Guide to NESHAP Regulations for Demolition and Renovations
Posted on: 2016-01-04 11:47
Asbestos Program Checklist
1. Does the building meet the definition of a “facility”?
Facility — Defined by 40 CFR Part 61, Subpart M, as any institutional, commercial, public, industrial or residential structure, installation or building (including government owned or operated). This excludes residential buildings with four or fewer dwelling units, any ship and any active or inactive waste disposal site.
2. Is the building undergoing “renovation” or “demolition” as defined by the NESHAP regulation?
Demolition — Wrecking or taking out of any load-supporting structural member of a facility together with any related handling operation or the intentional burning of any facility.
Renovation — Altering a facility or at least one facility component in any way, including the stripping or removal of regulated asbestos-containing materials (RACM).
3. Has a “thorough asbestos inspection” been conducted to determine the presence, condition and quantity of asbestos-containing materials in the building?
Survey — Examines all suspect asbestos-containing materials by having them sampled and analyzed by an approved laboratory to determine their asbestos content. The survey should be done by someone who is knowledgeable in field of asbestos, preferably trained and certified as an Asbestos Hazard Emergency Response Act (AHERA) building inspector. Materials can be assumed to be asbestos-containing if sampling and analysis are not performed; however, ADEQ recommends that a sampling and laboratory analysis be conducted.
Laboratory Analysis — Uses a microscopic method defined by the Environmental Protection Agency (EPA) in 40 CFR Appendix E to Subpart E of Part 763, Section 763.87, Polarized Light Microscopy (PLM). Accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), the laboratory identifies materials that contain greater than 1 percent asbestos.
Friable Asbestos — Any material containing more than 1 percent asbestos (as determined by PLM) that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. The inspector that conducts the sampling will determine the friability of each of the materials prior to sending to the laboratory.
4. Have the materials been categorized and quantified into one of the following?
• Regulated Asbestos-Containing Materials
• Category I (Cat I) non-friable asbestos-containing materials
• Category II (Cat II) non-friable asbestos-containing materials
5. Has a notification been submitted to ADEQ at least 10 working days prior to beginning the renovation or demolition activity?
6. Were removal procedures properly followed?
Trained Workers — Normally an asbestos contractor is used to perform asbestos removal to ensure the training requirements, worker protection measures and National Standard for Hazardous Air Pollutants (NESHAP) requirements are met as outlined by Occupational Safety and Health Administration (OSHA) workers protection measures (29 CFR 1926.1101) and NESHAP compliance (40 CFR Part 61, Subpart M).
At a minimum, this includes:
• Workers who can provide evidence of training that complies with both OSHA and NESHAP requirements.
• At least one on-site representative trained as a contractor/supervisor to comply with OSHA and NESHAP regulations.
Emission Controls — The principle controls contained in the NESHAP for removal operations include the following requirements for RACM:
• Remove an asbestos-containing materials prior to other construction activities.
• Adequately wet the material and ensure that it remains wet while being collected, contained, treated, transported and prepared for final disposal.
• Remove material by using methods that minimize disturbance or damage of RACM (normally manual methods or cutting).
• Take out components in whole units or sections without disturbing the RACM.
• Lower components to the ground without dropping, throwing, sliding or otherwise damaging the material.
• Use a local exhaust ventilation and collection system designed and operated to capture particulate asbestos materials produced during handling.
• Encase all removed materials in leak-tight wrapping.
• Discharge no visible emissions to the outside air.
Labeling, Transport and Disposal — As soon as practical, waste material must be taken to a landfill that is operated in accordance with NESHAP regulations. The waste must be properly contained in leak-tight containers and properly labeled for disposal.
• Label the waste material for transport with the name and location of the generator.
• Dispose the RACM only at permitted landfills.
• Use an appropriate manifest for transportation of the waste.
• Provide the completed waste manifest to ADEQ within 45 days of shipment to the waste disposal site.