agency requirement.
Students should read this section in the course notebook and see references on the slide for additional information.

4. 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
Asbestos waste that must be kept wet is to be handled as described on this slide.

5. Waste Containerization
Leak-tight: Means that solids or liquids cannot escape or spill out. It also means dust-tight.
See slide text.
Maintaining leak-tight containers is a continual compliance issue.
There are no NESHAP color requirements for bags. Some agencies may have such requirements. Black bags are common. Clear bags are easier for inspectors to inspect!

6. Typical waste bag seen on asbestos control projects
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!
Most waste bags are pre-printed with the OSHA Danger label and DOT markings.
The contractor must fill in or (most commonly) affix a label to the bag with the generator info.
Bundles (waste wrapped in poly) must be individually labeled as well.
Typical waste bag seen on
asbestos control projects

7. 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
Asbestos is not “hazardous waste” and is not regulated as such.
Most states have identified landfills that are approved for asbestos deposition. Many are municipal solid waste (MSW) landfills.
Asbestos conversion is an expensive technology that is rarely encountered. Conversion costs are high.

8. Vehicle Marking Required only during loading and unloading
Visible signage may include:
OSHA danger signs
Red barrier tape
When trucks, dumpsters etc. are loaded/unloaded, a regulated area should be established during the activity.
Is this legal?

9. Vehicle Marking Required sign Is this legal?
Vehicle signage does not need to be present during the movement of the vehicle (unless required by a local or state jurisdiction).
The sign on the right represents the correct signage.
Required sign
Is this legal?

10. 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.
Completed WSR’s must be in the owner’s files within 35 days. If not, the owner should make inquiries.
If owner does not receive WSR within 45 days, owner must notify State/EPA in writing.

11. § 61.153 Source Reporting Requirements
§ (a)
New and existing sources
§ (b)
Active waste disposal sites (WDSs)
Title slide. Further information on next two slides.

12. 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.
This is a section of the NESHAP that applies to stationary manufacturing sources of asbestos.
The average inspector rarely would encounter compliance issues related to this requirement today.
See the student notebook and the regulation for further information.

13. 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
Requirements on previous slide apply to active waste disposal sites.

14. § 61.154 – Active Waste Disposal Sites
§ (a-d) Site operation
§ (e) Site operation recordkeeping and
reporting (R&R)
§ (f-h) Site closure R&R
§ (i) Record availability
§ (j) Excavation notification
Recordkeeping and reporting information is on the next three slides.

15. Waste Disposal Site Operation
Warning signs and fencing
AND
No visible emissions
§61.154(a) OR
Natural barrier that deters
public access OR
Six inch cover of compacted
non-asbestos-containing material
within 24-hr period
§61.154(c)(1) OR
Warning signs and fencing
Cover with a resinous petroleum-
based dust suppression agent within 24-hr period
§61.154(c)(2)
AND OR
This slide explains issues with operating asbestos waste sites.
Follow the flow chart with students.
“Natural barrier” is defined in earlier in the presentation.
Natural barrier that deters
public access OR
Warning signs and fencing
Alternate control method receiving
prior approval
§61.154(d)
AND OR
Natural barrier that deters
public access

16. 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
R&R recordkeeping and reporting requirements for active waste disposal sites.
Go over bullets.

17. 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
Disposal site recordkeeping and reporting.
Go over points on slide.

18. Active Waste Disposal Sites
Record Availability
Furnish records upon request
Make available during normal business hours
Disposal site record availability.
Go over points on slide.

19. 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
This slide applies to the disturbance or relocation of buried (interred) ACWM.
Go over points.

20. § 61.151 Inactive Waste Disposal Sites
§ (a) – Site operation
§ (b) – Site demarcation
§ (c) – Control alternatives
§ (d) – Excavation notification
§ (e) – Deed notation
Summary of inactive waste disposal site requirements covered in next two slides.

21. 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
Discuss slide bullets.

22. 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
Briefly go over points on slide.

23. 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
Briefly go over points on slide.

24. § 61.151 Conversion of RACM and ACWM to Nonasbestos (asbestos-free)
Two processes have been approved by EPA:
ABCOV, New York (proprietary mixture of several strong acids mixed over time).
ARI Technologies, Inc., Washington (a vitrification-like process).
Both processes were reviewed and approved in the late 1990s.
ABCOV is the most visible. The company has been working in the mid-Atlantic states for the past 10+ years.
ARI Technologies not widely known or used. The company has recently made itself known to clean-up sites in PA and MA.

25. § 61.157 Delegation of Authority
Authorities retained by the EPA Administrator and not delegated to states
Briefly summarize.
These sections are enforced by the EPA and are not delegable to states.

26. Interpretive Rule Governing Roof Removal Operations (Appendix A to Subpart M)
Applicability
Notification
Emission Control
Practices
Waste Disposal
The next series of slides deal with roofing issues.

27. 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
Roofing materials are defined in the NESHAP as Category I nonfriable asbestos-containing materials.
Historically there were many questions regarding the handling of ACM roof removal.
This slide addresses the common use of rotating blade cutting devices.
This device cuts roofing materials into more easily handled “blocks” or “squares.”
EPA has determined that removing more than 5,580 SF of roofing using an RB creates 160 SF of RACM.
Photo provided by Panther East
Contractor Tools & Equipment

28. 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
If Category II materials become friable, they are subject to the standard by effectively having become RACM.
If handled in a nonfriable manner, the roofing is not subject to the NESHAP.
These materials are very heavy!
If not lowered to the ground carefully, they will shatter and become RACM.

29. Roof Removal Issues- Summary
Roof blade cutters –
SUBJECT
Methods that do not create RACM –
NOT SUBJECT
Power removers and tear-off machines –
Note! These summary points are EPA positions on enforcing the NESHAP..
Local/state agencies may establish more stringent applicabilities.
The significant in this case and so many others is, “when does a material become friable?”

30. 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
Notification applicability is different for demolitions compared to renovations.
Some local/state agencies consider roof removal activities to be demolitions and some have differing requirements for renovations.

31. 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
When a roof blade cutter is used, wetting should occur or a HEPA vacuum should be used.
If waste is RACM, waste needs to be containerized. A lined, labeled dumpster or individual bagging with applicable labeling may be used.
Wetting may not be required with written approval of the likelihood of significant building structure or equipment damage or if freezing temperatures are encountered.

32. Roof Removal Issues Waste collection and handling
No RACM generated - NOT SUBJECT
RACM generated - SUBJECT
Determination of whether RACM is generated is key decision
There are a number of criteria on when RACM is generated. Such determinations vary from agency to agency and sometimes from inspector to inspector.
It is important for compliance personnel to follow agency legal and policy advice on such issues.

33. Is this Category I NF or RACM?
If you climb a ladder and find this on the roof of a building, what would your compliance determination be?
Unfortunately this scenario is not uncommon.
Allow a brief time for group discussion.
It’s your call!

34. 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. § (b)
Waste Shipment Record requirements previously reviewed apply. § (d)
Additional ACM roof issues.
Dust, debris and contaminated squares are subject to waste disposal requirements.
Waste shipment records must be kept as previously explained.

35. 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
In most cases, supervisors will have to have taken 5-day approved contractor/supervisor training.
Workers are required to have training by OSHA. Such training will be, at a minimum, eight hours.
Some local and state agencies require approved 4-day worker training.
See student manual for more details.

36. 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!
This section was presented as an overview of this regulation.
The asbestos NESHAP is very detailed and it is not possible to cover all of the requirements and interpretation issues in the time alloted.
It behooves regulatory staff to read the regulation, related guidance documents, and the student manual.
On-the-job experience is irreplaceable.
Asking questions of more experienced staff, attorneys, and agency management will help with learning specific requirements that apply within your jurisdiction.

37. Further Help
A Guide to Normal Demolition Practices Under the Asbestos NESHAP
EPA-340/ September 1992
Applicability of the Asbestos NESHAP to Asbestos Roofing Removal Projects
EPA-340-B August 1994
Guideline for Asbestos NESHAP Demolition and Renovation Inspection Procedures
EPA-340/ Rev. November 1990
These guidance documents are helpful and should be kept at hand or bookmarked on your computer.

38. QUESTIONS?
If there are a variety of local, state, and/or federal agency staff in attendance, and if time allows, a discussion of program and interpretation differences would be beneficial to the group.