Asbestos NESHAP Inspection and Safety Procedures Course

Asbestos NESHAP Inspection and Safety Procedures Course
Chapter 4 Asbestos NESHAP Regulation The instructor must have an excellent working knowledge of the asbestos NESHAP regulation. To prepare for teaching the topic, instructors should review the regulation, Chapter 4 of the student manual, and these slides. If there are a variety of local, state, and/or federal agency staff in attendance, and if time allows, brief discussions of program and interpretation differences would be beneficial to the group as different topics are presented. Instructors should take questions throughout the presentations but should keep the course on schedule and not allow too much deviation from the agenda. Version

Topics Introduction History Asbestos NESHAP 40 CFR Part 61, Subpart M
Appendix A – Roof Removal Operations Title slide for this section.

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 Chapter 4 breaks down the regulation by section to illustrate the main points that inspectors should know to conduct asbestos NESHAP inspections. All students should have at least some elementary knowledge of the regulation. However, be prepared for the possibility that one or more students may not have been exposed to the regulation nor may they have taken the suggested prerequisite self-instructional course. Inspectors must read and understand the regulation to be fully effective on the job.

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 The CAA is the enabling statute for the asbestos NESHAP regulation Statute; the law…Regulations; the language drafted by the Agency (with public participation; comment periods, public meetings) to explain to the public how to meet the law

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 There are “NESHAP” regulations for many substances. We refer to the NESHAP regulation that regulates asbestos as the “asbestos NESHAP.” For simplicity here, this program is about asbestos, so when we say NESHAP here, we are inferring the asbestos NESHAP.

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 See slide bullets. Describe each. Each point will be addressed in this chapter.

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 Continuation slide. Continue description of bullets.

NESHAP Information Asbestos NESHAP policy information:
Applicability Determination Index (ADI) Stationary source compliance/guidance Technology Transfer Network (TTN) These sites are excellent sources for clarification letters and other items to help the inspector know how the regulation has been interpreted over the years.

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 Significant dates in the asbestos NESHAP.

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 Continuation slide. Significant dates in the asbestos NESHAP

Asbestos NESHAP Sections
§ Applicability § Definitions § – Standard for Demo/Renovations § – Waste disposal § – Inactive waste disposal sites § – Source reporting requirements § – Active waste disposal sites § – Delegation of authority Sections within the regulation. The symbol § is for “section,” in this case, the specific section of 40 CFR (Code of Federal Regulations) Part 61 Subpart M.

§ 61.140 - Applicability Asbestos mill operations Roadway surfacing
Product manufacturing Demolition/renovation operations Spraying of ACM Fabricating operations Use of insulating materials This slide shows how the NESHAP applies (“applicability”) to asbestos-related issues. Some of these issues such as mill operations and spraying of ACM are not frequently encountered today. Check mark/gold colored items denotes sections we’ll discuss during this program

§ 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 Continuation slide. ACWM - asbestos containing waste materials

Selected definitions to be highlighted in the course.
40 CFR § 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 from the NESHAP will be addressed. Note for “definitions” slides … these are very brief descriptions of terms. Many of these terms will be used later in this Chapter and in the remainder of the course. Selected definitions to be highlighted in the course.

Adequately wet To sufficiently mix or penetrate with liquid to prevent the release of particulates “Surfactant” is a mixture of chemicals and water designed to assist in absorption and adsorption. Water containing surfactants is sometimes referred to as “amended water.” Note the document number on the EPA document photo. Though out of print, it can be found on EPA web sites. This is a guidance document, not a regulation. This means that there can be some flexibility in use, depending on the circumstances of a particular situation. EPA 340/

Asbestos Serpentine (chrysotile) Amphiboles Riebeckite (crocidolite)
Cummingtonite-grunerite (amosite) Anthophyllite Actinolite-tremolite The regulated asbestos minerals as found in the NESHAP.

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 The acronym ACWM will be used throughout this program. Bullets describe the types of regulated wastes.

Category I Nonfriable ACM
… asbestos-containing packings, gaskets, resilient floor covering, and asphaltic roofing products containing >1% asbestos … Category I nonfriable asbestos-containing metarial definition. Be sure that students understand that the term includes these four materials. Nonfriable materials can become friable during demolition/renovation activities.

Category II Nonfriable ACM
… any material excluding Category I nonfriable ACM containing >1% asbestos … Category II nonfriable ACM is any nonfriable material other than the four types of materials listed in Category I. TM

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 Demolition is not just razing a building. See slide text. Burning a building (for example, a fire department conducting bona fide fire training - practice burns) is subject to NESHAP requirements including inspection and removal of all ACM.

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 Explain definition.

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 Explain definition.

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

Glove Bag Sealed compartment Attached inner gloves
Allows handling of ACM inside work area enclosures Briefly explain what a glovebag is and how it is used. This will be reviewed in more detail in a Chapter 8.

Inactive Waste Disposal Site
A disposal site where no ACWM has been deposited within the past year. Explain term from slide.

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

Installation 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) Explain definition. An important factor in defining an installation surrounds who is in control during NESHAP-related work – who is the owner/operator. If it is an installation, there are multiple jobs in different buildings, and a single person is in charge of the operations of the installation, that person is responsible for all work on the installation. Example: There are multiple demolition contractors working within an installation. If a noncompliance situation is identified, the demolition contractors (operator) can be cited. Ihere is a general contractor in control of the demolition contractors (operator), that person/firm can be cited and the owner that has control of the installation can be cited.

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

Natural Barrier 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 Explain definition. Natural barriers are used to protect the public from exposure. This terminology is often used in reference to public access to waste sites.

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

Outside Air Air outside buildings and structures
This includes air under bridges at open-air ferry docks Explain definition and relevance. Open air is generally assumed to be accessible to the general public. The asbestos NESHAP is designed to control asbestos emissions to the outside air, since a safe concentration of asbestos in the air has not been identified.

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 Explain definition.

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. Explain definition. It is imperative that the students have a very clear understanding of the information on this slide.

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

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

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. Most local/state programs have their own version of this form, as determined by each state. Waste hauler forms used by various waste firms like BFI and Waste Management do not replace the requirement for state/federal waste shipment records.

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

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

§ (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 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. 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. 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 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 ACM 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.

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. Adherence to minimum requirements of the original NESHAP is still required with any modern systems that are deployed. 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 and on-line notification templates. 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 concreate 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 stands 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. 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.

Treatment of Removed Units/Sections
Strip Adequately wet during stripping or Use 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
Local exhaust ventilation control system (LEVC); 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 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.

§ 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.

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.

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.

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.

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!

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

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.

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?

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?

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.

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

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.

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.

§ 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.

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

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.

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.

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

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.

§ 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.

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.

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.

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.

§ 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.

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.

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

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.

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?”

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 differomg requirements for renovations.

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.

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.

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!

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.

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.

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.

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.

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.

Asbestos NESHAP Inspection and Safety Procedures Course

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Asbestos NESHAP Inspection and Safety Procedures Course

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