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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

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

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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

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42 61.145(b) Notification Requirements Notification responsibility Notifications timing Notification content

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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

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62 Wetting Techniques Pump-up-type garden sprayer (small projects) Garden hose Hydrant source Airless paint sprayer Amended water/surfactant

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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

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110 QUESTIONS?