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      Common Questions
  On The Asbestos NESHAP
           United States
    Envrionmental Protection Agency
Office Of Air Quality Planning and Standards
  Stationary Source Compliance Division

           December 1990

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                           DISCLAIMER

This manual was prepared by Entropy Environmentalist, Inc. for the Stationary Source
Compliance Division of the U.S. Environmental Protection Agency.  It has been completed in
accordance with EPA Contract No. 68-02-4462, Work Assignment No. 90-123. This
document is intended for information purposes ONLY, and may not in any way be interpreted
to alter or replace the coverage or requirements of the asbestos National Emission Standards
for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M.  Any mention of
product names does not constitute endorsement by the U.S. Environmental Protection Agency.

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             Common Questions on the Asbestos NESHAP
         Contents      Introduction	   1




                        General Information  	   2




                        NESHAP Jurisdiction 	   3




                        Notifications	   6




                        Removal  	   9




                        Ordered Demolitions	  10




                        Friable and Non-Friable Asbestos	  11




                        Transport and Disposal  	  12



                        Monitoring and Sampling	  14



                        Inspections  	  15



                        Training	  17



                        Violations and Penalties	  17




                        NARS	  19



                        Additional Information  	  21



                        Glossary of Terms  	  22



                        AHERA and NESHAP Coordinators	  24
December 1990

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Asbestos NESHAP Questions
                 Common  Questions on the Asbestos  NESHAP
Introduction
The Clean Air Act (CAA) requires the U. S. Environmental Protection Agency (EPA) to
develop and enforce regulations to protect the general public from exposure to
airborne contaminants that are known to be hazardous to human health.  In
accordance with Section 112 of the CAA, EPA established National Emissions
Standards for Hazardous Air Pollutants (NESHAP) to protect the public. Asbestos
was one of the first hazardous air pollutants regulated under Section 112. On March
31, 1971, EPA identified asbestos as a hazardous pollutant, and on April 6, 1973,
EPA first promulgated the Asbestos NESHAP in 40 CFR Part 61.

In 1990, a revised NESHAP regulation was promulgated by EPA. Information
contained in this pamphlet is consistent with the amended regulation.

This pamphlet answers the most commonly asked questions about the Asbestos
NESHAP for demolitions and renovations. Many of the questions included in this
pamphlet have been raised by demolition and renovation contractors in recent years.
Most questions relate to how a demolition or renovation contractor or building
owner can best comply with the regulation.  The responses assume that the
questioner has a basic understanding of the Asbestos NESHAP and demolition and
renovation practices. A brief glossary of terms is also included at the back of the
pamphlet.

The Asbestos NESHAP regulations protect the public by minimizing the release of
asbestos fibers during activities involving the processing, handling, and disposal of
asbestos-containing material.  Accordingly, the Asbestos NESHAP specifies work
practices to be followed during demolitions and renovations of all structures,
installations, and buildings (excluding residential buildings that have four or fewer
dwelling units). In addition, the regulations require the owner of the building
and/or the contractor to notify applicable State and local agencies and/or EPA
Regional Offices before all demolitions, or before renovations of buildings that
contain a certain threshold amount of asbestos.

For more information about the Asbestos NESHAP or for answers to questions not
covered in this pamphlet, contact the delegated State or local agency or the
appropriate EPA Regional Office listed on page 24.
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Asbestos NESHAP Questions
General
Information
What Is the purpose of the Asbestos NESHAP regulation?

The purpose is to protect the public health by minimising the release of asbestos
when facilities which contain asbestos-containing materials (ACMs) are demolished
or renovated.
                   How much regulated asbestos-containing material (RACM) Is disposed of
                   annually from demolition/renovation operations?

                   Approximately 5.7 million cubic feet of RACM is disposed of annually. In accordance
                   with the regulation, most RACM is taken to landfills, where it is covered by soil or
                   other debris in order to keep it from releasing asbestos fibers.
                   What Is the difference between demolishing a facility and renovating It?

                   "Demolition" and "renovation" are defined in the regulation. You "demolish" a facility
                   when you remove or wreck any load-supporting structural member of that facility or
                   perform any related operations; you also "demolish" a facility when you burn it. You
                   "renovate" a facility when you alter any part of that facility in any other manner.
                   Renovation includes stripping or removing asbestos from the facility.
                   What percentage of asbestos related activities Involve demolitions?

                   Demolitions comprise approximately 10% of all reported asbestos-related activities.
                   Is there a numeric emission limit for the release of asbestos fibers during
                   renovations or demolitions in the asbestos NESHAP regulation?

                   No, the Asbestos NESHAP relating to demolitions or renovations is a work practice
                   standard. This means that it does not place specific numerical emission limitations
                   for asbestos fibers on asbestos demolitions and removals. Instead, it requires specific
                   actions be taken to control emissions. However, the Asbestos NESHAP does specify
                   zero visible emissions to the outside air from activity relating to the transport and
                   disposal of asbestos waste.
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Asbestos NESHAP Questions
                   Who Is responsible for enforcing the Asbestos NESHAP standards?

                   Under Section 112 of the Clean Air Act, Congress gave EPA the responsibility for
                   enforcing regulations relating to asbestos renovations and demolitions. The CAA
                   allows EPA to delegate this authority to State and local agencies. Even after EPA
                   delegates responsibility to a State or local agency, EPA retains the authority to
                   oversee agency performance and to enforce NESHAP regulations as appropriate.
                   How many States have primary responsibility for Implementing the
                   Asbestos NESHAP regulations?

                   As of October 1990, approximately 45 states.
NESHAP
Jurisdiction
What Is a facility?11

As defined in the regulation, a "facility8 is any institutional, commercial, public,
industrial or residential structure, installation or building (including any structure,
installation or building containing condominiums, or individual dwelling units
operated as a residential cooperative, but excluding residential buildings having four
or fewer dwelling units); any ship; or any active or inactive waste disposal site. Any
building, structure or installation that contains a loft used as a dwelling is not
considered residential.  Any structure, installation, or building that was previously
subject to the Asbestos NESHAP is not excluded, regardless of its current use or
function.
                   If I renovate several two-family units, are the units defined as a facility?'

                   Residential buildings which have four or fewer dwelling units are not considered
                   "facilities" unless they are part of a larger installation (for example, an  army base,
                   company housing, apartment or housing complex, part of a group of houses subject
                   to condemnation for a highway right-of-way, an apartment which is an integral part
                   of a commercial facility, etc.).
                   Are mobile homes or mobile structures regulated by the Asbestos
                   NESHAP?

                   Mobile homes used as single-family dwellings are not subject to Asbestos NESHAP.
                   Mobile structures used for non-residential purposes are subject to NESHAP.
December 1990

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 Asbestos NESHAP Questions
                   Are Federal facilities regulated by the Asbestos NESHAP?

                   Yes.


                   Are single-family private residences regulated by the Asbestos NESHAP?

                   No.
                   How much asbestos must be present before the Asbestos NESHAP work
                   practice standards apply to renovation projects?

                   Asbestos NESHAP regulations must be followed for all renovations of facilities with at
                   least 80 linear meters  (260 linear feet) of regulated asbestos-containing materials
                   CRACM) on pipes, or 15 square meters (160 square feet) of regulated asbestos-
                   containing materials on other facility components, or at least one cubic meter (35
                   cubic feet) off facility components where the amount of RACM previously removed
                   from pipes and other facility components could not be measured before stripping.
                   These amounts are known as the "threshold" amounts.
                   How much asbestos must be present before the Asbestos NESHAP work
                   practice standards apply to demolition projects?

                   Asbestos NESHAP regulations must be followed for demolitions of facilities with at
                   least 80 linear meters  (260 linear feet) of regulated asbestos-containing materials
                   (RACM) on pipes, 15 square meters (160 square feet) of regulated asbestos-
                   containing materials on other facility components, or at. least one cubic meter (35
                   cubic feet) off facility components where the amount of RACM previously removed
                   from pipes and other facility components could not be measured before stripping.

                   However, all demolitions must notify the appropriate regulatory agency, even if no
                   asbestos is present at the site, and all demolitions and renovations are "subject" to
                   the Asbestos NESHAP insofar as owners and operators must determine if and how
                   much asbestos is present at the site.
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 Asbestos NESHAP Questions
                   Are homes that are demolished or renovated to build non-residential
                   structures regulated by the Asbestos NESHAP?

                   Yes. For example, homes which are demolished as part of an urban renewal project,
                   a highway construction project, or a project to develop  a shopping mall are regulated
                   by the Asbestos NESHAP.

                   A single home which is converted into a non-residential structure is also regulated by
                   the Asbestos NESHAP.  For example, if someone buys a house and converts it into a
                   store, the renovation is subject to the Asbestos NESHAP.
                   If a renovation site is abandoned, Is the site still regulated by the Asbestos
                   NESHAP?

                   Yes.  Even after a renovation site is abandoned, it is still regulated by the Asbestos
                   NESHAP.
                   What Is encapsulation, and is it regulated by the Asbestos NESHAP?

                   Encapsulation is the application of a material with a sealant to stop it from releasing
                   fibers.  Normally, encapsulation is not regulated by the Asbestos NESHAP unless it
                   involves removing or stripping asbestos. However, if encapsulation is done using
                   methods that damage asbestos and release fibers it would be covered.  For example,
                   high pressure spraying to apply encapsulant could damage asbestos. Also, if friable
                   RACM is encapsulated, the RACM is still covered by the Asbestos NESHAP if
                   renovation or demolition occurs.
                   Are offshore oil rigs regulated In terms of asbestos removal and
                   demolition?

                   Yes.  Federal jurisdiction extends to the continental shelf (100 miles).  When EPA
                   delegates authority to State or local agencies, the State and local agencies are usually
                   considered to have authority only in territorial waters (12 miles).  The Department of
                   the Interior is still evaluating whether States may extend their jurisdiction beyond
                   territorial waters. EPA currently enforces the NESHAP between territorial waters and
                   the continental shelf.
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Asbestos NESHAP Questions
Notifications     What Is a notification?
                   A notification is a written notice of intent to renovate or demolish. Notifications
                   must contain certain specified information, including but not limited to, the
                   scheduled starting and completion date of the work, the location of the site, the
                   names of operators or asbestos removal contractors, methods of removal and the
                   amount of asbestos, and whether the operation is a demolition or renovation.

                   See Section 61.145(b) of the Asbestos NESHAP regulation.
                   Whom do I notify?

                   You should notify the delegated State/Local Pollution Control Agency in your area
                   and/or the EPA Regional Office of the demolition or renovation operations subject to
                   NESHAP. Some EPA Regions require that both the EPA Regional Office and the local
                   delegated agency be notified, while some require notice only to the delegated State
                   or local agency.  If the program is not delegated, notify the EPA Regional Office.
                   How do I notify?

                   Mail or hand-deliver the notification to the appropriate agency.


                   Are telefaxed or telephone notifications acceptable?

                   No. Telefaxed notifications are not accepted. Telephone notifications are only
                   acceptable in emergency situations at the discretion of the EPA Regional Office or
                   delegated agency and must be followed with a written copy by the following working
                   day.
                   Who is responsible for submitting a notification - the owner of the building
                   which Is being demolished or renovated, or the contractor?

                   The NESHAP regulation states that either the owner of the building or operator of
                   the demolition or renovation operation can submit the notification.  Usually, the two
                   parties decide together who will notify. If neither provide adequate notice, EPA can
                   hold either or both parties liable.
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 Asbestos NESHAP Questions
                   When a condominium complex Is being renovated, who as owner, Is
                   responsible for submitting a notification?

                   While owners and operators share responsibility for proper notification, the
                   condominium or co-op board is responsible as the owner. The board should ensure
                   that they are told when work takes place on individual units, so that they can comply
                   with notification (and other EPA) requirements, especially if multiple operators are
                   involved.
                   Is there a form or format for notifications?

                   Yes, there is a suggested form for notifications. You can obtain a form, and
                   instructions on how to fill it out, from your delegated State or local agency or from
                   your EPA Regional Office.
                   Do demolitions of facilities in which no asbestos Is present require
                   notification?

                   Yes.  All demolitions that meet the definition of facility must notify.
                   When 1 notify regarding a renovation, what date do I consider the start
                   date?

                   For a renovation, the start date is the day that the removal of asbestos-containing
                   material, or any other asbestos-handling activities, including precleaning,
                   construction of containment, or other activities that could disturb the asbestos, will
                   begin.
                   When I notify regarding a demolition, do 1 give the start date of the
                   demolition or of the asbestos removal? Which date do I use to determine
                   whether I've met the 10-day waiting period?

                   For a demolition, the start date is the date that the removal or related activity begins.
                   The date the demolition starts also must be reported. The waiting period should be
                   calculated based on the start date of the removal or the demolition, if no removal is
                   required.  The waiting period is necessary to give inspectors time to visit the site .
                   before activity begins.
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Asbestos NESHAP Questions
                   Does the 10-day notification requirement refer to 'calendar' days or
                   "working1 days?

                   The Asbestos NESHAP regulation specifies "working days." Holidays that fall
                   between Monday and Friday count as "working days."


                   What Is a 'nonscheduled renovation operation"?

                   A "nonscheduled renovation operation" is a renovation operation that is caused by
                   the routine failure of equipment which is expected to occur based on past operating
                   experience, but for which an exact date cannot be predicted.


                   Do I  have to notify for non-scheduled operations?  When?

                   Yes, if you can predict based on past experience that renovations will be necessary
                   during the calendar year and the amount of asbestos is likely to exceed the
                   jurisdictional amount, notification is required. This notification must be submitted at
                   least 10 working days before the end of the calendar year preceding the year for
                   which notice is being given.

                   Note: Single renovation projects which exceed the  threshold amount are not covered
                   by this type of notice. A separate notification is required for these projects.


                   Must I  notify the agency again if I know that a specific renovation project
                   Involving more than the threshold amount (including the work covered by
                   the calendar year notice for non-scheduled operations)  is about to occur at
                   a specific time?

                   Yes.
                   What constitutes an emergency renovation?

                   An emergency renovation is a renovation that was not planned, but results from a
                   sudden, unexpected event that either immediately produces unsafe conditions, or
                   that, if not quickly remedied, could be reasonably foreseen to result in an unsafe or
                   detrimental effect on health or is necessary to protect equipment and avoid
                   unreasonable financial burden.  The term includes renovations necessitated by non-
                   routine equipment failures. For example, the explosion of a boiler in a chemical
                   plant might require  emergency renovations, since such an explosion would disrupt
December 1990

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Asbestos NESHAP Questions
                   normal operations. However, renovations involving routine repairs are not
                   emergencies.


                   Under what conditions must I notify for emergency renovations?   When
                   must I notify?

                   First, inspect the facility and determine the amount of RACM that may have to be
                   removed or disturbed to repair the facility. (If you don't have the time to have
                   samples analyzed, you should assume that all insulation is RACM.)  Then, if the
                   amount of RACM is in excess of the threshold amount, you should mail or deliver a
                   notification as soon as possible, but certainly no later than the following workday. A
                   notification which is postmarked more than one working day after the emergency
                   will be considered in violation of the notification requirements.  EPA recommends
                   that you send the notice by overnight express mail, and that you phone in a
                   notification as well to the delegated agency and/or EPA Regional Office.
                   When does a notification need to be revised?

                   A notification must be revised if information contained in the original notice has
                   changed.  For example, you must revise the notification if you change the start date
                   of an operation.  If the change relates to the amount of RACM involved, you need
                   only revise the notification if the amount changes by more than 20 percent.


                   When do I submit a revised notification?

                   You should telephone EPA as soon as possible after you realize the revision is
                   necessary, and should then mail or hand deliver a written notice. If you delay the
                   start date of a project, EPA must receive the revised notification no later than the
                   original start date.  If you plan to begin work before the date specified in the original
                   notice, EPA must receive the revised notice at least 10 working days before the
                   revised start date.
Removal
Does the Asbestos NESHAP require a building owner or operator to remove
damaged or deteriorating asbestos-containing material?

No. Not unless a renovation of the facility is planned which would disturb the ACM
and it exceeds the threshold amount.
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Asbestos NESHAP Questions
                   What does "adequately wet* mean?

                   To "adequately wet* ACM means to sufficiently mix or penetrate the material with
                   liquid to prevent the release of particulates.  If visible emissions are observed coming
                   from ACM, then the material has not been adequately wetted. However, the absence
                   of visible emissions is not evidence of being adequately wet.
                   If a contractor puts water In the bottom of a bag, then strips the friable
                   asbestos material dry and lets it fall Into the water, Is this a violation of the
                   Asbestos NESHAP standards?

                   Yes. The regulation states that friable asbestos-containing material must be
                   "adequately wet" during stripping operations. The material must remain wet until
                   disposal.
                   Section 61.145(c) (6) (ill) states that the operator must transport the
                   materials to the ground via dust tight chutes or containers If It has been
                   removed or stripped more than 50 feet above ground level.' Can a room
                   sealed with plastic and a negative air system be considered a dust tight
                   chute?

                   No, the area in which removal is being conducted (the containment area) cannot be
                   considered a dust tight chute in order to comply with 61.145(c)(6)(iii).
Ordered
Demolitions
If a facility is being demolished under an order of a State or local
government because the facility is structurally unsound, and therefore
unsafe, do all the normal regulations covering demolitions apply?

No. The regulations which do apply are specified in 61.145 (a) (3) of the
regulation.
                  If a facility Is being demolished under an order of a State or local
                  government, must all the debris be treated as asbestos-contaminated
                  waste?

                  If, for safety reasons, the RACM in the facility is not removed prior to demolition, the
                  RACM must be kept adequately wet during the wrecking operations. After
                  wrecking, all the'contaminated debris must be kept adequately wet until disposal.
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Asbestos NESHAP Questions
                   All contaminated debris which cannot be segregated and cleaned should be disposed
                   of as asbestos waste.
Friable and
Non-Friable
Asbestos
What Is friable asbestos-containing material?

Friable ACM is any material containing more than one percent asbestos (as
determined by Polarized Light Microscopy) that, when dry, may be crumbled,
pulverized, or reduced to powder by hand pressure.
                   What Is non-friable ACM?

                   Non-friable ACM is any material containing more than one percent asbestos (as
                   determined by Polarized Light Microscopy) that, when dry, cannot be crumbled,
                   pulverized, or reduced to powder by hand pressure. Under the Asbestos NESHAP,
                   non-friable ACM is divided into two categories. Category I non-finable ACM are
                   asbestos-containing resilient floor coverings (commonly known as vinyl asbestos tile
                   (VAT)), asphalt roofing products, packings and gaskets.  These materials rarely
                   become friable. All other non-friable ACM are considered category II non-friable
                   ACM.
                   Must I remove category I non-friable material prior to demolition or
                   renovation?

                   Under normal circumstances, category I non-friable materials need not be removed
                   prior to demolition or renovation, because generally these materials do not release
                   significant amounts of asbestos fibers, even when damaged. This is not, however, a
                   hard and fast rule. If category I materials have become friable or are in poor
                   condition, they must be removed. Also, if you sand, grind, abrade, drill, cut or chip
                   any non-friable materials, including category I materials, you must treat the material
                   as friable, if more than the jurisdictional amount is involved.
                   Must I remove category II non-friable materials prior to demolition or
                   renovation?

                   These materials should be evaluated on a case-by-case basis.  If category II non-
                   friable materials are likely to become crushed, pulverized or reduced to powder
                   during demolition or renovation, they should be removed before demolition or
                   renovation begin. For example, A/C (asbestos cement) siding on a building that is
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Asbestos NESHAP Questions
                   going to be demolished with a wrecking ball should be removed, because it is likely
                   that the siding will be pulverized by the wrecking ball.
                   Does non-friable waste, If broken, damaged, etc., have to be wetted and
                   contained?

                   Non-friable ACM that has been damaged during a demolition or renovation operation
                   such that some portions of the material are crumbled, pulverized or reduced to
                   powder is covered by the Asbestos NESHAP if the facility contains more than the
                   threshold amount of RACM. However, category II non-friable ACM that has a high
                   probability of being damaged by the demolition or renovation forces expected to act
                   on the materials such that it will be crumbled,  pulverized, or reduced to powder
                   must be removed prior to the demolition or renovation operation. It is the owner's
                   or operator's responsibility to make these determinations.
Transport
and Disposal
How should I handle bulk waste from a facility that contained RACM and
that was not found until after demolition began?

The demolition debris must be treated as asbestos-containing waste. Adequately wet
the demolition debris until collected for disposal and during loading, transport it in
covered vehicles and emit no visible emissions to the outside air as required by
61.150.  The waste must be deposited at an acceptable waste disposal site.
                   Can I transport bulk asbestos waste without placing it in containers as long
                   as I  keep the waste pile wet?

                   No. After wetting, seal all asbestos-containing waste material in leak-tight containers;
                   while wet and label with the appropriate signs and labels. If the waste will not fit
                   into containers, it must be placed in leak-tight wrapping.

                   However, for facilities that are demolished without removing the RACM and for
                   ordered demolitions, the material must be  adequately wet after the demolition has
                   occurred and again when loading the material for transport to a disposal site. RACM
                   covered by this paragraph may be transported in bulk without being placed in leak-
                   tight containers or wrapping.
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Asbestos NESHAP Questions
                   How should I label asbestos-containing waste that is being taken away from
                   the facility?

                   You should label the containers or wrapped materials with the name of the waste
                   generator and the location at which the waste was generated. An OSHA warning
                   label must also be used.
                   Does EPA license landfills for asbestos waste?

                   The EPA does not license asbestos landfills under the Clean Air Act.. However, it has
                   established asbestos disposal requirements for active and inactive disposal sites under
                   the NESHAP, and general requirements for solid waste disposal under the Resource
                   Conservation and Recovery Act (RCRA). In addition, State and/or local agencies
                   usually require asbestos landfills to be approved or licensed.
                   Where can I obtain a list of licensed landfills?

                   State and local agencies which require handling or licensing procedures can supply a
                   list of "approved" or licensed asbestos disposal sites upon request.  Solid waste
                   control agencies are listed in local telephone directories under State, county or city
                   headings.
                   What should the owner or operator of a waste disposal site do if it is
                   determined that there is a discrepancy between the amount of waste that left
                   the facility and the amount of waste that was delivered to the site?

                   The waste site owner or operator must contact the demolition/renovation owner or
                   operator, and attempt to reconcile the discrepancy.  If they cannot do so within 15
                   days after the waste was received, the waste site owner or operator must notify both
                   the delegated agency responsible for trie facility from which the waste was removed,
                   and the delegated agency responsible for the area in which the waste was disposed.
                   Can water be considered "six-inch compacted non-asbestos cover"?  In other
                   words, could asbestos covered components be dropped in the ocean?

                   No.
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Asbestos NESHAP Questions
Monitoring
and
Sampling
Does the NESHAP regulation require air monitoring during renovation or
removal?
                   No.
                   Does the Asbestos NESHAP regulation require me to inspect my property for
                   asbestos?

                   No, not unless demolition or renovation is planned.  The only Federal regulation
                   which requires general inspections are the AHERA regulations, which mandate that
                   schools must be inspected for asbestos. The NESHAP regulation requires that you
                   inspect for asbestos before demolition or renovation.
                   What is the acceptable exposure/ambient air standard for asbestos?

                   EPA does not specify an acceptable exposure/ambient air standard.


                   What Is a bulk sample?

                   A bulk sample is a solid quantity of insulation, floor tile, building material, etc., that
                   is suspected of containing asbestos fibers that will be analyzed for the presence and
                   quantity of asbestos.


                   Will EPA test my building for asbestos for me?

                   No. Owners and operators are responsible for getting their buildings tested.


                   How can I find someone to do the testing?

                   The National Institute of Standards and Technology (NIST) publishes a yearly listing
                   of accredited laboratories enrolled in the National Voluntary Laboratory Accreditation
                   Program (NVLAP).  Then, on a quarterly basis NIST publishes updates to the master
                   list detailing labs newly accredited, labs which have had their accreditation
                   suspended, etc. Contact NIST NVLAP for a current listing of accredited labs.  The
                   NIST NVLAP number is listed at the end of this pamphlet, along with other contact
                   numbers.
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Asbestos NESHAP Questions
                   Does EPA accredit laboratories that test for asbestos?

                   No. EPA, under CFR Part 763, requires local education agencies to use laboratories
                   accredited by the National Institute of Standards and Technology (NIST) in its
                   National Voluntary Laboratory Accreditation Program (NVLAP).  It is recommended
                   for NESHAP related projects that NIST accredited laboratories be used.
                   How do laboratories analyze bulk samples?

                   Laboratories analyze bulk samples a number of ways.  Most laboratories use
                   Polarized Light Microscopy (PLM). Some laboratories use Transmission Electron
                   Microscopy (TEM).  However, there is currently no published method for bulk
                   analysis using TEM.
                   How much does it cost to have a bulk sample analyzed?

                   The cost varies with the method.  The cost of PLM analysis ranges from $20.00 to
                   $100.00.  The average cost is $30.00.  TEM analysis is more expensive.
Inspections       Does an inspector have the right to enter any facility and the containment area?

                   Yes.  All inspectors have the right under the Clean Air Act to inspect any facility and
                   the containment area. Inspectors are trained and equipped to do this safely.
                   If I can see ACM dust inside the containment area or inside a glovebag, is this
                   a violation of the Asbestos NESHAP?

                   The observation of ACM dust will be used as evidence of a violation of the
                   "adequately wet" requirement. This is consistent with the definition of adequately
                   wet that requires enough wetting "to prevent the release of particulates."
                   Is visible asbestos-containing debris on the ground outside a removal job
                   considered a "visible emission," and a violation of the NESHAP?

                   Yes.  Dry friable asbestos insulation on the ground violates the "adequately wet"
                   requirement, and can be considered evidence of a visible emission.
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Asbestos NESHAP Questions
                   Is it appropriate for an inspector to open any bags outside the designated
                   contaminated area?

                   Yes.  The inspector may open any bags outside the designated contaminated area to
                   inspect them. The inspector may use a glovebag or other control techniques. The
                   inspector will then properly reseal the bag, or request that the operator do so.
                   Must an inspector witness improper removal of more than 160 square feet or
                   260 linear feet of asbestos-containing material to prove a violation of the
                   NESHAP regulation?

                   No. First, the inspector must gather information about the quantity of asbestos to
                   prove that the project is subject to the NESHAP standards.  Second, the inspector
                   must prove that there has been improper removal. The two tasks are distinct from
                   each other.
                   Are Inspectors required to have medical examinations to ensure that they are
                   medically fit to wear respirators?

                   Yes.  Several Federal provisions under OSHA, EHSD, and NIOSH require people to be
                   examined by a doctor and pronounced physically fit before they are permitted to
                   wear respirators.
                   Must Inspectors have personnel monitoring conducted on them during
                   inspections to comply with OSHA requirements for workers?

                   No.  The inspectors do not have to comply with the work practice safety standards
                   required by OSHA for personnel monitoring.
                   Do inspectors need to follow facility training requirements including fit testing?

                   No.
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Asbestos NESHAP Questions
Training
Do contractors and employees need to be accredited?

As of November 20, 1991, the Asbestos NESHAP requires a person trained in the
provisions of this rule and the means of complying with them to be on-site when
asbestos-containing material is stripped, removed, or disturbed. Under AHERA, all
contractors and employees involved in the removal and disposal of asbestos-
containing material from schools must be accredited. Additionally, many States
require that all workers be accredited before they remove asbestos from any facility.
                   How can I qualify as an asbestos contractor/worker/consultant under AHERA?

                   You must attend and pass an EPA accredited training course.  A list of training
                   courses approved by EPA is published quarterly in the Federal Register, and is
                   available through the TSCA hotline. The TSCA number is printed at the end of this
                   pamphlet, along with other contact numbers.  Contact your State or local agency for
                   more information.
                   Do supervisors need to be trained?

                   Beginning on November 20, 1991, the Asbestos NESHAP requires at least one trained
                   supervisor to be present at any site at which RACM is stripped, removed, or
                   otherwise disturbed at any facility which is being demolished or renovated and is
                   regulated by NESHAP.  Evidence of the training must be posted and made available
                   for inspection at the demolition or renovation site. Training includes, at a minimum:
                   applicability, notification, material identification, control procedures, waste disposal,
                   reporting and record keeping, asbestos hazards and worker protection. Completion
                   of an AHERA accredited course constitutes adequate training. Every 2 years the
                   trained individual is required to receive refresher training. Information about both
                   the training and refresher courses is available through EPA or delegated State or
                   local agencies.
Violations
and
Penalties
What will happen if I violate the Asbestos NESHAP?

Sanctions vary.  In some cases, Notices of Deficiency (NOD)  written warnings  or
Notices of Violation (NOVs) are issued to owners or operators who violate
notification requirements. Or, depending upon the offense, EPA recommends fines
up to $25,000 per day per violation.
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Asbestos NESHAP Questions
                   Violators of the work practice or disposal standards may be subject to either written
                   warnings, administrative orders or civil penalties up to $25,000 per day per violation,
                   depending upon the seriousness of the violation. EPA may also bring criminal
                   charges against violators. Some owners and operators who have knowingly violated
                   the Asbestos NESHAP have been sentenced to prison terms.

                   For more information on penalties and enforcement, see the EPA Public Information
                   Document entitled "Asbestos NESHAP Enforcement."
                   What Is the maximum penalty which can be assessed for NESHAP
                   violations?

                   $25,000 per day, per violation, with no absolute maximum.  However, some NESHAP
                   violators may also be liable under CERCLA, and if so, the maximum penalty may be
                   much higher.
                   How are penalties calculated?

                   Penalties are computed on a case-by-case basis.  The amount of asbestos involved,
                   the number of previous violations, the duration of the offense, the economic benefit
                   that accrued to the owner or operator as a result of the violation, and similar
                   considerations are taken into account.
                   What Is "contractor listing?"

                   Contractors who have shown a pattern of violation, or who have been convicted of a
                   criminal violation, may be placed on a list of violators who are prohibited from
                   contracting for any jobs involving Federal money (grants, contracts, sub-grants, etc.).
                   Can a corporation that has changed its name, but is owned by an individual
                   who has been listed be subject to contractor listing?

                   Yes.
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Asbestos NESHAP Questions
NARS
What is NARS?

NARS stands for "National Asbestos Registry System."  NARS is a computerized
database established by EPA in April, 1989. NARS stores data on the compliance
history of firms doing demolition or renovation work subject to the Asbestos
NESHAP.
                   What is the purpose of NARS?

                   NARS is used by EPA Regional Offices as well as State and local agencies to "target"
                   inspections of contractors with poor compliance histories, and to monitor activity
                   subject to the NESHAP regulations.
                   Can I get NARS information?

                   Yes. NARS information is available through EPA Regional Offices under the
                   provisions of the Freedom of Information Act.
                   Are there any penalties for being listed In NARS as a violator?

                   No. NARS is only an information system. Contractors who have violations listed in
                   NARS may, however, be inspected more frequently than contractors who have no
                   violations.
                   Why does EPA recommend Inspection targeting?

                   Delegated agencies receive over 60,000 notifications of planned renovation or
                   demolition projects each year. Because all projects cannot be inspected, EPA
                   recommends targeting inspections so that agencies can make better use of their
                   inspection resources.
                   Can firms avoid future inspections based on past good performance?

                   Past performance is an important criterion for targeting inspections; however, other
                   criteria are also used.  As a result of EPA guidance to State and local air pollution
                   agencies, many asbestos removal contractors will be inspected at least once per year.
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Asbestos NESHAP Questions
                   How many contractors and owners are currently listed In NARS?

                   As of October 1990, there were approximately 7,000 contractors and owners in
                   NARS.
                   How does Information get Into NARS?

                   Information on the number of notifications, inspections, and violations for each
                   contractor or owner is submitted by delegated State and local air pollution agencies
                   and is reported through the EPA Regional NARS Coordinators to EPA Headquarters
                   where the report is compiled.
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Asbestos NESHAP Questions
Additional       You can obtain more information about the Asbestos NESHAP by contacting your
Information      EPA Regional Office's NESHAP coordinator. You can obtain more information about
                  AHERA by contacting your Regional Asbestos Coordinator CRAG). The addresses and
                  phone numbers of both the RAG and NESHAP coordinators are listed at the end of
                  this pamphlet.

                  You may also call the EPA Toxic Substances Control Act (TSCA) Hotline to ask
                  general questions about asbestos, or to request asbestos guidance documents.  The
                  Hotline number is (202) 554-1404. The EPA Public Information Center can send you
                  information on EPA regulations. You can reach the Center at (202) 382-2080 or
                  (202) 475-7751.

                  The EPA has an Asbestos Ombudsman to provide information on the handling and
                  abatement of asbestos in schools, the  workplace and the home.  Also,  the EPA
                  Asbestos Ombudsman can help citizens with asbestos-in-school complaints.  The
                  Ombudsman can be reached toll-free at (800) 368-5888, direct at (703) 557-1938 or
                  557-1939.

                  To obtain a current listing of accredited labs contact NIST NYLAP at (301)975-4016.
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Glossary of Terms
                                     Glossary of Terms
AHERA

CAA

CERCLA


EPA

EHSD

Friable Asbestos
Material
Glovebag


WARS

NESHAP


NIOSH

NIST

NVLAP

OSHA

Partlculate
Asbestos
Material

RACM
The Asbestos Hazard Emergency Response Act, passed by Congress in 1986

Clean Air Act

The Comprehensive Environmental Response Compensation and Liability Act.  Also
known as the "Superfund."

The United States Environmental Protection Agency

Environmental Health and Safety Division, U.S. EPA

Any material containing more than one percent asbestos, as determined using the
method specified in Appendix A, subpart F 40 CFR part 763, section 1,  Polarized
Light Microscopy, that when dry, can be crumbled, pulverized, or reduced to powder
by hand pressure. If the asbestos content is less than 10 percent as determined by a
method other than point counting by polarized light microscopy (PLM), verify the
asbestos by point counting using PLM.

A sealed compartment with attached inner gloves used for the handling of asbestos-
containing materials.

National Asbestos Registry System

The National Emission Standard for Hazardous Air Pollutants found in Title 40 CFR
part 61 promulgated under Section 112 of the Clean Air Act.

National Institute for Occupational Safety and Health

National Institute of Standards and Technology

National Voluntary Laboratory Accreditation Program

Occupational Safety & Health Administration

Finely divided particles of asbestos or material containing asbestos.
Regulated Asbestos-Containing Material.  RACM means (a) Friable asbestos material,
(b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable
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Glossary of Terms
                   ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or
                   (d) Category II nonfiiable ACM that has a high probability of becoming or has
                   become crumbled, pulverized, or reduced to powder by the forces expected to act on
                   the material in the course of demolition or renovation operations regulated by the
                   Asbestos NESHAP.
RCRA
TSCA
Resource Conservation and Recovery Act

Toxic Substances Control Act
Visible Emissions  Any emissions, which are visually detectable without the aid of instruments, coming
                   from RACM or asbestos-containing waste material, or from any asbestos milling,
                   manufacturing, or fabricating operation.
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  AHERA and NESHAP Coordinators
                                     AHERA and  NESHAP Coordinators
                         Region
         NESHAP
                                         AHERA
                         Region 1

                       CT, MA, ME
                       NH, RI, VT
Asbestos NESHAP Coordinator
Air Management Division
US EPA
JFK Building
Boston, MA 02203

(617) 565-3265
Regional Asbestos Coordinator
US EPA
JFK Federal Building
Boston, MA 02203
                                                                       (617) 565-3835
                         Region 2

                         NJ, NY
                         PR, VI
Asbestos NESHAP Coordinator
Air & Waste Management Div.
US EPA
26 Federal Plaza
New York, NY 10278

(212) 264-6770
Regional Asbestos Coordinator
US EPA
Woodbridge Avenue
Edison, NJ 08837
                                                                       (201) 321-6671
                         Region 3

                       DC, DE, MD
                       PA, VA, WV
Asbestos NESHAP Coordinator
Air and Toxics Division
US EPA
841 Chestnut Street
Philadelphia, PA 19107

(215) 597-8683
Regional Asbestos Coordinator
US EPA
841 Chestnut Street
Philadelphia, PA 19107
                                                                       (215)597-3160
                        Region 4

                       AL, FL, GA,
                      KY, MS, NC,
                         SC.TN
Asbestos NESHAP Coordinator
Air, Pesticide & Toxics Div.
US EPA
345 Courtland Street
Atlanta, GA 30365

(404) 347-5014
Regional Asbestos Coordinator
US EPA
345 Courtland Street
Atlanta, GA 30365
                                                                       (404) 347-5014
                        Region 5

                        IX, IN, MI
                       MN, OH, WI
Asbestos NESHAP Coordinator
Air & Radiation Division
US EPA
230 South Dearborn Street
Chicago, IL 60604

(312) 353-6793
Regional Asbestos Coordinator
US EPA
230 South Dearborn St;
Chicago, IL 60604
                                                                       (312)353-6003
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AHERA and NESHAP Coordinators
                        AHERA and NESHAP Coordinators
Region
Region 6

AR, LA, MM
OK, TX



Region 7

IA, KS
MO, NE



Region 8

CO, MT, ND
SD, UT, WY




Region 9

AS, CA, HI,
NV, AZ, GU,
TT

Region 10

AK, ID
OR, WA


NESHAP
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Div.
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7233
Asbestos NESHAP Coordinator
Air & Toxics Division
US EPA
726 Minnesota Avenue
Kansas City, KS 66101

(913) 551-7618
Asbestos NESHAP Coordinator
Air & Waste Management Div.
US EPA
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 294-7685
Asbestos NESHAP Coordinator
Air Management Division
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1135
Asbestos NESHAP Coordinator
Air & Toxics Management Div.
US EPA
1200 6th Avenue
Seattle, WA 98101
(206) 442-1757
AHERA
Regional Asbestos Coordinator
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733

(214) 655-7244
Regional Asbestos Coordinator
US EPA
726 Minnesota Avenue
Kansas City, KS 66101

(913) 551-7020

Regional Asbestos Coordinator
US EPA
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405

(303) 293-1442
Regional Asbestos Coordinator
US EPA
75 Hawthorne Street
San Francisco, CA 94105

(415) 744-1128
Regional Asbestos Coordinator
US EPA
1200 6th Avenue
Seattle, WA 98101

(206) 442-4762
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