EPA 340/1-90-003D .
June 1991
REFERENCE INFORMATION
Asbestos NESHAPs Inspection and Safety Procedures
Training Course
(Supplemental Published Guides and Other Informational Documents)
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Supplemental Information
Asbestos NESHAPs Inspection and Safety Procedures
Table of Contents
Item 1 - A Guide to the Asbestos NESHAP
(As Revised November 1990)
Item 2 - Asbestos/NESHAP Regulated Asbestos Containing
Materials Guidance
Item 3 - Asbestos/NESHAP Adeqately Wet Guidance
Item 4 - Reporting And Recordkeeping Requirements For Waste
Disposal
(A Field Guide)
Item 5 - Common Questions On The Asbestos NESHAP
Item 6 - The Asbestos Informer
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"
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
AIR AND RADIATION
ASBESTOS NESHAP GUIDANCE MATERIALS
The Asbestos National Emission Standards for Hazardous Air
Pollutants (NESHAP), 40 CFR 61, Subpart M, was amended on November 20,
1990 by the U.S. Environmental Protection Agency (EPA) to increase the
level of compliance with the demolition and renovation provisions.
In order to assist the public and regulated community to understand
the requirements under the Asbestos NESHAP, a series of guidance
documents were developed and are enclosed with this letter.
These documents are intended for information purposes ONLY, and
may not in any way be interpreted to alter or replace the coverage or
requirements of Subpart M.
If you have specific questions on any of these documents, please
contact the Asbestos NESHAP Coordinator for your State. A list of
coordinators can be found in the document entitled: Asbestos NESHAP
National Contact List.
Printed on Recycled Paper
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Item 1 - A Guide to the Asbestos NESHAP
(As Revised November 1990)
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United States Air And Radiation EPA340/1-90-015
Environmental Protection (EN-341) November 1990
Agency
xvEPA A Guide To The
Asbestos NESHAP
As Revised November 1990
Printed on Recycled Paper
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EPA-340/1-90-015
A Guide to the Asbestos
NESHAP as Revised
November 1990
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington. DC 20460
December 1990
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DISCLAIMER
This manual was prepared by the Research Triangle
Institute and Entropy Environmentalists, 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. The contents of this report are
reproduced herein as received from the contractor. The
opinions, findings, and conclusions expressed are those
of the authors and not necessarily those of the U.S.
Environmental Protection Agency. Any mention of product
names does not constitute endorsement by the U.S.
Environmental Protection Agency.
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A GUIDE TO THE ASBESTOS NESHAP AS REVISED NOVEMBER 1990
INTRODUCTION
The Environmental Protection Agency (EPA), under the requirements set forth by
the Clean Air Act (CAA) of 1971, is required to develop and enforce
regulations necessary to protect the general public from exposure to air
pollutants that are known to be hazardous to human health. The specific
authority of EPA regarding asbestos is listed under Section 112 of the CAA
entitled "National Emission Standards for Hazardous Air Pollutants" (NESHAP).
The particular standard, that addresses asbestos is contained in Title 40 of
the Code of Federal Regulations (40 CFR) Part 61, Subpart M.
These regulations generally specify emission control requirements for the
milling, manufacturing and fabricating of asbestos, for activities associated
with the demolition and renovation of asbestos-containing buildings, and for
the handling and disposal of asbestos-containing waste material. The major
intention of the regulations is to minimize the release of asbestos fibers
during all activities involving the handling and processing of asbestos and
asbestos-containing material.
SOURCES UNDER SUBPART H
The following activities are regulated by the Asbestos NESHAP Regulations:
Asbestos milling (61.142);
Roadway surfacing with asbestos-containing material (61.143);
Manufacture of products using commercial asbestos (61.144);
Demolition and/or renovation of facilities with asbestos-containing
material (61.145);
Spraying of asbestos-containing material (61.146);
Fabrication of products containing commercial asbestos (61.147);
Use of insulating materials that contain commercial asbestos (61.148);
Waste disposal for asbestos milling (61.149);
Disposal of asbestos-containing waste generated during manufacturing,
demolition, renovation, spraying, and fabricating operations (61.150);
Closure and maintenance of Inactive waste disposal sites (61.151);
Design and operation of air cleaning devices (61.152);
Reporting of information pertaining to process control equipment,
filter devices, processes that generate asbestos waste, etc. (61.153);
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Operations at active waste disposal sites (61.154); and
Operations and reporting for facilities that convert asbestos-
containing waste material into nonasbestos (asbestos-free) material
(61.155).
REGULATORY HISTORY OF THE ASBESTOS NESHAP
The Asbestos NESHAP regulation has been in existence since 1973 and has been
amended several times. The following is a summary of the main provisions
contained in the original stipulations and subsequent revisions:
March 31, 1971 - Asbestos listed as a hazardous air pollutant under
Section 112.
April 6, 1973 - Original promulgation developed regulations for:
- Asbestos mills and manufacturing sources;
- Asbestos-containing spray-on materials;
- Use of tailings in roadways;
- Demolition of buildings containing friable asbestos-containing
fireproofing and insulating material;
- The spraying of asbestos-containing materials on buildings and
structures for fireproofing and insulating purposes.
May 3, 1974 - Regulations were revised to Include:
- Addition of clarifying definitions;
- Clarification of demolition provisions;
- Clarification of the no visible emission standard to exclude
condensed uncombined water vapor.
October 14, 1975 - Substantial changes were made including:
- Addition of fabricators;
- Inclusion of renovation projects as regulated activities;
- Prohibition of the use of wet applied and molded Insulation (I.e.,
pipe lagging);
- Expansion of the scope of the regulation to cover asbestos-
containing waste handling and disposal;
- Inclusion of Inactive waste disposal sites that were operated by
milling, manufacturing, and fabricating sources.
March 2, 1977 - Minor changes, mostly addressing definitions.
June 19, 1978 - Important changes made include;
- Expansion of the coverage of spraying restriction to prohibit
application of asbestos-containing materials for decorative
purposes;
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- Adoption of provisions to exempt bitumen- or resin-based (i.e.,
contains material such as tar or asphalt) materials from the
spraying restrictions;
- Repromulgation of certain work practice provisions.
April 5, 1984 - Repromulgation to make sure that work practice
standards could be enforced. In 1978, the United States Supreme Court
ruled that EPA's authority to enforce emission standards under the CAA
of 1970 did not extend to work practice standards.
The CAA Amendments of 1977 gave EPA clear authority to enforce work
practice standards. By repromulgating the standard, EPA removed any
doubt that the work practice standards could be enforced. The
standard was also reorganized and clarified, and placed in Subpart M.
October 1990 - Promulgated revisions to clarify standard, promote
compliance, and aid enforcement, including:
- Requirements for milling, manufacturing, and fabricating to monitor
and inspect control devices and keep records of monitoring
activities;
- Renotification requirements and other clarifying revisions for
demolition and renovation; and
- Requirements to keep records of waste shipments and waste disposal.
GUIDELINES
The following chapters explain what emission sources are covered by the
asbestos NESHAP and what the requirements are for these sources. There is a
separate chapter for each section of the regulation. The corresponding
section(s) of the regulation are shown in brackets after each chapter heading
and major sub-heading (except for definitions). This guide may not in any way
be interpreted to alter or replace the coverage or requirements of Subpart M.
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ASBESTOS MILLS [61.142]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Administrator
Asbestos
Asbestos mill
Fugitive sources
Malfunction
Outside air
Owner or operator
Particulate asbestos material
Visible emissions
STANDARD [61.142(a)]
Owners or operators of an asbestos mill must either operate the mill,
including fugitive sources, with no visible emissions of asbestos to the
outside air or must follow Air Cleaning (61.152) that have been set forth by
the NESHAP regulations to clean emissions containing particulate asbestos
material before they are released to the outside air.
INSPECTION AND MONITORING REQUIREMENTS [61.142(b)]
Owners or operators of asbestos mills must do the following:
Monitor for visible emissions (I.e., observe and record) at each
potential source of asbestos emissions from any part of the mill
facility dally with the monitoring period lasting at least 15 seconds
for each source of emissions. Monitoring must be done during daylight
hours.
Inspect each air cleaning device weekly for proper operation and for
changes that signal potential malfunctions.
Record all monitoring and Inspections on forms similar to Figures 1
and 2 on pages 3 and 4, respectively. As a minimum, record:
- - Date and time of Inspection;
- Presence or absence of visible emissions;
- If a fabric filtration control device 1s used, the condition of
fabric filters and presence of dust deposits on the clean side of
fabric filters;
- Corrective actions taken; and
- Daily hours of air cleaning device operation.
Furnish upon request and make available during normal business hours,
all required records.
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All records of monitoring and inspections must be kept for at least 2
years.
If visible emissions are observed, owners and operators must submit
quarterly reports to the Administrator of the monitoring results.
Reports need only be submitted for those quarters in which visible
emissions occurred. These reports must be postmarked within 30 days
of the end of the calendar quarter.
Exceptions To Monitoring Requirements
If the construction of an air cleaning device is such that weekly inspections
cannot be made without dismantling beyond opening the device, then, instead of
inspections, a written maintenance plan may be submitted to the Administrator
that includes at a minimum, the following:
Maintenance schedule; and
Recordkeeping plan.
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Date of
Inspection
(mo/day/yr)
Time of
Inspection
(a.m. /p.m.)
Control
device or
fugitive
emission
source
designation
or number
Visible
emissions
observed
(yes/no) ,
corrective
action
taken
Dally
operating
hours
Inspector's
initials
Figure 1. Record of Visible Emission Monitoring
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1. Control device designation or number
2. Date of inspection
3. Time of inspection
4. Is control device operating
properly (yes/no)
5. Tears, holes, or abrasions
in bags (yes/no)
6. Dust on clean side of bags
(yes/no)
7. Other signs of malfunctions or
potential malfunctions (yes/no)
8. Describe other malfunctions or signs of potential malfunctions.
9. Describe corrective act1on(s) taken.
10. Date and time corrective
action taken
11. Inspected by
(Print/Type Name)
(Title)
(Signature)
(Date)
(Print/Type Name)
TTitle)
(Signature)
(Date)
Figure 2. Air Pollution Control Device Inspection Checklist
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ROADWAYS [61.143]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A.
Asbestos-containing waste material
Asbestos mill
Asbestos tailings
Roadways
STANDARD
Construction or maintenance of a roadway with asbestos tailings or asbestos-
containing waste material 1s not allowed.
EXEMPTIONS [61.143(a),(b),(c)]
Exemptions to this prohibition are allowed for asbestos tailings if they are:
Used on a temporary roadway on an area of asbestos ore deposits; or
Used on a temporary roadway at an asbestos mill site and the tailings
have been encapsulated with resinous or bituminous binder (i.e.,
covered or coated with material such as tar or asphalt) and the
roadway surface 1s maintained at least once each year to prevent dust
emissions; or
Encapsulated in asphalt concrete that meets Section 401 of the
Standard Specifications for Construction of Roads and Bridges on
Federal Highway Projects or its equivalent. (This document may be
obtained from the Federal Highway. Administration.)
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MANUFACTURING [61.144]
DEFINITIONS
The following terms used in this section are defined in Appendix A.
Administrator
Asbestos
Commercial asbestos
Fugitive sources
Malfunction
Manufacturing
Outside air
Owner or operator
Particulate asbestos material
Visible emissions
APPLICABILITY [61.144(a)]
The standard for manufacturing applies to the following manufacturing
operations using commercial asbestos:
Cloth, cord, wicks, tubing, tape, twine, rope, thread, yarn, roving,
lap, or other textile products;
Cement products;
Fireproofing and Insulating materials;
Friction products (refers primarily to clutch facings, brake pads, and
brake linings);
Paper, millboard, felt;
Floor tile;
Paints, coatings, caulks, adhesives, sealants;
Plastics, rubber materials;
Chlorine utilizing the asbestos diaphragm technology;
Shotgun shell wads; and
Asphalt concrete.
STANDARD [61.144(b)]
Owners or operators of any manufacturing operations to which this section
applies must operate with no visible emissions of asbestos to the outside air
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from the manufacturing operations, the building or structure the operations
are conducted in, or from any other fugitive source; or must follow Air
Cleaning (61.152) that have been set forth by the NESHAP regulations to clean
emissions containing particulate asbestos material before they are released to
the outside air.
Inspection and Monitoring Requirements
Owners and operators of affected manufacturing operations must do the
following:
Monitor for visible emissions (i.e., observe and record) at each
potential source of asbestos emissions from any part of the
manufacturing facility daily with the monitoring period lasting at
least 15 seconds for each source of emissions. Monitoring must be
done during daylight hours.
Inspect each air cleaning device weekly for proper operation and for
changes that signal potential malfunctions.
Record all monitoring and inspections on forms similar to Figures 1
and 2 on pages 3 and 4, respectively. As a minimum, record:
- Date and time of inspection;
- Presence or absence of visible emissions;
- If a fabric filtration control device is used, the condition of
fabric filters and presence of dust deposits on the clean side of
fabric filters;
- Corrective actions taken; and
- Daily hours of air cleaning device operation.
Furnish upon request and make available during normal working hours,
all required records.
All records of monitoring and Inspections must be kept for at least 2
years.
If visible emissions are observed, then the owner or operator must
submit quarterly reports to the Administrator of the monitoring
results. Reports need only be submitted for those quarters 1n which
visible emissions occurred. The reports must be postmarked within 30
days of the end of the calendar quarter.
Exceptions To Monitoring Requirements
If the construction of an air cleaning device 1s such that the weekly
Inspections cannot be made without dismantling beyond opening the device
then, instead of inspections, a written maintenance plan may be submitted to
the Administrator that Includes at a minimum, the following:
Maintenance schedule; and
Recordkeeping plan.
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Date of
Inspection
(mo/day/yr)
Time of
Inspection
(a.m. /p.m.)
Control
device or
fugitive
emission
source
designation
or number
Visible
emissions
observed
(yes/no) ,
corrective
action
taken
Dally
operating
hours
Inspector's
Initials
Figure 1. Record of Visible Emission Monitoring
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1. Control device designation or number
2. Date of Inspection
3. Time of Inspection
4. Is control device operating
properly (yes/no)
5. Tears, holes, or abrasions
1n bags (yes/no)
6. Dust on clean side of bags
(yes/no)
7. Other signs of malfunctions or
potential malfunctions (yes/no)
8. Describe other malfunctions or signs of potential malfunctions,
9. Describe corrective action(s) taken.
10. Date and time corrective
action taken
11. Inspected by
(Print/Type Name)
(Title)
(Signature)
(Date)
(Print/Type Name)
(Title)
(Signature)
(Date)
Figure 2. Air Pollution Control Device Inspection Checklist
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DEMOLITION AND RENOVATION [61.145]
DEFINITIONS
The following terms used in this section are defined in Appendix A:
Adequately wet
Administrator
Asbestos
Category I nonfriable asbestos-containing material
Category II nonfriable asbestos-containing material
Cutting
Demolition
Emergency renovation operation
Facility
Facility component
Friable asbestos material
Glove bag
Grinding
In poor condition
Installation
Leak-tight
Nonscheduled renovation operation
Outside air
Owner or operator of a demolition or renovation activity
Particulate asbestos material
Planned renovation operations
Regulated asbestos-containing material
Remove
Renovation
Resilient floor covering
Strip
Structural member
Visible emissions
Working days
INSPECTION FOR ASBESTOS [61.145(a)]
To determine which of the applicability [61.145(a)], notification [61.145(b)],
or emission control [61.145(c)] procedures apply, the owner or operator of a
demolition or renovation activity must first thoroughly inspect the facility
or the part of the facility where the demolition or renovation will occur for
the presence of friable and nonfriable asbestos-containing material.
APPLICABILITY [61.145(a)]
The applicability requirements for this section have been divided into
different categories according to the amount of regulated asbestos-containing
material in the demolition or renovation activity and the nature of the
activity.
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Demolitions (Above Cutoff)
If the amount of regulated asbestos-containing material present in a facility
being demolished is (1) at least 80 linear meters (260 linear feet) on pipes,
or (2) at least 15 square meters (160 square feet) on other facility
components, or (3) where the amount of asbestos-containing material on pipes
and other components could not be measured before stripping, a total of at
least one cubic meter (35 cubic feet) from all facility components in a
facility being demolished, all notification requirements [61.145(b)] on pages
3-7, emission control procedures [61.145(c)] on pages 7-11, and waste disposal
requirements [61.150] apply.
Demolitions (Below Cutoff)
If the amount of regulated asbestos-containing material present 1n a facility
being demolished is (1) less than 80 linear meters (260 linear feet) on pipes,
and (2) less than 15 square meters (160 square feet) on other facility
components, and (3) where the amount of asbestos-containing materials on pipes
and other components could not be measured before stripping or demolition, the
total amount from all facility components in a facility being demolished is
less than one cubic meter (35 cubic feet) or there is no asbestos, none of the
emission control procedures [61.145(c)] or waste disposal requirements
[61.150] apply. The applicable notification requirements [61.145(b)] are
listed on pages 3-7.
Demolitions (Ordered)
If the facility is being demolished by an order of the State or local
government agency because the facility 1s structurally unsound and in danger
of imminent collapse, the applicable notification requirements [61.145(b)j are
described on pages 3-7. The emission control procedures [61.145(c)] that do
not apply are those presented under "removal of asbestos-containing material,"
"removal of units or sections," "stripping regulated asbestos-containing
material from facility components within a facility," and "burning of
facilities" on pages 7-11. The applicable waste disposal provisions are
contained in 61.150.
Renovations (Above Cutoff)
If the amount of regulated asbestos-containing material that will be stripped,
removed, dislodged, cut, drilled, or otherwise disturbed in a facility being
renovated including nonscheduled renovation operations is (1) at least 80
linear meters (260 linear feet) on pipes, or (2) at least 15 square meters
(160'square feet) on other facility components, or (3) where the amount of
asbestos-containing material on pipes and other components could not be
measured before stripping, a total of at least one cubic meter (35 cubic feet)
from all facility components, all notification requirements [61.145(b)] on
pages 3-7, emission control procedures [61.145(c)] on pages 7-11, and waste
disposal requirements (61.150) apply.
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Renovations (Below Cutoff)
If the amount of regulated asbestos-containing material that will be stripped,
removed or otherwise disturbed 1s less than all of the above stated
quantities, then none of the notification requirements, emission control
procedures, or waste disposal requirements apply.
Renovations (Planned)
Planned renovation operations Involving individual nonscheduled operations are
subject to all notification requirements [61.145(b)], emission control
procedures [61.145(c)], and waste disposal requirements (61.150) if, during a
calendar year of January 1 through December 31, the additive amount of
regulated asbestos-containing material that will be removed or stripped 1s
predicted to be more than any of; the quantities stated above, under
"Renovations (Above Cutoff)."
Renovations (Emergency)
If the estimated amount of regulated asbestos-containing materials to be
removed or stripped during an emergency renovation that results from a sudden,
unexpected event, is more than any of the quantities stated above, under
"Renovation (Above Cutoff)," all notification requirements [61.145(b)]f
emission control procedures [61.145(c)] and waste disposal requirements
(61.150), apply.
Exemption
Owners or operators of demolition and renovation operations are exempt from
the prohibitions to construct or modify contained in §61.05(a), the
application for approval requirements 1n §61.07, and the notification of
startup requirements in §61.09.
NOTIFICATION REQUIREMENTS [61.145(b)]
Notifying Responsibility
Each owner or operator of a demolition or renovation activity subject to this
subpart should provide the Administrator with written notices specifying an
intention to demolish or renovate a facility and provide updates to these
notices when the amount of asbestos-containing material affected changes by as
much as 20 percent. The notice should be sent by U.S. mall, by commercial
delivery service, or should be hand delivered.
Time Line for Submlttal of Notification
The stipulations concerning the appropriate manner of delivery or postmark of
the notice depends on the type of demolition and renovation activity. The
following notification times have been established:
Postmarked or delivered at least 10 working days before asbestos
stripping or removal work or other activity (such as site preparation
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that would break up, dislodge, or similarly disturb asbestos material)
begins, if the amount of asbestos affected by the demolition or
renovation is at least 80 linear meters (260 linear feet) on pipes or
15 square meters (160 linear feet) on other facility components or,
where the amount of asbestos containing material could not be measured
prior to stripping, a total of at least one cubic meter (35 cubic
feet) from all facility components.
Postmarked or delivered at least 10 working days before demolition
begins if the amount of affected asbestos is less than 80 linear
meters (260 linear feet) on pipes or less than 15 square meters (160
linear feet) on other facility components or, where the amount of
asbestos containing material could not be measured prior to stripping,
a total of less than one cubic meter (35 cubic feet) from all facility
components.
Postmarked or delivered at least 10 working days before the end of the
calendar year preceding the year for which the notice is given for
planned renovation operations involving nonscheduled operations if the
amount of asbestos affected in the renovation activities is more than
the previously stated amount.
Postmarked or delivered as early as possible, but no later than the
following working day, after asbestos stripping or removal work or the
sanding, grinding, cutting, or abrading of Category I and II
nonfriable asbestos-containing material in an emergency renovation
activity or a government ordered demolition activity begins.
If the planned start date of a demolition or renovation operation
changes after a notification is submitted, the Administrator must be
notified according to the following schedule:
- If the new start date is later than the original start date, provide
a notice by telephone as soon as possible before the original start
date and provide a notice 1n writing as soon as possible before, but
no later than, the original start date.
- If the new start date is earlier than the original start date,
provide a notice 1n writing at least 10 working days before any
stripping or removal work begins for demolition and renovation
operations where the amount of asbestos affected is above the cutoff
and for demolition operations where the amount of asbestos affected
is below the cutoff, provide a notice at least 10 working days
before demolition begins.
In no event shall an operation begin on a date other than the date
contained in the written notice of the new start date.
Contents of Notification
All notifications must be 1n a form similar to that shown 1n Figure 1 on pages
12 and 13. For demolitions (above cutoff and ordered) and for renovations
(above cutoff, planned, and emergency), all notifications must contain at
least the following information:
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An indication of whether the notice is an original or a revised
notification.
Name, address, and telephone number of the facility owner and operator
and the owner or operator of the asbestos removal firm.
Type of operation: demolition or renovation.
Facility description including at least the following:
- Size (square meters [or square feet] and number of floors)
- Age
- Present and prior uses
Procedure, including analytical methods, employed to detect the
presence of asbestos-containing material.
Estimate of the approximate amount of regulated asbestos-containing
material to be stripped using the appropriate units, either linear
meters (linear feet) for pipes, square meters (square feet) for other
facility components, or cubic meters (cubic feet), if the asbestos
containing material will be stripped from the facility components
without being measured.
Estimate of the amount of Category I and Category II nonfriable
asbestos-containing materials in the affected part of the facility
that will not be removed before demolition.
Location and address, including building number or name and floor or
room number, if appropriate, street address, city, county, and State
of the facility being demolished or renovated.
Scheduled starting and completion dates of asbestos removal work (or
any other activity, such as site preparation that would break up,
dislodge, or similarly disturb asbestos material) in a demolition
(with the exception of government ordered demolitions) or renovation,
and scheduled starting and completion dates of the demolition or
renovation.
The beginning and ending dates of the report period for planned
renovation operations involving individual nonscheduled operations.
Description of planned demolition or renovation work including the
demolition and renovation techniques to be used and a description of
the affected facility components.
Description of work practice and engineering controls to be used to
comply with the requirements of this standard.
Name and location of the waste disposal site where the asbestos-
containing waste material will be deposited.
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Certification that only persons trained as required in paragraph
(c)(8) will supervise the stripping and removal of asbestos-containing
material (effective 1 year after promulgation).
Description of procedures for handling the finding of unexpected
regulated asbestos-containing material or Category II nonfriable
asbestos-containing material that has been crumbled, pulverized, or
reduced to powder.
For government ordered demolitions, include the name, title, and
authority of the government representative ordering the demolition,
the date an order was issued, and the date the demolition was ordered
to begin by a State or local government representative. Attach a copy
of the order to the notification.
For emergency renovations, include the date and hour the emergency
occurred, a description of the event and an explanation of how the
event has caused unsafe conditions or would cause equipment damage or
unreasonable financial burden.
Name, address, and telephone number of the waste transporter.
For demolitions (below cutoff), all notifications must contain at least the
following information:
An indication of whether the notice is an original or a revised
notification.
Name, address, and telephone number of the facility owner and operator
and the owner or operator of the asbestos removal firm.
Type of operation: demolition or renovation.
Facility description including at least the following:
- Size (square meters [or square feet] and number of floors)
- Age
- Present and prior uses
Procedure, Including analytical methods, employed to detect the
presence of asbestos-containing material.
Estimate of the approximate amount of regulated asbestos-containing
material to be stripped using the appropriate units, either linear
meters (linear feet) for pipe, square meters (square feet) for other
facility components, or cubic meters (cubic feet), if the asbestos-
containing material will be stripped from the facility components
without being measured.
Estimate of the amount of Category I and Category II nonfriable
asbestos-containing materials in the affected part of the facility
that will not be removed before demolition.
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Location and street address, Including building number or name and
floor or room number, if appropriate, street address, city, county,
and State of the facility being demolished.
Scheduled starting and completion dates of demolition.
Description of procedures for handling the finding of unexpected
regulated asbestos-containing material or Category II nonfriable
asbestos-containing material that been crumbled, pulverized, or
reduced to powder.
PROCEDURES FOR ASBESTOS EMISSIONS CONTROL [61.145(c)]
Removal of Asbestos-Containing Material
All regulated asbestos-containing materials must be removed from a facility
being demolished or renovated before any activities are carried out that would
break up, dislodge or similarly disturb the materials or preclude access to
the materials for subsequent removal.
Exceptions From Removal
Regulated asbestos-containing materials do not need to be removed before
demolition if:
The material consists of Category I nonfriable asbestos-containing
materials such as packing, gaskets, asphalt roofing, and vinyl floor
tile, which is not in poor condition and is not friable; or
?-
The material is on a facility component that is encased in concrete or
other similarly hard material and is adequately wet whenever exposed
during demolition; or
The material was not accessible for testing and was not discovered
until after demolition began and, as a result of the demolition, the
material cannot be safely removed. If not removed for safety reasons,
the exposed material and any asbestos contaminated debris must be
treated as asbestos-containing waste material and adequately .wet at
all times until final disposal; or
The materials are Category II nonfriable asbestos-containing materials
that are unlikely to become crumbled, pulverized, or reduced to powder
during demolition.
Removal of Units or Sections
When a facility component that contains regulated asbestos-containing
materials or that is covered or coated with regulated asbestos-containing
materials 1s being taken out of the facility as a unit or in sections, removal
must adhere to the following procedures:
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Adequately wet any regulated asbestos-containing materials exposed
during cutting or disjoining (i.e., separating or detaching)
operations; and
Carefully lower the units or sections to the floor or to ground level
without dropping, throwing, sliding or otherwise damaging or
disturbing the regulated asbestos-containing material.
Stripping Regulated Asbestos-Containing Material From Facility Components
Within a Facility
When regulated asbestos-containing material is stripped from facility
components while they remain in place within a facility, the regulated
asbestos-containing material must be adequately wet during the stripping
operation.
Stripping Regulated Asbestos-Containing Material from Facility Components that
Have Been Taken Out as Units or Sections
When facility components that are covered, coated, or contain regulated
asbestos-containing materials are removed from a facility as a unit or in
sections, the components must be contained in leak-tight wrapping or the
regulated asbestos-containing material must be stripped. If regulated
asbestos-containing material is stripped from these components, the following
procedures must be used:
Adequately wet the regulated asbestos-containing material during
stripping; or
Use a local exhaust ventilation and collection system designed and
operated to capture the particulate asbestos materials produced by the
stripping;
- The local exhaust system must exhibit no visible emissions to the
outside air; or
- The system must be designed and operated in accordance with the
requirements contained 1n Air Cleaning (61.152).
Exception From Stripping Regulated Asbestos-Containing Material from Facility
Components that Have Been Taken Out as Units or Sections
Stripping of asbestos is not required 1f the unit or section is a large
facility component (excluding beams) such as reactor vessels, large tanks, and
steam-generators, and the following conditions are met:
The component can be removed, transported, stored, and reused without
disturbing or damaging the asbestos; and
The component 1s encased 1n a leak-tight wrapping that is labeled in
accordance with the legend given below during all loading and
unloading operations and during storage.
-------
DANGER
(2.5 cm (1 inch) Sans Serif, Gothic or Block)
ASBESTOS DUST HAZARD
(2.5 cm (1 Inch) Sans Serif, Gothic or Block)
CANCER AND LUNG DISEASE HAZARD
(1.9 cm (3/4 inch) Sans Serif, Gothic or Block)
Authorized Personnel Only
(14 Point Gothic)
- Spacing between the lines should be at least equal to the height of
the upper two lines.
Regulated Asbestos-Containing Materials that Have Been Removed or Stripped
All asbestos-containing materials, including those that have been removed or
stripped must be handled as follows:
Materials must be adequately wet to ensure that they will remain wet
until they are collected and contained or treated in preparation for
disposal in accordance with the Standard for Waste Disposal for
Demolition and Renovation (61.150); and
Materials must be carefully lowered to the ground or a lower floor
without dropping, throwing, sliding, or otherwise damaging them; and
Materials must be transported to the ground via leak-tight chutes or
containers if they have been removed or stripped more than 50 feet
above the ground level and were not removed as units or sections.
Exceptions from Wetting
Wetting of regulated asbestos-containing material is not required in the
following situations:
In a renovation where the Administrator has determined that wetting
would unavoidably damage equipment or present a safety hazard and one
of the following emission control methods is employed:
- A local exhaust ventilation and collection system to catch the
particulate asbestos material; the system must exhibit no visible
emissions to the outside air or must be designed and operated in
accordance with the requirements contained in Air Cleaning (61.152);
or
- A glove-bag system to contain the particulate asbestos material; or
- A leak-tight wrapping to contain all asbestos-containing material
prior to dismantlement; or
- Other equivalent methods for which approval has been received from
the Administrator based on a determination that it is equivalent to
wetting as a means of controlling asbestos emissions.
-------
- If an equivalent alternative is used, a copy of the Administrator's
written approval shall be kept at the worksite and available for
inspection.
Regulated asbestos-containing materials contained in leak tight
wrapping that have been removed in accordance with the paragraphs on
"stripping regulated asbestos-containing material from facility
components that have been taken out as units or sections" on page 8,
and "exception from wetting" for renovations, on page 4, need not be
wetted.
When the temperature is below freezing at the point of removal. In
these cases the owner or operator should:
- Remove facility components coated or covered with asbestos-
containing materials as units or in sections to the maximum extent
possible; and
- During periods when wetting operations are suspended due to freezing
temperature, the owner or operator must record the temperature at
the beginning, middle, and end of each work day; and
- Keep daily temperature records available during normal business
hours for the Administrator's inspection. The records should be
kept at the demolition or renovation site and the owner or operator
should retain them for at least 2 years.
Training for Handling of Regulated Asbestos-Containing Material (Effective 1
year After Promulgation)
All asbestos-containing material shall be stripped, removed, and otherwise
handled by an owner or operator of a demolition or renovation activity with at
least one on-s1te representative trained 1n the provisions of this regulation
and the means of complying with them. The minimum training will Include:
Applicability of regulations;
Notification requirements;
Material identification procedures;
Control procedures for removals Including;
- Wetting;
- Local exhaust ventilation;
- - Negative pressure enclosures;
- Glove-bag procedures; and
- High Efficiency Paniculate Air (HEPA) filters.
Waste disposal practices;
Reporting and recordkeeplng;
Asbestos hazards and worker protection.
10
-------
Records must be kept demonstrating that the required training has taken place
and these records must be available for Inspection by the Administrator during
normal business hours at the demolition and renovation site. This requirement
becomes effective one year after promulgation of the regulations. Individuals
trained 1n accordance with this requirement must take a refresher course at
least every 2 years.
Wrecking of Structurally Unsound Facilities
When a structurally unsound facility Is being demolished by order of State or
local governments, that portion of the facility having regulated asbestos-
containing materials should be adequately wet during the wrecking operation.
Burning of Facilities
All regulated asbestos centaln1ng-mater1als, Including Category I and Category
II nonfrlable materials must be removed from a facility that is to be
destroyed by burning.
11
-------
NOTIFICATION OF DEMOLITION AND RENOVATION (continued)
X. DESCRIPTION OF PLANNED DEMOLITION OR RENOVATION WORK, AND METHOD(S) TO BE USED:
XI. DESCRIPTION OF ENGINEERING CONTROLS AND WORK PRACTICES TO BE USED TO CONTROL
EMISSIONS OF ASBESTOS AT THE DEMOLITION AND RENOVATION SITE:
XII. WASTE TRANSPORTER II
Name:
Address
Citys
State i
Contact Person i
Zip:
Telephone:
WASTE TRANSPORTER 12
Name:
Address:
City:
State:
Contact Person :
Zip:
Telephone:
XIII. WASTE DISPOSAL SITE
Name:
Address:
City:
State:
Zip:
Telephonei
XIV. IF DEMOLITION ORDERED BY A GOVERNMENT AGENCY, PLEASE IDENTIFY THE AGENCY BELOW:
Titlei
Authorityt
Date of Order (MM/DD/YT):
Date Ordered to Begin (MM/DD/TT):
XV. FOR EMERGENCY RENOVATIONS
Date and Hour of Emergency (MM/DD/YY):
Description of the Sudden, Unexpected Event:
Explanation of Bow the Event Caused Unsafe Conditions or Serious Disruption of Industrial
Operations t
XVI. DESCRIPTION OF PROCEDURES TO BE FOLLOWED IN THE EVENT THAT UNEXPECTED ASBESTOS IS
FOUND OR PREVIOUSLY NONFRIABLE ASBESTOS MATERIAL BECOMES CRUMBLED, PULVERIZED,
OR REDUCED TO POWDER.
XVII.I CERTIFY THAT AN INDIVIDUAL TRAINED IN THE PROVISIONS OF THIS REGULATION (40 CFR
PART 61, SUBPART M)WILL BE ON-SITE DURING THE DEMOLITION OR RENOVATION AND EVIDENCE
THAT THE REQUIRED TRAINING HAS BEEN ACCOMPLISHED BY THIS PERSON WILL BE AVAILABLE
FOR INSPECTION DURING NORMAL BUSINESS HOURS. (Required 1 year after promulgation)
(Signature of Owner/Operator)
(Date)
XVIII. I CERTIFY THAT THE ABOVE INFORMATION IS CORRECT.
(Signature of Owner/Operator)
(Date)
Figure 1. Notification of Demolition and Renovation
12
-------
NOTIFICATION OF DEMOLITION AND RENOVATION
I. FACILITY INFORMATION (Identify owner, removal contractor, and other operator)
OWNER:
Address t
City:
Statei
Zip i
Contacti
Tell
REMOVAL CONTRACTOR:
Addresst
City:
States
Zip i
Contacti
Tell
OTHER OPERATOR:
Addressi
City i
Statei
Zip i
Contacti
Tell
II. TYPE OF NOTIFICATION (O - Original/R - Revised) i
III.TYPE OF OPERATION (D - Oemolition/R - Renovation) i
IV. IS ASBESTOS PRESENT? (yes/No)
V. FACILITY DESCRIPTION (Include building name, number and floor or room number)
Bldg Namet
Address i
Addresss
City i
Statei
I Countyi
Site locationi
Building Size
SgHeteri
SqPti
f of Floorsi
Age in Yearsi
Present Use:
Prior Osei
VI. PROCEDURE, INCLUDING ANALYTICAL METHOD, IF APPROPRIATE, USED TO DETECT THE PRESENCE
OF ASBESTOS MATERIAL:
VII.APPROXIMATE AMOUNT OF RACM TO BE REMOVED AND NONFRIABLE ASBESTOS MATERIAL THAT WILL
NOT BE REMOVED. SPECIFY THE AMOUNT OF ASBESTOS BELOW.
Nonfriable Asbestos Mat-
erial Not to Be Removed
RACM To
Be Removed Category I Category II
Pipes - Linear Feet
Pipes - Linear Meters
Surface Area - Square Feet
Surface Area - Square Meters
Volume RACM Off Facility Component - Cubic Feet
Volume RACM Off Facility Component - Cubic Meter
VIII. SCHEDULED DATES OF ASBESTOS REMOVAL (MM/DD/YY)
Start:
Completion:
IX. SCHEDULED DATES OF DEMO/RENOVATION (MM/DD/YY)
Start:
Completion:
Continued on page two
Figure 1. Notification of Demolition and Renovation
13
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SPRAYING [61.146]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Administrator
Asbestos
Friable asbestos material
Outside air
Owner or operator
Particulate asbestos material
Visible emissions
STANDARD FOR BUILDINGS, STRUCTURES, PIPES, AND CONDUITS [61.146(a)]
The owner or operator of an operation in which asbestos-containing materials
are spray applied may not use materials that contain more than 1 percent
asbestos for spray application on buildings, structures, pipes, and conduits.
The determination of asbestos content must be made using the method specified
in Appendix A, Subpart F, Title 40 of the Code of Federal Regulations (40 CFR)
Part 763, Section 1, Polarized Light Microscopy.
STANDARD FOR EQUIPMENT AND MACHINERY [61.146(b)]
For spray-on application of materials that contain more than 1 percent
asbestos on equipment and machinery, the owner or operator of an operation
must:
Notify the Administrator at least 20 days before beginning the
spraying operation and Include the following Information In the
notice:
- Name and address of owner or operator;
- Location of spraying operation;
- Procedures to be followed to meet the requirements of this standard.
Discharge no visible emissions to the outside air from spray-on
application of the asbestos-containing material or use the methods
specified in Air Cleaning (61.152) to clean emissions containing
particulate asbestos material before they are released to the outside
air.
EXCEPTIONS TO STANDARDS [61.146(c)]
The requirements of this section do not apply to the spray-on application of
materials where the asbestos fibers in the materials are encapsulated with a
bituminous or resinous binder (such as asphalt or tar) during spraying and the
materials are not friable after drying.
-------
EXEMPTIONS [61.146(d)]
Owners or operators of sources subject to this paragraph are exempt from the
prohibition to construct or modify 1n §61.05(a), the application for approval
of construction or modification requirements in §61.07, and notification of
startup requirements 1n §61.09.
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FABRICATING [61.147]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Administrator
Asbestos
Commercial asbestos
Fabricating
Fugitive sources
Malfunction
Outside air
Owner or operator
Particulate asbestos material
Regulated asbestos-containing material
Visible emissions
APPLICABILITY [61.147(a)]
This section applies to the following fabricating operations using commercial
asbestos:
The fabrication of cement building products.
The fabrication of friction products (refers primarily to clutch
facings, brake pads, and brake linings), except those operations that
primarily Install asbestos friction materials on motor vehicles.
The fabrication of cement or silicate board for ventilation hoods;
ovens; electrical panels; laboratory furniture; bulkheads, partitions,
and ceilings for marine construction; and flow control devices for the
molten metal industry.
STANDARD [61.147(b)]
Each owner or operator of any of the fabricating operations to which this
section applies shall either:
Discharge no visible emissions to the outside air from any of the
operations or from any building or structure In which they are
conducted or from any other fugitive sources; or
Use the methods specified by A1r Cleaning (61.152) to clean emissions
containing particulate asbestos material before they reach the outside
air.
Inspection and Monitoring Requirements
Owners and operators of fabricating operations must comply with the following:
-------
Monitor for visible emissions (i.e., observe and record) at each
potential source of asbestos emissions from any part of the
fabricating facility daily with the monitoring period lasting at least
15 seconds for each source of emissions. Monitoring must be done
during daylight hours.
Inspect each air cleaning device weekly for proper operation and for
changes that signal potential malfunctions.
Record all monitoring and inspections on forms similar to Figures 1
and 2 on pages 3 and 4 respectively. As a minimum record:
- Date and time of inspection;
- Presence or absence of visible emissions;
- If a fabric filtration control device is used, the condition of
fabric filters and presence of dust deposits on clean side of fabric
filters;
- Corrective actions taken; and
- Daily hours of air cleaning device operation.
Furnish upon request and make available during normal working hours,
all required records.
All records of monitoring and inspections must be kept for at least 2
years.
If visible emissions are observed, then the owner or operator must
submit quarterly reports to the Administrator of the monitoring
results. Reports need only be submitted for those quarters in which
visible emissions occurred. The reports must be postmarked within 30
days of the end of the calendar quarter.
Exceptions To Monitoring Requirements
If the construction of an air cleaning device is such that the weekly
Inspections cannot be made without dismantling beyond opening the device,
then, Instead of Inspections, a written maintenance plan may be submitted to
the Administrator that includes at a minimum, the following:
Maintenance schedule; and
Recordkeeping plan.
-------
Date of
Inspection
(mo/day/yr)
Time of
Inspection
(a. m. /p.m.)
Control
device or
fugitive
emission
source
designation
or number
Visible
emissions
observed
(yes/no),
corrective
action
taken
Dally
operating
hours
Inspector's
Initials
Figure 1. Record of Visible Emission Monitoring
-------
1. Control device designation or number
2. Date of Inspection
3. Time of Inspection
4. Is control device operating
properly (yes/no)
5. Tears, holes, or abrasions
1n bags (yes/no)
6. Dust on clean side of bags
(yes/no)
7. Other signs of malfunctions or
potential malfunctions (yes/no)
8. Describe other malfunctions or signs of potential malfunctions.
9. Describe corrective act1on(s) taken.
10. Date and time corrective
action taken
11. Inspected by
(Print/Type Name) (Title) (Signature) (Date)
(Print/Type Name) (Title) (Signature) (Date)
Figure 2. Air Pollution Control Device Inspection Checklist
-------
INSULATING MATERIALS [61.148]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Commercial asbestos
Facility
Facility component
Friable asbestos material
Owner or operator
STANDARD
An owner or operator of a facility may not Install or reinstall any Insulating
materials on a facility component 1f these materials contain commercial
asbestos and if the materials are either molded and friable or are applied wet
and become friable after drying. The provisions of this paragraph do not
apply to spray-applied insulating materials regulated under the Standard for
Spraying (61.146).
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WASTE DISPOSAL REQUIREMENTS FOR ASBESTOS MILLS [61.149]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Active waste disposal site
Adequately wet
Administrator
Asbestos
Asbestos-containing waste material
Asbestos mill
Asbestos tailings
Asbestos waste from control devices
Facility
Facility component
Friable asbestos material
Fugitive sources
Outside air
Owner or operator
Particulate asbestos material
Regulated asbestos-containing material
Visible emissions
Waste generator
Waste shipment record
Working days
APPLICABILITY [61.149]
This section applies to each owner or operator of any source covered under the
provisions of the Standards for Asbestos Mills (61.142).
STANDARD [61.149(a)(b)(c)]
Each owner or operator of any asbestos mill source shall:
Deposit all asbestos-containing waste material at a waste disposal
site operated 1n accordance with the provisions of the Standard for
Active Waste Disposal Sites (61.154); and
' Discharge no visible emissions to the outside air from the transfer of
control device asbestos waste to the tailings conveyor, or use the
methods specified by A1r Cleaning (61.152) to clean emissions; and
Dispose of the asbestos waste from control devices in accordance with
[61.150(aj], or by discharging no visible emissions or by using the
procedures contained 1n "waste disposal methods for asbestos-
containing waste material" on page 2; and
-------
Discharge no visible emissions to the outside air during the
collection, processing, packaging, or transporting of any asbestos-
containing waste material or use one of the disposal methods described
below in "waste disposal methods for asbestos-containing waste
material."
Waste Disposal Methods for Asbestos-Containing Waste Material
Use a wetting agent as follows:
- Adequately mix all asbestos-containing waste material with a wetting
agent recommended by the manufacturer of the agent to effectively
wet dust and tailings, before depositing the material at a waste
disposal site. Use the agent as recommended for the particular dust
by the manufacturer of the agent; and
- Discharge no visible emissions to the outside air from the wetting
operation or use the methods specified by Air Cleaning (61.152) to
clean emissions.
- Wetting may be suspended when the ambient temperature at the waste
disposal site is less than -9.5 °C (15 °F). When wetting operations
are suspended, hourly temperature recordings must be kept and the
records retained for at least 2 years in a form suitable for
inspection.
Use an alternative treatment that has received approval by the
Administrator.
Obtaining Approval for Alternative Treatment
To obtain approval for an alternative treatment, a written request must be
submitted to EPA. The request must demonstrate that the following criteria
are met:
The method controls asbestos emissions to levels equivalent to those
achieved by currently required methods;
The method is suitable for the Intended application;
The method will not violate other regulations; and
The method will not result in increased water pollution, land
pollution, or occupational hazard.
TRANSPORTATION OF ASBESTOS-CONTAINING WASTE MATERIAL [61,149(d)]
If asbestos-containing waste material 1s transported by vehicle to a disposal
site, 1t should be:
In marked (placarded) vehicles with the signs visible during the
loading and unloading of the waste. The markings must:
-------
- Be posted In such a manner that a person can easily read the legend.
- Conform to the requirements for 51 cm. x 36 cm. (20 1n. x 14 1n.)
upright format signs as specified in 29 CFR 1910.145 and this
paragraph; and
- Display the following legend in the lower panel with letter sizes
and styles of a visibility at least equal to those specified below:
DANGER
(2.5 cm (1 Inch) Sans Serif, Gothic or Block)
ASBESTOS DUST HAZARD
(2.5 cm (1 Inch) Sans Serif, Gothic or Block)
CANCER AND LUNG DISEASE HAZARD
(1.9 cm (3/4 inch) Sans Serif, Gothic or Block)
Authorized Personnel Only
(14 Point Gothic)
- Spacing between the lines should be at least equal to the height of
the upper two lines.
Provide a copy of the waste shipment record described below in "waste
shipment record," to the disposal site owner or operator at the same
time as the asbestos-containing material arrives at the disposal site.
WASTE SHIPMENT RECORD [61.149(e)]
For all asbestos-containing waste material transported off site:
Maintain asbestos waste shipment records using a form similar to that
shown 1n Figure 1 that Includes the following Information:
- Name, address, and telephone number of the waste generator;
- Name and address of the local State, or EPA Regional agency
responsible for administering the asbestos NESHAP program.
- Quantity of asbestos-containing waste material in cubic meters or
cubic yards;
- Name and telephone number of the disposal site operator;
- Name and physical location of the disposal site;
- Date transported;
- Name, address and telephone number of the transporter(s); and
- A certification that the contents of the shipment are accurately
described and classified and that they are packaged properly to meet
all applicable international and government transport regulations.
Retain a copy of the asbestos waste shipment record for at least 2
years.
If a copy of the waste shipment record signed by the owner or operator
of the waste disposal site has not been returned to the generator
within 35 days from the date the waste was accepted by the initial
transporter, the generator must contact the transporter and/or the
-------
owner or operator of the waste disposal site to determine the status
of the shipment.
If a copy of the waste shipment record signed by the owner or operator
of the waste disposal site has not been returned to the generator
within 45 days from the date the waste was accepted by the initial
transporter, the generator must submit a written report to the agency
responsible for administering the asbestos NESHAP program for the
waste generator. The report must include:
- a copy of the waste shipment record for which a copy signed by the
owner or operator of the waste disposal site was not received.
- A cover letter signed by the waste generator explaining the efforts
taken to locate the asbestos waste shipment and the results of those
efforts.
Furnish upon request, and make available during normal business hours
for inspection, all records required under this section.
-------
Generator ]
Transporter
V
4->
1-
(/>-
to
V)
0
0.
Ul
5
1. Work site name and mailing address Owner's name
2. Operator's name and address
3. Waste disposal site (WDS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
Owner's
telephone no.
Operator's
telephone no.
WDS
phone no.
agency
6. Containers
No. Type
7. Total quantity
m3 (yd3)
8. Special handling Instructions and additional Information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are 1n all
respects 1n proper condition for transport by highway according to
applicable International and government regulations.
Printed/typed name & title
10. Transporter 1 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
12. Discrepancy Indication space
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
13. Waste disposal site
owner or operator: Certification of receipt of asbestos materials
covered bv this manifest except as noted 1n Item 12.
Printed/typed name & title
Signature
Month Day Year
(Continued
Figure 1. Waste Shipment Record
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INSTRUCTIONS
Waste Generator Section (Items 1-9)
1. Enter the name of the facility at which asbestos waste 1s generated and
the address where the facility 1s located. In the appropriate spaces,
also enter the name of the owner of the facility and the owner's phone
number.
2. If a demolition or renovation, enter the name and address of the company
and authorized agent responsible for performing the asbestos removal.
In the appropriate spaces, also enter the phone number of the operator.
3. Enter the name, address, and physical site location of the waste
disposal site (WDS) that will be receiving the asbestos materials. In
the appropriate spaces, also enter the phone number of the WDS. Enter
"on-s1te" 1f the waste will be disposed of on the generator's property.
4. Provide the name and address of the local, State, or EPA Regional office
responsible for administering the asbestos NESHAP program.
5. Indicate the types of asbestos waste materials generated. If from a
demolition or renovation, Indicate the amount of asbestos that 1s
- Friable asbestos material
- Nonfrlable asbestos material
6. Enter the number of containers used to transport the asbestos materials
listed 1n Item 5. Also enter one of the following container codes used
1n transporting each type of asbestos material (specify any other type
of container used 1f not listed below):
DM - Metal drums, barrels
DP - Plastic drums, barrels
BA - 6 mil plastic bags or wrapping
7. Enter the quantities of each type of asbestos material removed 1n units
of cubic meters (cubic yards).
8. Use this space to Indicate special transportation, treatment, storage
or disposal or Bill of Lading Information. If an alternate waste
disposal site 1s designated, note 1t here. Emergency response
telephone numbers or similar Information may be Included here.
NOTE: The waste generator must retain a copy of this form.
(continued)
Figure 1. Waste Shipment Record
-------
9. The authorized agent of the waste generator must read and then sign
and date this certification. The date 1s the date of receipt by
transporter.
Transporter Section (Items 10 & 11)
10. & 11. Enter name, address, and telephone number of each transporter
used, 1f applicable. Print or type the full name and title of
person accepting responsibility and acknowledging receipt of
materials as listed on this waste shipment record for transport.
Enter date of receipt and signature.
NOTE: The transporter must retain a copy of this form.
Disposal Site Section (Items 12 & 13)
12. The authorized representative of the WDS must note 1n this space any
discrepancy between waste described on this manifest and waste actually
received as well as any Improperly enclosed or contained waste. Any
rejected materials should be listed and destination of those materials
provided. A site that converts asbestos-containing waste material to
nonasbestos material 1s considered a WDS.
13. The signature (by hand) of the authorized WDS agent Indicates
acceptance and agreement with statements on this manifest except as
noted In Item 12. The date 1s the date of signature and receipt of
shipment.
NOTE: The WDS must retain a completed copy of this form. The WDS must
also send a completed copy to the operator listed 1n Item 2.
Figure 1. Waste Shipment Record
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STANDARD FOR WASTE DISPOSAL FOR MANUFACTURING, FABRICATING, DEMOLITION,
RENOVATION, AND SPRAYING OPERATIONS [61.150]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Active waste disposal site
Adequately wet
Administrator
Asbestos
Asbestos-containing waste materials
Asbestos waste from control devices
Category I nonfrlable asbestos^-contalning material
Category II nonfrlable asbestos-containing material
Demolition
Fabricating
Facility
Facility component
Friable asbestos material
Leak-tight
Manufacturing
Outside air
Owner or operator
Particulate asbestos material
Regulated asbestos-containing material
Renovation
Visible emissions
Waste generator
Waste shipment record
APPLICABILITY [61.150]
This section applies to each owner or operator of any of the following
sources:
Manufacturing (61.144);
Fabricating (61.147);
. Demolition (61.145);
Renovation (61.145); and
Spraying (61.146).
EMISSION CONTROL STANDARD [61.150(a)]
Each owner or operator of any of the above sources must discharge no visible
emissions to the outside air during the collection, processing (Including
-------
Incineration), packaging, or transporting of any asbestos-containing material
generated by the source, or use one of the following treatments:
Adequately wet asbestos-containing waste material as follows:
- Mix control device asbestos waste to form a slurry and adequately
wet other asbestos-containing waste material; and
- Discharge no visible emissions to the outside air from collection,
mixing, wetting, and handling operations, or use the methods
specified by Air Cleaning (61.152) to clean emissions containing
particulate asbestos material; and
- After wetting, seal all asbestos-containing waste material in leak-
tight containers while wet; or, for materials that will not fit into
containers without additional breaking, put materials into leak-
tight wrapping; and
- Label the containers or wrapped materials using warning labels
specified by Occupational Safety and Health Standards of the
Department of Labor, Occupational Safety and Health Administration
(OSHA) under 29 CFR 1910.1001(j)(2) or 1926.58(k)(2)(111). The
labels must be printed in letters of sufficient size and contrast to
be readily visible and legible.
- For asbestos-containing waste material that is to be transported off
the facility site, label containers or wrapped materials with the
name of the waste generator and the location at which the waste was
generated.
- This provision does not apply to Category I nonfriable asbestos-
containing materials or Category II nonfriable asbestos-containing
materials that do not become crumbled pulverized, or reduced to
powder during demolition or renovation.
Process asbestos-containing waste material Into nonfriable forms as
follows:
- Form all asbestos-containing waste material into nonfriable pellets
or other shapes; and
- Discharge no visible emissions to the outside air from collection
and processing operations or use the method specified by Air
Cleaning (61.152) to clean emissions containing particulate asbestos
material.
- This provision does not apply to Category I nonfriable asbestos-
containing materials or Category II nonfriable asbestos-containing
materials that do not become crumbled, pulverized, or reduced to
powder during demolition or renovation.
For facilities that are demolished without removing the regulated
asbestos-containing materials 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.
Asbestos-containing materials covered by this paragraph may be
transported in bulk without being placed 1n leak-tight containers or
wrapping.
Use an alternative treatment that has received prior approval by EPA.
-------
These treatment methods for asbestos-containing waste materials do not
apply to Category I nonfriable asbestos-containing material and
Category II nonfriable asbestos-containing materials that do not
become crumbled pulverized, or reduced to powder during demolition or
renovation.
Obtaining Approval for Alternative Treatment
To obtain approval for an alternative treatment, a written request must be
submitted to EPA. The request must demonstrate that the alternative method
meets the following criteria:
The method controls asbestos emissions to levels equivalent to those
achieved by currently required methods;
The method is suitable for the intended application;
The method will not violate other regulations; and
The method will not result in increased water pollution, land
pollution, or occupational hazard.
DISPOSAL OF ASBESTOS-CONTAINING WASTE MATERIAL [61.150(b)]
All asbestos-containing waste material, except Category I nonfriable asbestos-
containing waste material that has not been sanded, ground, cut, or abraded,
must be deposited as soon as is practical at:
A waste disposal site operated 1n accordance with the Standard for
Active Waste Disposal Sites (61.154); or
An EPA-approved site that converts regulated asbestos-containing
material and asbestos-containing waste material into nonasbestos
(asbestos-free) material according to the Standard for Sites that
. Convert Asbestos-Containing Waste Material Into Nonasbestos (Asbestos-
Free) Material (61.155).
TRANSPORTATION OF ASBESTOS-CONTAINING WASTE MATERIAL [61.150(c)]
If asbestos-containing waste material is transported by vehicle to a disposal
site, it should be:
In marked (placarded) vehicles with the signs visible during loading
and unloading of the waste. The markings must:
- Be posted 1n such a manner that a person can easily read the legend.
- Conform to the requirements for 51 cm. x 36 cm. (20 in. x 14 1n.)
upright format signs as specified in 29 CFR 1910.145 and this
paragraph; and
- Display the following legend in the lower panel with letter sizes
and styles of a visibility at least equal to those specified below:
-------
DANGER
(2.5 cm (1 inch) Sans Serif, Gothic or Block)
ASBESTOS DUST HAZARD
(2.5 cm (1 inch) Sans Serif, Gothic or Block)
CANCER AND LUNG DISEASE HAZARD
(1.9 cm (3/4 inch) Sans Serif, Gothic or Block)
Authorized Personnel Only
(14 Point Gothic)
- Spacing between the lines should be at least equal to the height of
the upper two lines.
Provide a copy of the waste shipment record described below in "waste
shipment record," to the disposal site owner or operator at the same
time as the asbestos-containing material arrives at the disposal site
WASTE SHIPMENT RECORD [61.150(d)]
For all asbestos-containing waste material transported off the facility site:
Maintain waste shipment records using a form similar to that shown in
Figure 1 that includes the following information:
- Name, address, and telephone number of the waste generator;
- Name and address of local, State, or EPA Regional agency responsible
for administering the asbestos NESHAP program.
- Quantity of asbestos-containing waste material in cubic meters or
yards;
- Name and telephone number of the disposal site operator;
- Name and physical location of the disposal site;
- Date transported;
- Name, address and telephone number of the transporter(s); and
- A certification that the contents of the shipment are accurately
described and that the material is packaged properly to comply with
all applicable international and government transport regulations.
Retain a copy of the asbestos waste shipment record for at least 2
years.
' If a copy of the waste shipment record signed by the owner or operator
of the designated waste disposal site has not been returned to the
generator within 35 days from the date the waste was accepted by the
initial transporter, the generator must contact the transporter and/or
the owner or operator of the designated waste disposal site to
determine the status of the shipment.
If a copy of the shipment record signed by the owner or operator of
the designated waste disposal site has not been returned to the
generator within 45 days of the date the waste was accepted by the
-------
Initial transporter, the generator must submit a written report to the
agency responsible for administering the asbestos NESHAP program for
the waste generator that contains the following:
- A copy of the waste shipment record, and
- A letter explaining the efforts taken to locate the asbestos waste
shipment and the results of those efforts.
Furnish upon request, and make available during normal business hours
for Inspection, all records under this section.
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Generator
Transporter
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1. Work site name and mailing address Owner's name
2. Operator's name and address
3. Waste disposal site (WDS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
Owner's
telephone no.
Operator's
telephone no.
WOS
phone no.
agency
6. Containers
No. Type
7. Total quantity
m3 (yd*)
8. Special handling Instructions and additional Information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are In all
respects 1n proper condition for transport by highway according to
applicable International and government regulations.
Printed/typed name & title
10. Transporter 1 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
12. Discrepancy Indication space
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
13. Waste disposal site
owner or operator: Certification of receipt of asbestos materials
covered bv this manifest except as noted in Item 12.
Printed/typed name & title
Signature
Month Day Year
(Continued
Figure 1. Waste Shipment Record
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INSTRUCTIONS
Waste Generator Section (Items 1-9)
1. Enter the name of the facility at which asbestos waste Is generated and
the address where the facility 1s located. In the appropriate spaces,
also enter the name of the owner of the facility and the owner's phone
number.
2. If a demolition or renovation, enter the name and address of the company
and authorized agent responsible for performing the asbestos removal.
In the appropriate spaces, also enter the phone number of the operator.
3. Enter the name, address, and physical site location of the waste
disposal site (WDS) that will be receiving the asbestos materials. In
the appropriate spaces, also enter the phone number of the WDS. Enter
"on-slte" 1f the waste will be disposed of on the generator's property.
4. Provide the name and address of the local, State, or EPA Regional office
responsible for administering the asbestos NESHAP program.
5. Indicate the types of asbestos waste materials generated. If from a
demolition or renovation, Indicate the amount of asbestos that 1s
- Friable asbestos material
- Nonfrlable asbestos material
6. Enter the number of containers used to transport the asbestos materials
listed 1n Item 5. Also enter one of the following container codes used
In transporting each type of asbestos material (specify any other type
of container used 1f not listed below):
DM - Metal drums, barrels
DP - Plastic drums, barrels
BA - 6 mil plastic bags or wrapping
7. Enter the quantities of each type of asbestos material removed 1n units
of cubic meters (cubic yards).
8. Use this space to Indicate special transportation, treatment, storage
or disposal or Bill of Lading Information. If an alternate waste
disposal site Is designated, note It here. Emergency response
telephone numbers or similar Information may be Included here.
NOTE: The waste generator must retain a copy of this form.
~'(continued)
Figure 1. Waste Shipment Record
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9. The authorized agent of the waste generator must read and then sign
and date this certification. The date 1s the date of receipt by
transporter.
Transporter Section (Items 10 & 11)
10. & 11. Enter name, address, and telephone number of each transporter
used, 1f applicable. Print or type the full name and title of
person accepting responsibility and acknowledging receipt of
materials as listed on this waste shipment record for transport.
Enter date of receipt and signature.
NOTE: The transporter must retain a copy of this form.
Disposal Site Section (Items 12 & 13)
12. The authorized representative of the WDS must note 1n this space any
discrepancy between waste described on this manifest and waste actually
received as well as any Improperly enclosed or contained waste. Any
rejected materials should be listed and destination of those materials
provided. A site that converts asbestos-containing waste material to
nonasbestos material Is considered a WDS.
13. The signature (by hand) of the authorized WDS agent Indicates
acceptance and agreement with statements on this manifest except as
noted 1n Item 12. The date 1s the date of signature and receipt of
shipment.
NOTE: The WDS must retain a completed copy of this form. The WDS must
also send a completed copy to the operator listed 1n Item 2.
Figure 1. Waste Shipment Record
8
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STANDARD FOR INACTIVE WASTE DISPOSAL SITES FOR ASBESTOS MILLS AND
MANUFACTURING AND FABRICATING OPERATIONS [61.151]
DEFINITIONS
The following terms used in this section are defined 1n Appendix A:
Administrator
Asbestos
Asbestos containing waste materials
Asbestos mill
Asbestos tailings
Fabricating
Facility
Inactive waste disposal site
Manufacturing
Natural barrier
Outside air
Owner or operator
Regulated asbestos-containing material
Visible emissions
APPLICABILITY [61.151]
This section applies to each owner or operator of any inactive disposal site
that was operated by and received deposits of asbestos-containing material
generated by any one of the following sources:
Asbestos Mills (61.142);
Manufacturing (61.144); or
Fabricating (61.147).
STANDARD [61.151(a)]
Each owner or operator of any inactive disposal site from any of the above
sources shall comply with one of the following:
Discharge no visible emissions to the outside air from an Inactive
waste disposal site; or
Cover the asbestos-containing material with at least 15 centimeters (6
inches) of compacted nonasbestos-contalnlng material, and grow and
maintain a cover of vegetation on the area adequate to prevent
exposure of the asbestos-containing material.
- In desert areas where vegetation would be difficult to maintain, at
least 8 additional centimeters (3 inches) of well-graded,
nonasbestos crushed rock may be placed on top of the final cover
instead of vegetation and maintained to prevent emissions; or
-------
Cover the asbestos-containing waste material with at least 60
centimeters (2 feet) of compacted nonasbestos-containing material, and
maintain it to prevent exposure of the asbestos-containing waste; or
For Inactive waste disposal sites for asbestos tailings, a resinous or
petroleum-based (i.e., contains material such as tar or asphalt) dust
suppression agent that effectively binds dust to control surface air
emissions may be used instead of the above cover and vegetation
methods. Use the agent in the manner and frequency recommended for
the particular asbestos tailings by the manufacturer of the dust
suppression agent to achieve and maintain dust control. Obtain prior
written approval of the Administrator to use other equally effective
dust suppression agents. Used, spent, or other waste oil is not
considered a dust suppression agent.
PUBLIC NOTICE OF INACTIVE WASTE DISPOSAL SITE [61.151(b)]
Unless a natural barrier adequately deters access by the general public,
either warning signs and fencing must be installed and maintained as follows,
or the cover and vegetation requirements of paragraph (a) of this section must
be met.
Warning signs must be displayed at all entrances and at intervals of
100 meters (330 feet) or less along the property line of the site
along the perimeter of the sections of the site where asbestos-
containing material is deposited. The warning signs must:
- Be posted in such a manner and location that a person can easily
read the legend; and
- Conform to the requirements of 51 cm. x 36 cm. (20 in. x 14 in.)
upright format signs specified in 29 CFR 1910.145 (d)(4) and this
paragraph; and
- Display the following legend in the lower panel with letter sizes
and styles of a visibility at least equal to those specified:
Asbestos Waste Disposal Site
(2.5 cm (1 inch) Sans Serif, Gothic or Block)
Do Not Create Dust
(1.9 cm (3/4 inch) Sans Serif, Gothic or Block)
Breathing Asbestos is Hazardous to Your Health
(14 Point Gothic)
- Spacing between the lines should be at least equal to the height of
the upper two lines.
The perimeter of the disposal site must be fenced in a manner adequate
to deter access by the general public.
-------
When requesting a determination on whether a natural barrier
adequately deters public access,supply Information enabling the
Administrator to determine whether a fence or a natural barrier
adequately deters access by the general public.
ALTERNATIVE CONTROL METHODS [61.151(c)]
The owner or operator may use an alternative control method that has received
prior approval of EPA rather than comply with the requirements of paragraph
(a) or (b) of this section.
DISTURBANCE OF ASBESTOS-CONTAINING WASTE MATERIAL [61.151(d)]
Written notice must be provided to the Administrator at least 45 days prior to
excavating or otherwise disturbing any asbestos-containing waste material that
has been deposited 1n a waste disposal site. The following information should
be Included 1n the notification:
Scheduled starting and completion dates;
Reason for disturbing the site;
Procedures to be used to control emissions; and
Location of any temporary storage site to be used and the location of
the final disposal site.
DISCLOSURE OF INACTIVE STATUS [61.151(e)]
Within 60 days after a site becomes Inactive, a notation must be made on the
deed of the facility property and on any other documents that may be examined
1n a title search, to notify potential purchasers of the property that:
The land has been used for the disposal of asbestos-containing waste;
A survey plot (1.e, map) containing a record of the location and
quantity of asbestos-containing waste disposed of within the site has
been filed with the Administrator; and
The site Is subject to the requirements of the National Emission
Standard for Asbestos 1n 40 CFR 61 Subpart M (I.e., to this
regulation).
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AIR CLEANING [61.152]
DEFINITIONS
The following terms used in this section are defined 1n Appendix A:
Administrator
Asbestos
Owner or operator
Particulate asbestos material
Visible emissions
STANDARD [61.152(a)]
Owners or operators who elect to use air-cleaning, as permitted in several
provisions of this standard, must:
Use a fabric filter collection device (i.e., a baghouse) for cleaning
emissions of particulate asbestos material operated in the following
manner:
- At a pressure drop of no more than 4 inches water gage, as measured
across the fabric filter;
- With an airflow permeability that does not exceed 9 cubic meters of
?as per minute flowing through a square meter of cloth (m3/min/m2)
30 ft3/min/ft2) for woven fabrics or 11 m3/min/m2 (35 ft3/min/ft2)
for felted fabrics.
- If the filtering air 1s from an asbestos ore dryer, then airflow
permeability must not exceed 12 m3/m1n/m2 (40 ft3/m1n/ft2) for woven
and 14 m3/m1n/m2 (45 ft3/m1n/ft2) for felted fabrics.
- If felted fabrics are used, the weight must be at least 475 grams
per square meter (14 ounces per square yard) and the material must
be at least 1.6 millimeters (one-sixteenth Inch) thick throughout.
- If synthetic fabrics are used, only spun fill yarn may be used.
The fabric filter collection device should be properly Installed,
used, operated, and maintained. Bypass devices may be used only
during upset or emergency conditions and for only as long as needed to
shut down the faulty operation.
- For fabric filter collection devices Installed after the revised
asbestos NESHAP proposal date of January 10, 1989, the owner or
operator should provide for easy Inspection for faulty bags.
EXEMPTIONS FROM THE USE OF A FABRIC FILTER COLLECTION DEVICE [61.152(b)]
There are several situations under which owners and operators are exempt from
the use of fabric filter collection devices. They are:
-------
Where the fabric filter collection device creates a fire or explosion
hazard and is installed after January 10, 1989, or the Administrator
determines that use of a fabric filter 1s not feasible. Under these
circumstances, the Administrator may authorize the use of wet
collectors as a substitute for the fabric filter collection device.
If used, the wet collectors must be designed to operate with a unit
contacting energy of at least 9.95 kllopascals (40 inches water gage
pressure);
Where a high efficiency partlculate air (HEPA) filter that 1s
certified to be at least 99.97 percent efficient for 0.3 micron
particles Is used; or
Where alternative filtering equipment authorized by EPA is used. The
EPA may authorize the use of alternative filter equipment 1f the owner
or operator has demonstrated to EPA's satisfaction that the
alternative equipment is equivalent to either the previously described
fabric filter collection device, the wet collector, or the HEPA filter
in filtering particulate asbestos materials.
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REPORTING [61.153]
DEFINITIONS
The following terms used 1n this section are defined Appendix A:
Active waste disposal site
Administrator
Asbestos-containing waste materials
Demolition
Owner or operator
Renovation
Roadways
Startup
STANDARD [61.153(a)]
Notification of New Source With Startup Before Effective Date (I.e..
Promulgation Date)
Any new sources to which this subpart applies (with the exception of roadways,
demolition and renovation, spraying and Insulating materials) which has an
initial start-up date preceding the effective date of this revision, shall
provide the Information listed below under Reporting Requirements to the
Administrator within 90 days of the effective date.
Notification of New Source With Start Up After Effective Date
In the case of a new source which did not have an initial start-up date
preceding the effective date, the Information shall be provided within 90 days
of the Initial start-up date.
Notification of Existing Source
Any owner or operator of an existing source shall provide the Information to
the Administrator within 90 days of the effective date, unless the Information
was previously provided to the Administrator. Any changes 1n the Information
provided by any existing source shall be provided to the Administrator within
30 days after the change.
Reporting Requirements
'The following Information must be provided using the format shown in Appendix
A, 40 CFR Part 61, as a guide:
A description of the emission control equipment used for each process;
If a fabric filter device Is used to control emissions:
- The airflow permeability 1n m3/m1n/m2 (ft3/m1n/ft2), 1f the fabric
filter device uses a woven fabric;
-------
- Whether the fill yarn is spun or not spun, if the fabric filter
device uses a synthetic fabric; and
- The density in g/m2 (oz/yd2), the minimum thickness in millimeters
(inches), and the airflow permeability in m3/min/m2 (ft3/min/ft^),
if the fabric filter device uses a felted fabric.
If a HEPA filter is used to control emissions, the certified
efficiency of the filter.
Additional Reporting Requirements by Source
For sources subject to the Standards for Waste Disposal for Asbestos Mills,
Manufacturing, Fabricating, Demolition, Renovation, and Spraying Operations
(61.149 and 61.150), the following additional information must be provided:
A brief description of each process that generates asbestos-containing
waste;
The average volume of asbestos-containing waste material disposed of,
measured 1n cubic meters (cubic yards), per day;
The emission control methods used 1n all stages of waste disposal; and
The type of disposal site or incineration site used for ultimate
disposal, the name of the site operator, and the name and location of
the disposal site.
For sources subject to the Standard for Inactive Waste Disposal Sites for
Asbestos Mills and Manufacturing and Fabricating Operations (61.151) or the
Standard for Active Waste Disposal Sites (61.154), the following additional
Information must be provided:
A brief description of the site; and
The method or methods used to comply with the standard, or alternative
procedures to be used.
ACCOMPANIMENT REQUIREMENT [61.153(b)]
The information required by paragraph (a) of this section must accompany the
Information required by the source reporting and waiver request in §61.10.
Roadways, demolition and renovation, spraying and insulating materials are
exempted from providing information related to the source description and
emission controls used that is required 1n §61.10(a).
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STANDARD FOR ACTIVE WASTE DISPOSAL SITES [61.154]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Active waste disposal site
Administrator
Asbestos
Asbestos-containing waste materials
Facility
Friable asbestos material
Inactive waste disposal site
Leak-tight
Natural barrier
Outside air
Owner or operator
Particulate asbestos material
Regulated asbestos-containing material
Visible emissions
Waste generator
Waste shipment record
APPLICABILITY [61.154]
Each owner or operator of an active waste disposal site that receives
asbestos-containing waste material from the following sources regulated under
the asbestos NESHAP shall meet the requirements of this subpart:
Asbestos Mills (61.142);
Manufacturing (61.144);
Fabricating (61.147);
Demolition and Renovation (61.145);
Spraying (61.146); and
Waste Conversion Processes (61.155).
STANDARD [61.154(a)]
Either there must be no visible emissions to the outside air from any active
waste disposal site where asbestos-containing waste material has been
deposited, or the requirements discussed 1n "alternatives to visible emissions
requirements" on pages 2 and 3 must be met.
-------
PUBLIC NOTICE OF ACTIVE WASTE DISPOSAL SITES [61.154(b)]
Unless a natural barrier adequately deters access by the general public,
either warning signs and fencing must be Installed and maintained as follows,
or the compacted nonasbestos cover requirements described below in
"alternatives to visible emissions requirements" of this section must be met.
Warning signs must be displayed at all entrances and at intervals of
100 meters (330 feet) or less along the property line of the site
along the perimeter of the sections of the site where asbestos-
containing material is deposited. The warning signs must:
- Be posted in such a manner and location that a person can easily
read the legend; and
- Conform to the requirements of 51 cm. x 36 cm. (20 in. x 14 in.)
upright format signs specified in 29 CFR 1910.145 (d)(4) and this
paragraph; and
- Display the following legend in the lower panel with letter sizes
and styles of a visibility at least equal to those specified below
in this paragraph.
Asbestos Waste Disposal Site
(2.5 cm (1 inch) Sans Serif, Gothic or Block)
Do Not Create Dust
(1.9 cm (3/4 inch) Sans Serif, Gothic or Block)
Breathing Asbestos is Hazardous to Your Health
(14 Point Gothic)
- Spacing between any two lines must be at least equal to the height
of the upper line.
The perimeter of the disposal site must be fenced in a manner adequate
to deter access by the general public.
Upon request and supply of appropriate information, the Administrator
will determine whether a fence or a natural barrier adequately deters
access to the general public.
ALTERNATIVES TO VISIBLE EMISSIONS REQUIREMENTS [61.154(c)(d)]
Rather'than meet the no visible emission requirement in paragraph (a) of this
section, an owner or operator of an active waste disposal sit? may:
At the end of each operating day, or at least once every 24-hour
period while the site 1s 1n continuous operation, cover the asbestos-
containing waste material which was deposited at the site during the
operating day or the previous 24-hour period with:
- At least 15 centimeters (6 inches) of compacted nonasbestos-
containing material, I.e., soil, or
-------
- A resinous or petroleum-based (I.e., contains material such as tar
or asphalt) dust suppression agent which effectively binds dust and
controls wind erosion. Any used, spent, or other waste oil is not
considered a dust supression agent.
Use an alternative control method for emissions that has received
prior approval by EPA.
Obtaining Approval for Alternative Treatment
To obtain approval for an alternative treatment, a written request must be
submitted to the Administrator. The request must demonstrate that the
following criteria are met:
The method controls asbestos emissions to levels equivalent to those
achieved by currently required methods;
The method is suitable for the intended application;
The method would not violate other regulations; and
The method would not result in increased water pollution, land
pollution, or occupational hazard.
RECORDKEEPING REQUIREMENTS [61.154(e)(f)(1)]
For all asbestos-containing waste material received, the owner or operator
shall:
Maintain records, using a form similar to that shown 1n Figure 1, that
Include the following information:
- Name, address, and telephone number of waste generator;
- Name, address, and telephone number of transporter;
- Quantity of asbestos-containing waste material in cubic meters;
- Presence of Improperly enclosed or uncovered waste not sealed In
leak-tight containers; and
- Date of receipt.
Send a copy of the waste shipment record to the waste generator as
soon as possible and no longer than 30 days after receiving the waste.
- Retain copies of the records for at least two years.
Upon discovering a discrepancy 1n recorded and actual waste amounts,
attempt to reconcile the discrepancy with the waste generator within
15 days after receipt of the waste. If the discrepancy cannot be
resolved within 15 days, submit a report immediately to the local,
State, or EPA regional office responsible for administering the
asbestos NESHAP for the waste generator and, 1f different, to the
local, State, or EPA Regional agency responsible for administering the
asbestos NESHAP for the disposal site, that describes the discrepancy
-------
and attempts made to reconcile 1t, and a copy of the waste shipment
record.
Report the presence of a significant amount of Improperly enclosed or
uncovered waste, by the following working day, to the NESHAP agency
responsible for the waste generator, and 1f different, to the NESHAP
agency responsible for the disposal site. Submit a copy of the waste
shipment record along with a cover letter explaining the incident.
Furnish upon request and make available during normal business hours
for inspection by the Administrator all records required under this
section.
Maintain until closure, records of the location, depth and area, and
quantity 1n cubic meters (cubic yards) of asbestos-containing waste
material within the disposal site on a map or diagram of the disposal
area.
CLOSURE OF ACTIVE WASTE DISPOSAL SITE [61.154(g)(h)(1)]
Upon closure of an active waste disposal site, the owner or operator shall:
Comply with all the provisions 1n the Standard for Inactive Waste
Disposal Sites (61.151); and
Submit to the Administrator a copy of records of asbestos waste
disposal locations and quantities.
DISTURBANCE OF ASBESTOS-CONTAINING WASTE MATERIAL [61.154(J)]
Written notice must be provided to the Administrator at least 45 days prior to
excavating or otherwise disturbing any asbestos-containing waste material that
has been deposited 1n a waste disposal site. The following Information should
be Included In the notification:
Scheduled starting and completion dates;
Reason for disturbing the site;
Procedures to be used to control emissions; and
- Location of any temporary storage site to be used and the location of
the final disposal site.
-------
Generator
Transporter
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1. Work site name and mailing address
2. Operator's name and address
Owner's name
3. Waste disposal site (WDS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
Owner's
telephone no.
Operator's
telephone no.
WOS
phone no.
agency
6. Containers
No. Type
7. Total quantity
n3 (yd3)
8. Special handling Instructions and additional Information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are 1n all
respects 1n proper condition for transport by highway according to
applicable International and government regulations.
Printed/typed name & title
10. Transporter 1 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
12. Discrepancy Indication space
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
13. Waste disposal site
owner or operator: Certification of receipt of asbestos materials
covered bv this manifest exceot as noted In Item 12.
Printed/typed name & title
Signature
Month Day Year
(Continued
Figure 1. Waste Shipment Record
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INSTRUCTIONS
Waste Generator Section (Items 1-9)
1. Enter the name of the facility at which asbestos waste 1s generated and
the address where the facility 1s located. In the appropriate spaces,
also enter the name of the owner of the facility and the owner's phone
number.
2. If a demolition or renovation, enter the name and address of the company
and authorized agent responsible for performing the asbestos removal.
In the appropriate spaces, also enter the phone number of the operator.
3. Enter the name, address, and physical site location of the waste
disposal site (WDS) that will be receiving the asbestos materials. In
the appropriate spaces, also enter the phone number of the WDS. Enter
"on-s1te" 1f the waste will be disposed of on the generator's property.
4. Provide the name and address of the local, State, or EPA Regional office
responsible for administering the asbestos NESHAP program.
5. Indicate the types of asbestos waste materials generated. If from a
demolition or renovation, Indicate the amount of asbestos that 1s
Friable asbestos material
- Nonfrlable asbestos material
6. Enter the number of containers used to transport the asbestos materials
listed In Item 5. Also enter one of the following container codes used
In transporting each type of asbestos material (specify any other type
of container used 1f not listed below):
DM - Metal drums, barrels
DP - Plastic drums, barrels
BA - 6 mil plastic bags or wrapping
7. Enter the quantities of each type of asbestos material removed 1n units
of cubic meters (cubic yards).
8. Use this space to Indicate special transportation, treatment, storage
or disposal or Bill of Lading Information. If an alternate waste
disposal site Is designated, note It here. Emergency response
telephone numbers or similar Information may be Included here.
NOTE: The waste generator must retain a copy of this form.
(continued)
Figure 1. Waste Shipment Record
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9. The authorized agent of the waste generator must read and then sign
and date this certification. The date 1s the date of receipt by
transporter.
Transporter Section (Items 10 & 11)
10. & 11. Enter name, address, and telephone number of each transporter
used, 1f applicable. Print or type the full name and title of
person accepting responsibility and acknowledging receipt of
materials as listed on this waste shipment record for transport.
Enter date of receipt and signature.
NOTE: The transporter must retain a copy of this form.
Disposal Site Section (Items 12 & 13)
12. The authorized representative of the WDS must note 1n this space any
discrepancy between waste described on this manifest and waste actually
received as well as any Improperly enclosed or contained waste. Any
rejected materials should be listed and destination of those materials
provided. A site that converts asbestos-containing waste material to
nonasbestos material Is considered a WDS.
13. The signature (by hand) of the authorized WDS agent Indicates
acceptance and agreement with statements on this manifest except as
noted In Item 12. The date Is the date of signature and receipt of
shipment.
NOTE: The WDS must retain a completed copy of this form. The WDS must
also send a completed copy to the operator listed 1n Item 2.
Figure 1. Waste Shipment Record
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STANDARD FOR SITES THAT CONVERT ASBESTOS-CONTAINING WASTE INTO NONASBESTOS
(ASBESTOS-FREE) MATERIAL [61.155]
DEFINITIONS
The following terms used 1n this section are defined 1n Appendix A:
Administrator
Asbestos
Asbestos-containing waste materials
Outside air
Owner or operator
Particulate asbestos material
Regulated asbestos-containing material
Startup
Visible emissions
STANDARD
This section involves the incorporation of new requirements for operations
that convert asbestos-containing waste into nonasbestos material. The
category is divided into sections dealing with the operations surrounding the
conversion of asbestos-containing waste and the appropriate recordkeeping
associated with the operations.
APPROVAL FOR CONVERSION SITE [61.155(a)]
Owners or operators of an operation that converts asbestos-containing waste
material Into nonasbestos (asbestos-free) material must meet the following
requirements:
Obtain written approval from EPA before construction of a conversion
process begins.
To obtain approval, the following Information must be provided to EPA:
- An application to construct pursuant to 61.07;
- A description of waste feed handling and temporary storage;
- A description of process operating conditions;
- A description of end product handling and temporary storage;
- A description of the protocol to be followed when analyzing output
materials by transmission electron microscopy;
- The performance test protocol; and
- Upon request by the Administrator, a demonstration of the conversion
process.
CONDUCTING A START-UP PERFORMANCE TEST [61.155(b)]
When conducting a start-up performance test, the test results should include
the following Information:
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Detailed description of the types and quantities of nonasbestos
material and asbestos-containing waste processed;
Documentation of test results to determine the asbestos content of the
waste processed, using polarized light microscopy;
Documentation of test results demonstrating that the output material
is free of asbestos, using transmission electron microscopy;
Description of operating parameters defining the full range over which
the process is expected to operate; and
The length of the test.
OPERATIONS (THE FIRST 90 DAYS) [61.155(c)]
During the initial 90 days of operation, the owners or operators must:
Continuously monitor and log the operating parameters specified during
start-up performance tests as a means of ensuring that the output
material is asbestos free; and
Monitor all input materials to ensure that they are within the range
used during the startup tests; and
Collect and analyze, by transmission electron microscopy, samples of
all output material for the presence of asbestos. All output material
must be stored on site until the analysis shows that the material is
asbestos-free. Otherwise, the output must be disposed of as asbestos-
containing waste material according to the Standard for Waste Disposal
for Manufacturing, Fabricating, Demolition, Renovation, and Spraying
Operations (61.150).
OPERATIONS (AFTER THE FIRST 90 DAYS) [61.155(d)]
After the initial 90 days of operation, the owners or operators must:
Continuously monitor and record the operating parameters identified
during the initial performance and any subsequent performance test.
Handle any product that is produced during a period when the operating
' parameters are outside the range of operating conditions that is
indicative of asbestos-free product in one of the following ways:
- Dispose of as asbestos-containing waste material according to the
Standard for Waste Disposal for Manufacturing, Fabricating,
Demolition, Renovation and Spraying Operations (61.150);
- Recycle as waste feed during a period when the operating parameters
are within the range indicative of asbestos-free product; or
- Store temporarily on-site until analyzed for asbestos content (Any
product determined by the analysis to contain asbestos, shall be
disposed of as asbestos-containing waste or recycled).
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Collect and analyze monthly composite samples (one 200 gm. [7 oz.]
sample collected every 8 hours of operation) of the output material.
Transmission electron microscopy shall be used to analyze the output
material for the presence of asbestos.
EMISSION CONTROL STANDARD [61.155(e)]
Owners or operators must discharge no visible emissions to the outside air or
use the methods specified in Air Cleaning (61.152) to clean emissions
containing particulate asbestos materials before they escape to, or are vented
to, the outside air.
RECORDKEEPING REQUIREMENTS [61.155(f)]
Owners or operators of such an operation should maintain records of all
operating activities, including the following:
Results of start-up performance test and any subsequent test;
Results of all composite analyses conducted during the initial 90
days;
Results of the monthly composite analysis;
Results of continuous monitoring and logs of process operating
parameters;
Information on waste shipments received;
Records of the name and location of the purchaser or disposal site and
the date of sale or deposit for output material that was not analyzed
for asbestos content; and
Retain all records for at least 2 years.
NOTIFICATION REQUIREMENTS [61.155(g)]
Owners or operators must submit two types of reports to the Administrator:
A report for each analysis of product composite samples taken during
the Initial 90 days of operation.
A quarterly report concerning activities of the conversion operations
during each consecutive 3-month period which contains:
- Results of analyses of monthly product composite samples;
- Description of any deviation from the operating parameters, Its
duration, and the corrective action taken;
- Disposition of any product produced during a period when the
operating parameters were outside the range indicative of asbestos-
free product; and
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- Information on waste disposal activity as required in the Standard
for Active Waste Disposal Sites (61.154).
EXEMPTIONS [61.155(h)]
Nonasbestos (asbestos-free) output material is not subject to any of the
provisions of this subpart. Output materials in which asbestos is detected,
or output materials produced when the operating parameters deviated from those
established during the start-up performance testing, unless shown by
transmission electron microscopy (TEM) analysis to be asbestos free, shall be
considered to be asbestos-containing waste and shall be handled and disposed
of according to the Standard for Waste Disposal for Manufacturing,
Fabricating, Demolition, Renovation, and Spraying Operations (61.150) or
reprocessed while all of the established operating parameters are being met.
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APPENDIX A
DEFINITIONS 61.02
Administrator means the Administrator of the Environmental Protection Agency
or his authorized representative.
Owner or operator means any person who owns, leases, operates, controls, or
supervises a stationary source.
Startup means the setting in operation of a stationary source for any purpose.
DEFINITIONS 61.141
Active waste disposal site means any disposal site other than an inactive
site.
Adequately wet means sufficiently mix or penetrate with a liquid to prevent
the release of particulates. If visible emissions are observed coming from
asbestos-containing material, then that material has not been adequately
wetted. However, the absence of visible emissions is not sufficient evidence
of being wet.
Asbestos means the asbestiform varieties of serpentinlte (chrysotile),
riebeckite (croddolite), cummlngtonite-grunerite, anthophyllite, and
actlnoli te-tremoli te.
Asbestos-containing waste materials means mill tailings or any waste that
contains commercial asbestos and 1s generated by a source subject to the
provisions of this subpart. This term includes filters from control devices,
friable asbestos waste material, and bags or other similar packaging
contaminated with asbestos. As applied to demolition and renovation
operations, this term also Includes regulated asbestos-containing material
waste and materials contaminated with asbestos-containing materials including
disposable equipment and clothing.
Asbestos mill means any facility engaged in converting, or in any intermediate
step in converting, asbestos ore into commercial asbestos. Outside storage of
asbestos material is not considered a part of the asbestos mill.
Asbestos tailings means any solid waste that contains asbestos and is a
product of asbestos mining or milling operations.
Asbestos waste from control devices means any waste material that contains
asbestos and 1s collected 1n a pollution control device.
Category I nonfrlable asbestos-containing material means asbestos-containing
packings, gaskets, resilient floor covering, and asphalt roofing products,
containing more than 1 percent asbestos as determined using the method
specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized
Light Microscopy.
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Category II nonfriable asbestos-containing material means any material,
excluding Category I nonfriable asbestos-containing material, containing more
than 1 percent asbestos as determined using the methods specified in Appendix
A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy that,
when dry, cannot be crumbled, pulverized, or reduced to powder by hand
pressure.
Commercial asbestos means any material containing asbestos that is extracted
from ore and has value because of its asbestos content.
Cutting means to penetrate with a sharp edged instrument and includes sawing,
but does not include shearing, slicing, or punching.
Demolition means the wrecking or taking out of any load-supporting structural
member of a facility together with any related handling operations or the
intentional burning of any facility.
Emergency renovation operation means a renovation operation that was not
planned but results from a sudden, unexpected event that, if not immediately
attended to, presents a safety or public health hazard, is necessary to
protect equipment from damage, or is necessary to avoid imposing an
unreasonable financial burden. This term includes operations necessitated by
nonroutine failures of equipment.
Fabricating means any processing (e.g., cutting, sawing, drilling) of a
manufactured product that contains commercial asbestos, with the exception of
processing at temporary sites (field fabricating) for the construction or
restoration of facilities. In the case of friction products, fabricating
includes bonding, debonding, grinding, cutting, drilling, or other similar
operations performed as part of fabricating.
Facility means any institutional, commercial, public, industrial, or
residential structure, installation, or building (including any building
containing condominiums or individual dwelling units operated as a residential
cooperative but excluding residential buildings having four or fewer dwelling
units); any ship; and any active and inactive waste disposal site. For
purposes of this definition, any building, structure, or installation that
contains a loft used as a dwelling, is not considered a residential structure,
installation, or building. Any structure, installation or building that was
previously subject to this subpart is not excluded, regardless of Its current
use of function.
Facility component means any part of a facility including equipment.
Friable asbestos material means any material containing more that 1 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 content by
point counting using PLM.
Fugitive source means any source of emissions not controlled by an air
pollution control device.
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Glove bag means a sealed compartment with attached inner gloves used for the
handling of asbestos-containing materials. Properly installed and used, glove
bags provide a small work area enclosure typically used for small-scale
asbestos stripping operations. Information on glove-bag installation,
equipment and supplies, and work practices is contained in the Occupational
Safety and Health Administration's (OSHA) final rule on occupational exposure
to asbestos (Appendix 6 to 29 CFR 1926.58).
Grinding means to reduce to powder or small fragments and includes mechanical
chipping or drilling.
Inactive waste disposal site means any disposal site or portion of it where
additional asbestos-containing waste material has not been deposited within
the past year.
In poor condition means the binding of the material is losing its integrity as
Indicated by peeling, cracking, or crumbling of the material.
Installation means any building or structure or any group of buildings or
structures at a single demolition or renovation site that are under the
control of the same owner or operator (or owner or operator under common
control).
Leak-tight means that solids or liquids cannot escape or spill out. It also
means dust-tight.
Malfunction means any sudden and unavoidable failure of air pollution control
equipment or process equipment or of a process to operate in a normal or usual
manner so that emissions of asbestos are increased. Failures of equipment
shall not be considered malfunctions if they are caused in any way by poor
maintenance, careless operations, or any other preventable upset conditions,
equipment breakdown, or process failure.
Manufacturing means the combining of commercial asbestosor, in the case of
woven friction products, the combining of textiles containing commercial
asbestoswith any other material(s), including commercial asbestos, and the
processing of this combination into a product. Chlorine production is
considered a part of manufacturing.
Natural Barrier means a natural object that effectively precludes or deters
access. Natural barriers include physical obstacles such as cliffs, lakes or
other large bodies of water, deep and wide ravines, and mountains. Remoteness
by itself Is not a natural barrier.
Nonfriable asbestos material means any material containing more than 1 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, cannot be
crumbled, pulverized, or reduced to powder by hand pressure.
Nonscheduled renovation operation means a renovation operation necessitated by
the routine failure of equipment, which is expected to occur within a given
period based on past operating experience, but for which an exact date cannot
be predicted.
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Outside air means the air outside building and structures, including, but not
limited to, the air under a bridge or in an open ferry dock.
Owner or operator of a demolition or renovation activity means any person who
owns, leases, operates, controls, or supervises the facility being demolished
or renovated or any person who owns, leases, operates, controls, or supervises
the demolition or renovation operation, or both.
Partlculate asbestos material means finely divided particles of asbestos or
material containing asbestos.
Planned renovation operations means a renovation operation, or a number of
such operations, in which some regulated asbestos-containing material will be
removed or stripped within a given period of time and that can be predicted.
Individual nonscheduled operations are included if a number of such operations
can be predicted to occur during a given period of time based on operating
experience.
Regulated asbestos-containing material means (a) friable asbestos material,
(b) Category I nonfriable asbestos-containing material that has become
friable, (c) Category I nonfriable ACM that will be or has been subjected to
sanding, grinding, cutting, or abrading, or (d) Category II nonfriable
asbestos-containing material 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 this subpart.
Remove means to take out regulated asbestos-containing materials or facility
components that contain or are covered with regulated asbestos-containing
material from any facility.
Renovation means altering a facility or one or more facility components in any
way, Including the stripping or removal of regulated asbestos-containing
material from a facility component. Operations in which load-supporting
structural members are wrecked or taken out are demolitions.
Resilient floor covering means asbestos-containing floor tile, Including
asphalt and vinyl floor tile, and sheet vinyl floor covering containing more
than 1 percent asbestos as determined using polarized light microscopy
according to the method specified 1n Appendix A, Subpart F, 40 CFR Part 763,
Section 1, Polarized Light Microscopy.
Roadways means surfaces on which motor vehicles travel. This term includes
public and private highways, roads, streets, parking areas, and driveways.
Strip means to take off regulated asbestos-containing materials from any part
of a facility or facility components.
Structural member means any load supporting member of a facility, such as
beams and load supporting walls; or any nonload-supporting member, such as
ceilings and nonload-supporting walls.
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Visible emissions means any emissions, which are visually detectable without
the aid of instruments, coming from regulated asbestos-containing material or
asbestos-containing waste material, or from any asbestos milling,
manufacturing, or fabricating operation. This does not Include condensed
uncombined water vapor.
Waste generator means any owner or operator or a source covered by this
subpart whose act or process produces asbestos-containing waste material.
Waste shipment record means the shipping document, required to be originated
and signed by the generator, used to track and substantiate the disposition of
asbestos-containing waste material.
Working days means Monday through Friday and Includes holidays that fall on
any of the days Monday through Friday.
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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
DE.DC.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,NQSC,TN
Asbestos NESHAP Coordinator
Air, Pesticide & Toxics Div.
US EPA
345 Courdand Street
Atlanta, GA 30365
(404) 347-5014
Regional Asbestos Coordinator
US EPA
345 Courdand Street
Atlanta, GA 30365
(404) 347-5014
Regions
IL.IN, Ml
MN, OH.WI
Asbestos NESHAP Coordinator
Air & Radiation Division
US EPA
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6793
Regional Asbestos Coordinate
US EPA
230 South Dearborn Si
Chicago, Q. 60604
(312) 886-6003
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AHERA and NESHAP Coordinators
Region
NESHAP
AHERA
Region 6
AR.LA, NM
OK.TX
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Div.
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7233
Regional Asbestos Coordinator
Air, Pesticides & Toxics Div.
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7244
Region 7
IA.KS
MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
Regional Asbestos Coordinator
Air & Toxics Division
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
Region 8
CO, MT, ND
SD, UT, WY
Asbestos NESHAP Coordinator
Air & Waste Management Div.
US EPA
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 294-7685
Regional Asbestos Coordinator
US EPA
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1442
Region 9
AS, AZ, CA, HI
NV, GU, TT
Asbestos NESHAP Coordinator
Air Management Division
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1135
Regional Asbestos Coordinator
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1128
Region 10
AK.ID
OR, WA
Asbestos NESHAP Coordinator
Air fit Toxics Management Div.
US EPA
1200 6th Avenue
Seattle, WA 98101
(206) 442-1757
Regional Asbestos Coordinator
US EPA
1200 6th Avenue
Seaole,WA 98101
(206) 442-4762
U.aQOVERNIyBaPRNT1NSaFFICE:18B1417-(XXV2a043
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Item 2 - Asbestos/NESHAP Regulated Asbestos Containing
Materials Guidance
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EPA 340/1-90-018
ASBESTOS NESHAP
REGULATED ASBESTOS CONTAINING
MATERIALS GUIDANCE
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Quality Planning and Standards
Stationary Source Compliance Division
Washington, DC 20460
December, 1990
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CONTENTS
Section Page
1. INTRODUCTION 6
2. FRIABLE ASBESTOS-CONTAINING MATERIALS ... 8
3. NON-FRIABLE ASBESTOS-CONTAINING
MATERIALS 9
Category I Nonfriable ACM 10
Category E Nonfriable ACM 11
4. INSPECTION PROCEDURES TO DETERMINE
THE POTENTIAL FOR FIBER RELEASE
FROM NONFRIABLE ASBESTOS-
CONTAINING MATERIALS 13
Friability Determination Decision
Trees 14
General Inspection Procedures 16
Specific Inspection Procedures 17
Category I Nonfriable ACM 17
Category E Nonfriable ACM 19
APPENDICES
A Asbestos NESHAP Coordinators
(For Demolition/Renovation Activities) A - 1
B Regional Asbestos Coordinators
(For Schools) B-l
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ACKNOWLEDGEMENTS
This document was written by Alliance Technologies, Inc.,
based on discussions with a work group from EPA. The group
consisted of the Regional Asbestos NESHAP Coordinators, Ron
Shafer, Scott Throwe, and Omayra Salgado of the Stationary Source
Compliance Division, Charles Garlow and Elise Hoerath of the Air
Enforcement Division and Sims Roy of the Standards Development
Branch. We thank the individuals who reviewed an earlier draft and
provided comments, many of which are incorporated in the final
version. Their input is gratefully acknowledged.
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1. INTRODUCTION
Section 112 of the Clean Air Act (CAA) requires EPA to develop
emission standards for hazardous air pollutants. In response to this
section the Environmental Protection Agency (EPA) published a list
of hazardous air pollutants and promulgated the "National Emission
Standards for Hazardous Air Pollutants" (NESHAP) regulations.
Since asbestos presents a significant risk to human health as a result
of air emissions from one or more source categories, it is therefore
considered a hazardous air pollutant The Asbestos NESHAP (40
CFR 61, Subpart M) addresses milling, manufacturing and
fabricating operations, demolition and renovation activities, waste
disposal issues, active and inactive waste disposal sites and asbestos
conversion processes.
In the initial Asbestos NESHAP rule promulgated in 1973, a
distinction was made between building materials that would readily
release asbestos fibers when damaged or disturbed and those
materials that were unlikely to result in significant fiber release. The
terms "friable" and "non-friable" were used to make this distinction.
EPA has since determined that, if severely damaged, otherwise
nonfriable materials can release significant amounts of asbestos
fibers.
Friable asbestos-containing material (ACM), is defined by the
Asbestos NESHAP, as any material containing more than 1 percent
asbestos as determined using the method specified in Appendix A,
Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy
(PLM), that, when dry, can be crumbled, pulverized or reduced to
powder by hand pressure. (Sec. 61.141)
Nonfriable ACM is any material containing more than 1 percent
asbestos as determined using the method specified in Appendix A,
Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy
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(PLM), that, when dry, cannot be crumbled, pulverized, or reduced
to powder by hand pressure. EPA also defines two categories of
nonfriable ACM, Category I and Category n nonfriable ACM, which
are described later in this guidance.
"Regulated Asbestos-Containing Material" (RACM) is (a) friable
asbestos material, (b) Category I nonfriable ACM that has become
friable, (c) Category I nonfriable ACM that will be or has been
subjected to sanding, grinding, cutting or abrading, or (d) Category n
nonfriable 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.
The purpose of this document is to assist asbestos inspectors and the
regulated community in determining whether or not a material is
RACM and thus subject to the Asbestos NESHAP.
The recommendations made in this guidance are solely
recommendations. They are not the exclusive means of complying
with the Asbestos NESHAP requirements. Following these
recommendations is not a guarantee against findings of violation.
The EPA intends for owners/operators to be reasonably certain
whether or not they are subject to the NESHAP. In the end, if a
question arises, determinations of whether asbestos containing
materials are regulated by the Asbestos NESHAP are made by EPA
inspectors on site.
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2. FRIABLE ASBESTOS CONTAINING-
MATERIALS
Due to their high tensile strength, incombustibility, corrosion and
friction resistance and other properties, such as acoustical and
thermal insulation abilities, asbestos fibers have been incorporated
into over 3600 commercial products. Thermal system, fireproofing
and acoustical insulation materials have been used extensively in the
construction industry.
Thermal system applications include steam or hot water pipe
coverings and thermal block insulation found on boilers and hot
water tanks. Fireproofing insulation may be found on building
structural beams and decking. Acoustical insulation (soundproofing)
commonly has been applied as a troweled-on plaster in school and
office building stairwells and hallways. Unfortunately, with time and
exposure to damaging forces (e.g., severe weather, chemicals,
mechanical forces, etc.), many asbestos- containing materials may
become crumbled, pulverized or reduced to powder, thereby releasing
asbestos fibers, or may deteriorate to the extent that they may release
fibers if disturbed. Since inhalation of asbestos fibers has been linked
to the development of respiratory and other diseases, any material
which is friable, or has a high probability of releasing fibers, must
be handled in accordance with the Asbestos NESHAP.
The following work practices should be followed whenever
demolition/renovation activities involving RACM occur:
notify EPA of intention to demolish/renovate,
remove all RACM from a facility being demolished or
renovated before any disruptive activity begins or before
access to the material is precluded,
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keep RACM adequately wet before, during, and after
removal operation,
conduct demolition/renovation activities in a manner which
produces no visible emissions to the outside air, and
handle and dispose of all RACM in an approved manner.
3. NONFRIABLE ASBESTOS-CONTAINING
MATERIALS
Because of the resilient nature of asbestos, it is used in materials
exposed to a wide variety of stressful environments. These
environments can cause the deterioration of binding materials and
cause nonfriable materials to become friable. For example, asbestos-
containing packings and gaskets (Category I nonfriable ACM) used
in thermal systems may be found in poor condition as a result of the
heat they have encountered. In petrochemical handling facilities,
which may have miles of transfer pipes and fittings which contain
asbestos gaskets and/or packings, profound degradation of the ACM
may occur due to exposure to organic-based liquids and gases or to
corrosive agents used to chemically clean these tines.
When nonfriable ACM is subjected to intense mechanical forces,
such as those encountered during demolition or renovation, it can be
crumbled, pulverized, or reduced to powder, and thereby release
asbestos fibers. When nonfriable materials are damaged or are likely
to become damaged during such activities, they must be handled in
accordance with the Asbestos NESHAP.
There are two categories of nonfriable materials: Category I
Nonfriable ACM and Category II Nonfriable ACM.
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CATEGORY I NONFRIABLE ACM
Category I nonfriable ACM is any asbestos-containing packing,
gasket, resilient floor covering or asphalt roofing product which
contains more than 1 percent asbestos as determined using polarized
light microscopy (PLM) according to the method specified in
Appendix A, Subpart F, 40 CFR Part 763. (Sec. 61. 141)
Category I nonfriable ACM must be inspected and tested for
friability if it is in poor condition before demolition to determine
whether or not it is subject to the Asbestos NESHAP. If the ACM
is friable, it must be handled in accordance with the NESHAP.
Asbestos-containing packings, gaskets, resilient floor coverings and
asphalt roofing materials must be removed before demolition only if
they are in poor condition and are friable.
The Asbestos NESHAP further requires that if a facility is
demolished by intentional burning, all of the facility's ACM,
including Category I and n nonfriable ACM, be considered RACM
and be removed prior to burning (Sec. 61.145 (c)(10)). Additionally,
if Category I or Category n nonfriable ACM is to be sanded,
ground, cut, or abraded, the material is considered RACM and the
owner or operator must abide by the following (Sec. 61.145 (c)(l)):
(i) Adequately wet the material during the sanding, grinding,
cutting, or abrading operations.
(ii) Comply with the requirements of 61.145(c)(3)(i) if wetting
would unavoidably damage equipment or present a safety
hazard.
(iii) Handle asbestos material produced by the sanding, grinding,
cutting, or abrading, as asbestos-containing waste material
subject to the waste handling and collection provisions of
Section 61.150.
10
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CATEGORY n NONFRIABLE ACM
Category n nonfriable ACM is any material, excluding Category I
nonfriable ACM, containing more than 1 percent asbestos as
determined using polarized light microscopy according to the
methods specified in Appendix A, Subpart F, 40 CFR Part 763 that,
when dry, cannot be crumbled, pulverized, or reduced to powder by
hand pressure. (Sec. 61.141)
Category n nonfriable ACMs (cement siding, transite board shingles,
etc.) subjected to intense weather conditions such as thunderstorms,
high winds or prolonged exposure to high heat and humidity may
become "weathered" to a point where they become friable. The
photograph in Figure 1 demonstrates a split asbestos shingle that has
become friable along the cracked edge.
The following table lists examples and other relevant information
about Category I and Category n nonfriable ACM.
Figure 1. Nonfriable asbestos shingle which has become
friable along the broken axis.
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TABLE 1.
NONFRIABLE ASBESTOS PRODUCTS
Subdivision Generic name
CemenMious extrusion panels
concrete-Ike products
(Caieoory II)
AsbetsBt (%) Binder/sizing
Roofng lain
(Category I)
Asbestos-containing
compounds
(Category I and II)
corrugated
flat
flexible
flexible perforated
lamhawd
(outer surface)
roof Was
clapboard and shingles:
clapboard
siding shingles
roofng shingles
Pipe
smooth surface
mneral surface
shingles
ptpeine
caufcing putties
adhesive (arid apphed)
roofng asphalt
mastics
asphalt We cement
roof putty
plaster/stucco
sealants fire/water
cement. Insulation
cement finishing
cement, fnagneeje.
20-45
40-50
30-50
30-50
35-50
20-30
12-15
12-14
20-32
20-15
10-15
10-15
1
10
X
5-25
5
5-25
13-25
10-25
2-10
50-55
20-100
55
15
Asbestos ebony products
Floor «e and vlnyVasbeMM Me
Sheet goods asphan/asbesto* We
aheet goods/resftent
SO
21
28-33
30
Portland cement
Portland lament
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
asphalt
asphalt
asphalt
asphalt
linseed oil
asphalt
asphalt
asphalt
asphalt
asphalt
Portland cement
castor 0* or poyisoouxyteni
day
aty
magnesium carbonate
Portland cement
poMvkiyOcMortde
aspnart
dry oils
From EPA Guidance entitled 'Guidance for Controlling Asbestos-Containing Materials In
Buildings" (Purple Book). Appendix A. Page A-1; EPA 560/5-65-024.
I2
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Except for the following, Section 61.145(c) of the Asbestos
NESHAP requires that each owner or operator of a demolition or
renovation activity involving RACM remove all such material 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.
ACM need not be removed before demolition if it:
(i) Is a Category I nonfriable ACM that is not friable.
(ii) Is on a facility component that is encased in
concrete or other similarly hard material and is
adequately wet whenever exposed during demolition.
(iii) Was not accessible for testing and therefore was not
discovered until after demolition began and, as a
result of the demolition, cannot be safely removed.
If not removed for safety reasons, the exposed
RACM and any asbestos-contaminated debris must
be treated as asbestos-containing waste material and
kept adequately wet at all times until disposed of.
(iv) Is a Category n nonfriable ACM and the probability
is low that the material will become crumbled,
pulverized, or reduced to powder during demolition.
4. INSPECTION PROCEDURES TO DETERMINE THE
POTENTIAL FOR FIBER RELEASE FROM
NONFRIABLE ASBESTOS-CONTAINING
MATERIALS
Members of the regulated community (i.e. abatement contractors,
industrial hygienists, building owners & operators, etc.) should
become familiar with these procedures as they are designed to
enhance compliance with the Asbestos NESHAP.
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Asbestos NESHAP RACM Decision Tree
(Pre Demolition/Renovation Activity)
F 8EVCRM. AREAS ABE BENO RBOVATR) OR
OEMOUSHEO AT ONE THE AS
PART OF «« ACTTVTTY THEN THE TOTAIS OF ALL
FACIUPES MUST BE SIMJED
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Asbestos NESHAP RACM Decision Tree
(Post Demolition/Renovation Activity)
REGULATED AMOUNTS OF
SUSPECT RACM DISCOVERED
AFTER DEMO/RENO
YES
NO
ANALYZE
REPRESENTATIVE
SAMPLE FOR ASBESTC
CONTENT
NOT COVERED BY
NESHAP
YES
NO
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GENERAL INSPECTION PROCEDURES
1. Identify all nonfriable suspect ACM and determine whether
it is Category I or II.
2. If it is Category I nonfriable RACM:
Is it in "poor condition?"
[Is the binding of the ACM losing its integrity? Is
the ACM peeling, cracking, or crumbling?
(Remember, friable ACM may not appear in poor
condition.)]
Is it friable?
Collect a piece of dry ACM and seal it in a
transparent, reclosable sample bag.
Apply hand pressure and observe if the
ACM falls apart to the extent that it is
crumbled, pulverized, or reduced to powder.
Does it occur suddenly, all at once?
Send representative samples of the RACM
to an analytical laboratory which is able to
test them for the presence of asbestos
according to the methods specified in 40
CFR Part 763 Subpart F, Appendix A.
Ask the owner/operator if any ACM or
RACM has been sampled and analyzed. If
so, determine where the samples were taken
and ask if the methods of demolition/
renovation were considered when assessing
-------
the fiber release potential of the material. -
Will it or has it been subjected to sanding,
grinding, cutting or abrading?
3. If it is Category n nonfriable ACM:
Has the material been crumbled, pulverized or
reduced to powder or is there a high probability that
it will be crumbled, pulverized or reduced to powder
during the demolition/renovation operations, thus
rendering the material friable and subject to the
Asbestos NESHAP?
If Category II nonfriable ACM has been or will be
crumbled, pulverized, or reduced to powder by
demolition or renovation forces, take representative
samples and send them to a laboratory to test for the
presence of asbestos according to the method
specified in 40 CFR Part 763, Subpart F, Appendix A.
5. SPECIFIC INSPECTION PROCEDURES
Category I Nonfriable ACM
Packings and Gaskets
These materials are often very difficult to find because they are
usually placed inside ovens, doors, pipes, boilers, etc.
Often a packing or gasket is discovered during a stripping or
demolition activity. For example, some boilers have an asbestos-
containing paraffin wax packing between the steam lines that travel
between the mud and fire boxes. The paraffin binding of the
packing may decompose due to the high temperatures, and render the
packing friable. Observe all of the packing and note areas that are in
poor condition. Packings in poor condition appear dry and
-------
discolored, and fibers may be visible.
A representative piece of asbestos-containing packing material (in
good or poor condition) should be removed with a utility knife and
sealed in a transparent, reclosable bag. Apply hand pressure to the
packing in the sample bag to determine if any portion is crumbled,
pulverized or reduced to powder. If the material simply deforms, but
does not crumble or reduces to a powder, then the material is
considered nonfriable.
Resilient Floor Covering
There is a wide variety of resilient floor covering applications that
contain asbestos. The most common are linoleum flooring and vinyl
asbestos tile (VAT). VAT is most commonly found in either a
9"x9" or a 12"xl2" square size. The 9"x9" VAT's are normally
found in older buildings because they were manufactured earlier than
the 12"xl2" VAT's; however, floor tile sizes and resilient floor
covering applications vary greatly since many buildings have been
re-tiled several times.
In order to determine if a resilient floor covering is in poor condition
look for sections or tiles which are cracked or peeling to the extent
that they are crumbled. Floor coverings in poor condition can often
be found near doorways or loading/staging areas where the floor has
sustained a lot of stress and traffic. If the floor covering is in poor
condition, collect a small representative sample and seal it in a
transparent, sample bag. Hand pressure should be applied to
determine if the material can be crumbled, pulverized, or reduced to
powder. If it can, the material is considered friable. Resilient floor
covering that will be or has been sanded, ground or abraded is
subject to the Asbestos NESHAP. Figure 2 depicts a VAT which is
in poor condition.
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Figure 2. VAT in poor condition
Asphalt Roofing Products
Asbestos-containing roofing felts have been widely used in "built-up"
roofs. Built-up roofing was used on flat surfaces and consists of
alternating layers of roofing felt and asphalt The roofing felt
consists of asbestos paper saturated and coated with asphalt
Asphalt-asbestos roofing products made from roofing felt coated with
asphalt were reportedly used on residential structures for only a short
time (1971-1974).
To determine if an asphalt roofing product is covered by the
Asbestos NESHAP, examine the RACM to spot any areas where the
material is in poor condition and friable. Figure 3 illustrates a
section of roofing felts which have deteriorated and display fibers.
If possible, sample areas where fibers can be seen protruding from
the matrix of the asphalt The sample should be sealed into a
transparent, reclosable sample bag and hand pressure applied to see
if the sample can be crumbled, pulverized, or reduced to powder.
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Figure 3. Asphalt roofing felts which are in poor condition. Notice
the fibers protruding along the edge of this roofing felt
Category II Nonfrlable ACM
Asbestos Cement Pipe and Sheet Products
Asbestos-cement (A-C) pipe has been widely used for water and
sewer mains and occasionally used as electrical conduits, drainage
pipe, and vent pipes. A-C sheet, manufactured in flat or corrugated
panels and shingles (transite board), has been used primarily for
roofing and siding, but also for cooling tower fill sheets, canal
bulkheads, laboratory tables, and electrical switching gear panels. If
these ACM are crumbled, pulverized or reduced to a powder, they
are friable and thus covered by the Asbestos NESHAP. Broken
edges of these materials typically are friable. The fractured surface
should be rubbed to see if it produces powder.
If Category n nonfriable ACM has not crumbled, been pulverized or
reduced to powder and will not become so during the course of
demolition/renovation operations, it is considered nonfriable and
therefore is not subject to the Asbestos NESHAP. However, if
during the demolition or renovation activity it becomes crumbled,
pulverized or reduced to powder, it is covered by the Asbestos
NESHAP.
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APPENDIX A
ASBESTOS NESHAP COORDINATORS
(FOR DEMOLITION/RENOVATION ACTIVITIES
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3265
CT, MA, ME, NH, RI, VT
Asbestos NESHAP Coordinator
Air & Waste Management Division
U.S. EPA Region H
26 Federal Plaza
New York, NY 10278
(212) 264-6770
NJ, NY, PR, VI
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region m
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6550
DC, DE, MD, PA, VA, WV
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-5014
AL, PL, GA, KY, MS, NC, SC, TN
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6819
IL, IN, MI, MN, OH, WI
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7223
AR, LA, NM, OK, TX
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region VH
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
IA, KS, MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA Region Vm
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-7685
CO, MT, ND, SD, UT, WY
A-l
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Asbestos NESHAP Coordinator
Air and Toxics Division
U.S. EPA Region DC
75 Hawthorne Street
San Francisco, CA 94105
(415) 774-5569
American Samoa, AZ, CA, Guam, HI
Northern Marianas, Trust Territories
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(205) 442-1757
AK, ID, OR, WA
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APPENDIX B
REGIONAL ASBESTOS COORDINATORS (FOR SCHOOLS)
Regional Asbestos Coordinator
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3835
CT, MA, ME, NH, RI, VT
Regional Asbestos Coordinator
U.S. EPA Region U
Woodbridge Avenue
Raritan Depot, Building 5
Edison, NJ 08837
(201) 321-6671
NJ, NY, PR, VI
Regional Asbestos Coordinator
U.S. EPA Region m
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-3160
DC, DE, MD, PA, VA, WV
Regional Asbestos Coordinator
ILS. EPA Region IV
345 Courtland SL N.E.
Atlanta, GA 30365
(404) 347-5014
AL, PL, GA, KY, MS, NC, SC, TN
Regional Asbestos Coordinator
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 886-6003
IL, IN, MI, MN, OH, WI
Regional Asbestos Coordinator
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244
AR, IA, NM, OK, TX
Regional Asbestos Coordinator
U.S. EPA Region VD
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
IA, KS, MO, NE
Regional Asbestos Coordinator
U.S. EPA Region VJH
1 Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2413
(303) 293-1442
CO, MT, ND, SD, UT, WY
B-!
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Regional Asbestos Coordinator
U.S. EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5406
American Samoa, AZ, CA Guam,
Northern Marianas, Trust Territories
Regional Asbestos Coordinator
U.S. EPA Region IV
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-4762
AK, ID, OR, WA
* U.S. GOVERNMENT PRINTING OFFICE: 1991-518-987
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Item 3 - Asbestos/NESHAP Adeqately Wet Guidance
-------
is^'rC^i^ias^
. . -.
-------
EPA340/1-90-019
ASBESTOS NESHAP
ADEQUATELY WET GUIDANCE
US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and
Standards
Stationary Source Compliance Division
Washington, DC 20460
December 1990
-------
CONTENTS
Section Page
1 INTRODUCTION 1
2 IMPORTANT TERMS 2
Adequately Wet 2
Friable Asbestos Material 3
Nonfriable Asbestos-containing Materials 3
3 FRIABLE AND NONFRIABLE ASBESTOS
CONTAINING MATERIALS 4
4 REQUIREMENTS FOR ADEQUATELY WETTING
ASBESTOS-CONTAINING MATERIALS 5
5 EXCEPTIONS TO ADEQUATELY WETTING
ASBESTOS-CONTAINING MATERIALS 9
6 TECHNIQUES FOR WETTING ASBESTOS-CONTAINING
MATERIALS 11
General Information 11
7 PROCEDURES FOR WETTING ASBESTOS-CONTAINING
MATERIALS 12
Thermal System Insulation 12
Asbestos-Containing Surfacing Materials 18
Miscellaneous Asbestos-
Containing Materials 18
8 INSPECTION PROCEDURES 21
Appendices
A Asbestos NESHAP Coordinators
(for Demolition/Renovation Activities) A-l
8 Regional Asbestos Coordinators
(for Schools) B-l
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ACKNOWLEDGEMENTS
This document was written by Alliance Technologies, Inc.,
based on discussions with a work group from EPA. The group
consisted of the Regional Asbestos NESHAP Coordinators, Ron Shafer,
Scott Throwe, and Omayra Salgado of the Stationary Source Compliance
Division, Charles Garlow and Elise Hoerath of the Air Enforcement
Division and Sims Roy of the Standards Development Branch. We thank the
individuals who reviewed an earlier draft and provided comments, many of
which are incorporated in the final version. Their input is gratefully
acknowledged.
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1. INTRODUCTION
The Clean Air Act (CAA) of 1970 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. The Asbestos NESHAP (40 CFR 61,
Subpart M) addresses milling, manufacturing and fabricating
operations, demolition and renovation activities, waste disposal
issues, active and inactive waste disposal sites and asbestos
conversion processes.
The Asbestos NESHAP requires facility owners and/or operators
involved in demolition and renovation activities to control emissions
of paniculate asbestos to the outside air because no safe
concentration of airborne asbestos has ever been established. The
primary method used to control asbestos emissions is to adequately
wet the Asbestos Containing Material (ACM) with a wetting agent
prior to, during and after demolition/renovation activities.
The purpose of this document is to provide guidance to asbestos
inspectors and the regulated community on how to determine if
friable ACM is adequately wet as required by the Asbestos
NESHAP.
The recommendations made in this guidance are solely
recommendations. They are not the exclusive means of complying
with the Asbestos NESHAP requirements. Following these
recommendations is not a guarantee against findings of violation.
Determinations of whether asbestos materials are adequately wetted
are made by EPA inspectors on site.
2. IMPORTANT TERMS
Adequately Wet
EPA defines "adequately wet" to mean "sufficiently mix or penetrate
with liquid to prevent the release of particulates. If visible emissions
are observed coming from asbestos-containing material (ACM), then
that material has not been adequately wetted. However, the absence
of visible emission is not sufficient evidence of being adequately wet
(Section 61.141, Definitions). Amended water is often used to wet
ACM during repair/removal operations.
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Friable Asbestos Material
Friable asbestos material is any material containing more than
1 percent asbestos as determined using Polarized Light Microscopy
(PLM), that, when dry, can be crumbled, pulverized, or reduced to
powder by hand pressure.
Asbestos-Containing Waste Materials (ACWM)
EPA defines ACWM to mean mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to the
provisions of this subpart. This term includes filters from control
devices, friable asbestos waste material, and bags on other similar
packaging contaminated with commercial asbestos. As applied to
demolition and renovation operations, this term also includes friable
asbestos waste and Category II nonfriable ACM waste that becomes
crumbled, pulverized, or reduced to powder by forces that acted on
the material during the course of demolition and renovation
operations regulated by this subpart, and materials contaminated with
asbestos including disposal equipment and clothing.
Nonfriable Asbestos-containing Materials
Nonfriable asbestos-containing material is any material containing
more than 1 percent asbestos as determined using Polarized Light
Microscopy (PLM) that, when dry, cannot be crumbled, pulverized,
or reduced to powder by hand pressure.
Regulated Asbestos-Containing Material (RACM)
Is (a) friable asbestos material, (b) Category I nonfriable ACM that
has become friable, (c) Category I nonfriable ACM that will be or
has been subjected to sanding, grinding, cutting or abrading, or (d)
Category II nonfriable ACM that has a high probability oFbecoming
or has become crumbled, pulverized, or reduced to powder by the
force expected to act on the material in the course of demolition or
renovation operations.
3. FRIABLE AND NONFRIABLE ASBESTOS-
CONTAINING MATERIALS
The Asbestos NESHAP defines two categories of nonfriable ACM:
Category I nonfriable ACM (asbestos-containing packings, gaskets,
resilient floor covering and asphalt roofing products) and Category n
nonfriable ACM (any nonfriable material not designated as
Category I).
The Agency requires that, where the Asbestos NESHAP is
applicable, friable ACM and Category n and nonfriable ACM that is
likely to become disturbed or damaged so that the material could be
-------
crumbled, pulverized or reduced to powder during a demolition or
renovation oe removed, from a facility prior to its demolition/
renovation. The fibrous or fluffy spray-applied asbestos materials
found in many buildings for fireproofing, insulating, sound-proofing,
or decorative purposes are generally considered friable. Pipe and
boiler wrap found in numerous buildings is also considered friable.
Nonfriable ACM, such as vinyl-asbestos floor tile, generally emits
low levels of airborne fibers unless subjected to burning or to
sanding, grinding, cutting or abrading operations. Other materials,
such as asbestos cement sheet and pipe, can emit asbestos fibers if
the materials are crumbled, pulverized or reduced to powder during
demolition/renovation activities. Whenever nonfriable materials are
going to be damaged to the extent that they are crumbled, pulverized
or reduced to powder, they must be handled in accordance with the
Asbestos NESHAP.
4. REQUIREMENTS FOR ADEQUATELY WETTING
ASBESTOS-CONTAINING MATERIALS
The NESHAP regulation requires that RACM be adequately wetted
during the following activities:
a. During cutting or disjoining operations when a facility
component which is covered or coated with friable ACM
is being removed from that facility as units or in sections
(Section 61.145 (c)(2)(i)).
During demolitions or renovations a contractor may choose to
remove an entire boiler, a section of pipe, or other facility
components without first removing the asbestos insulation from these
structures. Any ACM which will oe disturbed during cutting or
disjoining operations must be adequately wet
b. During stripping operations when a facility component
containing RACM remains in place in the facility.
(Section 61.145 (c)(3)).
Stripping operations are the most common form of asbestos removal
during renovation activities, since most items that are covered with
asbestos are facility components or structural members which will
not be removed. Stripping off all of the RACM can generate
significant asbestos emissions if the ACM is not adequately wet
during removal.
Friable spray-on ACM, which includes fire-proofing materials found
on decking and support I-beams, is normally easy to wet throughout
because o? the absorbing property of the cellulose mixing/binding
-------
agent. The Asbestos NESHAP requires that these materials be fully
penetrated with the wetting agent during demolition/renovation
activities.
Other ACM, however, such as "thermal-block" insulation used on
pipes and boilers, certain ceiling and floor tile applications, etc.,
which do not absorb water readily may be hard to penetrate by water
or a wetting agent. For such materials, adequate wetting consists of
coating the surfaces of the materials with water or a wetting agent
prior to, during, and, in most cases, after removal activities in
order to prevent asbestos emissions. Whenever such materials are
broken during the removal process, the exposed, dry surfaces must
be wetted immediately to reduce emissions.
If pieces of dry ACM are accidentally disturbed, they should be
immediately wetted and kept wet until collected for disposal.
Removal personnel are commonly assigned to keep the fallen RACM
wet prior to its being collected for disposal.
c. After the RACM has been stripped from a facility
component, it must remain adequately wet until it has
been collected and contained or treated in preparation
for disposal. (Section 61.145 (c)(6)(i))
After removal, adequately wetted ACWM must be sealed in leak-
tight containers or wrapping which must be labeled as specified by
the Occupational Health and Safety Administration (OSHA) under 29
CFR 1910.1001(j)(2) or 1926.58(k)(2Xiii). Such waste materials
destined for off-site transport must additionally be labeled with the
name of the generator and location of the waste generation site
(Section 61.150 (a)(l)(iv and v)).
d. In demolitions where the RACM was not removed prior
to demolition (Section 61.145 (c)(l)(i)(ii)(iii)(iv))
RACM on a facility component encased in concrete
or other similarly hard material must be adequately
wet whenever exposed during demolitions (Section
61.145 (c)(l)(ii));
RACM which was not accessible for testing and,
due to demolition, cannot be safely removed, must
be kept adequately wet at all times until disposed of
(Section 6U45 (c)(l)(iii)): ^^
The portion of a facility ordered demolished that
contains RACM must be adequately wet during the
wrecking operation (Section 61.145 (c)(9)).
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In each of the above situations, ACWM generated must be kept
adequately wet during handling and loading for transport to the
disposal site. In cases where ACWM can't be segregated from the
debri pile it must be disposed of as ACWM. Such ACWM does not
have to be sealed in leak-tight containers or wrapping, but may be
transported and disposed of in bulk (Section 61.150 (a)(3)).
5. EXCEPTIONS TO ADEQUATELY WETTING ASBESTOS-
CONTAINING MATERIALS
The Asbestos NESHAP allows two exceptions to wetting RACM
during a demolition or renovation project:
When the temperature at the point of wetting is
below 0°C (32*F) (Section 61.145 (c)(7)(i)).
The owner/operator must remove facility
components coated or covered with friable ACM as
units or sections to the maximum extent possible and
meet subsequent requirements of 61.145, including
the wetting requirements.
During periods when wetting operations are
suspended due to freezing temperatures, the
owner/operator must record the temperature in the
area containing the facility components at the
beginning, middle, and end of each workday and
keep daily temperature records available for
inspection by the Administratorduring normal
business hours at the demolition or renovation site.
The owner or operator shall retain the temperature
records for at least 2 years.
When the use of water would unavoidably
damage equipment or present a safety hazard
(Sec. 61.145 (c)(3)(i)(A)).
The owner/operator must first obtain written
approval from the Administrat9r for an alternative
work practice, prior to renovation activities and
utilize a local exhaust ventilation and collection
system designed to capture particulate asbestos
released during removal operations. (Section 61.145
(c)(3)(i)(B)Q)T; or a glove bag system or a leak-tight
wrapping which can contain the particulate asbestos
* » *^ « « . » \ ^^% f f& *--
materials produced by stripping ACM. (Section
61.145 (c)(3)(i)(B)(2)and Q))
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6. TECHNIQUES FOR WETTING ASBESTOS-
CONTAINING MATERIALS
General Information
Adequate wetting of ACM is typically accomplished by repeatedly
spraying it with a liquid or a wetting agent, usually amended water
(water to which surfactant chemicals have been added), until it can
absorb no more. However, this does not necessarily mean that the
ACM will be soaked throughout. Surfactant chemicals reduce the
surface tension of the water, thereby increasing its ability to
penetrate the ACM and surround the asbestos fibers. Although
amending agents are not required by the Asbestos NESHAP (the
NESHAP only requires the use of a liquid), EPA, in its "Guidance
for Controlling Asoestos-Containing Materials in Buildings", EPA-
560/5-85-024 (Purple Book), recommends the use of a 50:50 mixture
of polyoxyethylene ester and polyoxyethylene ether, or the
equivalent, in a 0.16 percent solution (1 ounce to 5 gallons) of water.
Wetting agents may be applied with garden sprayers or hoses.
Garden sprayers are hand-held, portable, and nave a one- to five-
gallon capacity. Water hoses are usually attached to a faucet tap,
Fire hydrant or water tank. Generally, the hose has a nozzle attached
which spreads the water stream so that a fine mist is created.
An engineering control often used is a misting unit which can be
used to create a high level of humidity within a removal area. It is
believed that fibers emitted into a saturated environment will absorb
the wetting agent and fall out of the air faster, thus reducing airborne
fiber levels.
7. PROCEDURES FOR WETTING ASBESTOS-
CONTAINING MATERIALS
The following procedures describe methods of adequately wetting
various applications of ACM.
Thermal System Insulation
Molded Pipe Insulation
The recommended wetting procedure for this type of RACM is to
saturate the outer surface with amended water, strip off the wet
canvas coating and then rewet the surface in order to thoroughly
saturate the ACM. The metal bands supporting the RACM should
be removed and the half-round sections carefully separated. While
this occurs, the interior side and edges of the sections should be
saturated with amended water. If a section breaks during removal,
the exposed surfaces should be wetted immediately. A misting
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sprayer may also be used to keep the air in the removal area or
containment area saturated with amended water to attempt to reduce
airborne asbestos fiber levels.
Corrugated Paper Pipe Insulation
The outer surface of the corrugated paper ("air-cell") pipe insulation,
usually a canvas wrap, should DC saturated with a wetting agent and
then removed. Wetting should continue until all the insulation is
permeated with amended water. Metal bands holding the insulation
in place should be removed and the corrugated RACM insulation
stripped. Any unsaturated surfaces exposed during the stripping
operation must be wetted immediately to reduce asbestos emissions.
A misting sprayer may also be used to keep the air in the removal
area saturated with amended water to attempt to reduce airborne
asbestos fiber levels. Inadequately wetted and adequately wetted
corrugated paper pipe insulation can be seen in Figures 1 and 2.
Figure 1. Inadequately wetted corrugated paper, pipe insulation.
(Note the fibrous material adjacent to the lagging clamp.)
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Figure 2. Adequately wetted corrugated paper, pipe insulation.
(Note the saturated material adjacent to the lagging clamp.)
Boiler and Water Tank Thermal Block Insulation
Asbestos-containing preformed block insulation has been used as
thermal insulation on boilers, hot water tanks and heat exchangers in
industrial, commercial, institutional and residential applications. The
blocks are commonly chalky in nature and may be held in place by
chicken wire or expanded metal lath. A plaster-saturated canvas was
often applied as a final covering or wrap.
Due to the number, thickness and varying absorbencies of these
layers of materials, adequate wetting may be accomplished only by
continually wetting the materials with amended water as the various
layers are
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One person may be assigned to spray the materials as they are
stripped, and a misting sprayer may oe used in an attempt to reduce
airborne asbestos fiber levels.
Cementitious Fitting Insulation
Wetting of cementitious fitting insulation is similar to that used when
removing asbestos-containing thermal block insulation. The outer
surface is saturated with amended water and the outer covering (if
applicable]) is removed. The fitting insulation is then rewetteo and
the insulation stripped. To ensure that the fitting remains adequately
wet during the removal operation, a person is often assigned to spray
the ACM as it is stripped. A misting sprayer may be used to reduce
airborne asbestos fiber levels. Inadequately wetted cementitious
fitting insulation can be seen in Figure 3.
Figure 3. Inadequately wetted cementitious fitting insulation. (Note
that the part of the insulation which has been wetted is dark grey in
color, whereas the dry section remains white.)
Asbestos-Containing Surfacing Materials
"Surfacing Material" is a generic term designated by the Asbestos
Hazard Emergency Response Act (AHERA; Asbestos Containing
Materials in Schools, 40 CFR Part 763, Subpart E) to mean any wall
or ceiling material that is sprayed-on or troweled-on, such as
acoustical plaster or fireproofing. The recommended wetting method
-------
for this type of RACM is to saturate the surfaces, begin the stripping
operation and continue to wet the RACM as it is being removed. A
misting sprayer may also be used to keep the air saturated while the
removal occurs. Since surfacing materials vary in their ability to
absorb a wetting agent, inspectors must consider the type of
surfacing material that is being removed in order to determine the
requirea extent of penetration oy the amended water. Surfacing
materials which easily absorb a wetting agent need to be fully
penetrated or permeated to be considered adequately wet, whereas
only the exposed surfaces of materials which do not absorb water
readily need to be wetted.
The use of high pressure water to remove asbestos-containing
surfacing materials, either through a steam-cleaning device or a
diesel powered hydroblasting water applicator, should be avoided
since such use may unduly disturb RACM and contribute to higher
airborne asbestos fiber levels. However, if this removal method is
used, contractors must adequately wet the ACM prior to and during
the removal.
Miscellaneous Asbestos-Containing Materials
Both friable and nonfriable forms of other asbestos-containing
building materials exist. Friable materials include asbestos-
containing paper (commonly found beneath wooden floors),
wallpaper, and joint compound. It has been estimated that 5 to 10
percent of the ceiling tiles currently installed in the U.S. contain
asbestos.
Nonfriable miscellaneous ACM includes floor tiles, asbestos cement
sheet (transite board), siding shingles, asphalt roofing shingles,
laboratory benchtpps and even chalkboards. These materials may
become friable with age, and under harsh conditions. Category I
nonfriable ACM must be carefully examined to determine if the
material is in poor condition, that is, if the binding material is losing
its integrity, exhibited by peeling, cracking or crumbling; and is also
friable. When Category I nonfriable ACM has become friable it is
subject to the NESI
If Category I or II ACM is sanded, ground, cut or abraded it is also
covered by the NESHAP. Category n nonfriable ACM which is
damaged to the extent that it has or will become crumbled,
pulverized or reduced to powder due to demolition/ renovation
activities, is subject to the Asbestos NESHAP.
Miscellaneous materials are wetted in manners similar to those used
to wet other categories of RACM. Coverings are saturated with a
wetting agent before removal and the asbestos-containing portions
fully penetrated with the agent prior to, during and after their
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removal, while stored in the removal area, and while being placed
into disposal containers. Miscellaneous materials that don't absorb
water readily (e.g., asbestos-concrete products, and floor tiles) are
only required to nave wetted surfaces. A misting sprayer may be
used to diminish airborne asbestos fiber levels.
8. INSPECTION PROCEDURES
The intent of the following guidelines is to provide
GUIDANCE ONLY, to the regulated community regarding the
inspection procedures recommended to Asbestos NESHAP inspectors
for determining compliance with the "Adequately Wet" requirements
of the Asbestos NESHAP. The purpose or the wetting provisions is
to require as much wetting as is necessary to prevent airborne
emissions of asbestos fibers. In order to achieve this result, RACM
and ACWM must be wetted and maintained wet until collected for
disposal. The determination of whether RACM or ACWM has been
adequately wetted is generally based on observations made by the
inspector at the time of inspection. Observations probative of
whether a material is adequately wet include but are not limited to,
the following:
1. Is there a water supply in place?
2. Is water or a wetting agent observed being sprayed onto the
RACM or ACWM both during stripping or removal and
afterwards while the material awaits proper disposal? If yes,
carefully note the method of application used (e.g., misting,
fogging, spraying of surface area only or drenching to
penetrate the ACM throughout).
3. If water or a wetting agent is being used, what equipment is
used to apply it (e.g., garden hose, plant mister)?
4. If water or a wetting agent is not being used, determine why
it is not and document the reason. Possible (although not
necessarily valid) reasons include:
prior permission obtained from the Administrator
(safety hazard, potential equipment damage);
no water source at the facility;
temperature at the point of wetting below
32 degrees F;
portable water supply ran out and contractor
continued to work; or
contractor prepared the area earlier, etc.
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5. Examine a stripped CM- removed piece of ACWM or RACM
which wets readily. Does it appear to be wetted throughout?
If it does not, adequately wet the sample. Describe and
photograph how the physical characteristics of the
material change upon wetting (e.g., color, weight, texture,
etc.). Take samples, as necessary, to document the presence
of asbestos in the suspect material.
6. When examining materials that do not readily absorb water
or a wetting agent (e.g., premolded thermal system
insulation, ceiling tiles, floor tiles) inspectors should note
whether all exposed surfaces of these materials have been
wetted as required.
7. Is there visible dust (airborne or settled), or dry ACWM
debris in the immediate vicinity of the operation? Inspectors
should collect samples of such materials for analysis of their
possible asbestos content.
8. Examine ACWM in bags or other containers using the
procedures that follow, to determine if the material has been
adequately wetted?
1. Randomly select bags or the containers for
inspection.
2. Lift the bag and assess its overall weight. (A bag of
dry ACWM can generally be lifted easily by one
hand. A bag filled with well-wetted material would
be substantially heavier.)
3. If the bag or other container is transparent:
Visually inspect the contents of the
unopened bag for evidence of moisture (e.g.,
water droplets, water in the bottom of the
bag, a change in the color of the material
due to water).
Without opening the bag, squeeze chunks of
debris to ascertain whether moisture droplets
are emitted.
If the material appears dry or not penetrated
with liquid or a wetting agent, open the bag
using the additional steps described in step 9
below, and collect a bulk sample of each
type of material in the bag ascertaining
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variations in size, patterns, color and
textures.
9. If the waste material is contained in an opaque bag or other
container, or if the material is in a transparent bag which
appears to be inadequately wetted:
» Carefully open the bag (in the containment
area, if possible). If mere is no containment
area at the site, a glove bag may be used to
enclose the container prior to opening it to
minimize the risk of any fiber release.
Examine the contents of the bag for
evidence of moisture as in 8 above, and if
the material appears dry or it is not fully
penetrated with water or a wetting agent,
collect a bulk sample.
Reseal the bag immediately after evaluating
and sampling its contents.
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APPENDIX A
ASBESTOS NESHAP COORDINATORS
(FOR DEMOLITION/RENOVATION ACTIVITIES)
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region I
JFK Federal Building
Boston, MA 02203
(617) 565-3265
CT, MA, ME, NH, RI, VT
Asbestos NESHAP Coordinator
Air & Waste Management Division
U.S. EPA Region II
26 Federal Plaza
New York, NY 10278
(212) 264-6770
NJ, NY PR, VI
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region ffl
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-6550
DC, DE, MD, PA, VA, WV
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region IV
345 Courtland Street, NJ2.
Atlanta, GA 30365
(404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312)886-6793
IL, IN, MI, MN, OH, WI
Asbestos NESHAP Coordinator
Air, Pesticide & Toxics Division
U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7223
AR, LA, NM, OK, TX
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
IA, KS, MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA Region VIE
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1767
CO, MT, ND, SD, UT, WY
Asbestos NESHAP Coordinator
Air Management Division (A-3-3)
U.S. EPAlRegion DC
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5569
AS, AZ, CA, GU, HI, NV,
Northern Marianas, TT
Asbestos NESHAP Coordinator
Air & Toxics Management Division
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(205) 442-1757
AK, ID, OR, WA
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APPENDIX B
REGIONAL ASBESTOS
COORDINATORS (FOR SCHOOLS)
Regional Asbestos Coordinator
EPA Region I
Air & Management Division
JFK Federal Building
Boston, MA 02203
(617) 565-3835
ME, NH, RI, VT
Regional Asbestos Coordinator
EPA Region II
Woodbndge Avenue
Raritan Depot, Building 5
Edison, NJ 08837
(201) 321-6671
NJ, NY, PR, VI
Regional Asbestos Coordinator
EPA Region UI
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-3160
DC, DE, MD, PA, VA, WV
Regional Asbestos Coordinator
EPA Region IV
345 Courtland St N.E.
Atlanta, GA 30365
(404) 347-5014
AL, FL, GA, KY, MS, NC, SC, TN
Regional Asbestos Coordinator
EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312)886-6003
IL, IN, ML MN, OH, WI
Regional Asbestos Coordinator
EPA Region VI
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244
AR, LA, NM, OK. TX
Regional Asbestos Coordinator
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
IA, KS, MO, NE
Regional Asbestos Coordinator
EPA Region Vm
1 Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2413
(303) 293-1442
CO, MT, ND, SD, UT, WY
Regional Asbestos Coordinator
EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 556-5406
AS, AZ, CA GU, HI, NV,
Northern Marianas, TT
Regional Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-4762
AK, ID, OR, WA
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Item 4 - Reporting And Recordkeeping Requirements For Waste
Disposal
(A Field Guide)
-------
r/EPA
United States
Environmental Protection
Agency
Air And Radiation
(EN-341)
EPA 340/1-90-016
November 1990
Reporting And
Recordkeeping Requirements
For Waste Disposal
A Field Guide
'.A,
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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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\>EPA Reporting And
Recordkeeping Requirements
For Waste Disposal
A Field Guide
-------
FIELD GUIDE
REPORTING AND RECORDKEEPING REQUIREMENTS FOR WASTE DISPOSAL
This is a guide to help you comply with the new reporting and recordkeeping requirements of
the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). The specific
responsibilities of waste generators, transporters and waste disposal site operators are addressed, as
well as detailed explanations of how to complete the new forms accurately and efficiently. This field
guide is organized into four main sections as follows:
Waste Shipment Record
Reporting Requirements
Recordkeeping Requirements
Source Reporting Requirements for Disposal Site Operators
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I. WASTE SHIPMENT RECORD
After (the effective date of this rule), all shipments of asbestos containing waste material must be
accompanied by a Waste Shipment Record (WSR) similar to the sample shown in Figure 1. When it is
signed by the generator, the transporter and the waste disposal site operator, the WSR documents the
movement and ultimate disposition of asbestos waste. The WSR consists of three parts and requires
three signatures, those of the generator, the transporter and the disposal site operator.
A. Waste Generator
Waste generator means any owner or operator of a source covered by this rule whose
activities produce asbestos-containing waste materials. Included are asbestos mills,
manufacturers, fabricators, demolitions, renovations and spraying operations [40 CFR 61.149
and 150]. Generators are responsible for filling out Items 1-9 of the WSR. The original should
be turned over to the transporter along with the waste shipment, although the generator
should retain a copy of the WSR signed by the transporter acknowledging receipt of the waste
shipment (Item 10) for his records.
Directions for filling out the WSR form are found in Figure 1. Items 1-4 and 6 provide
important reference information. In Item 5, Category I nonfriable materials (asbestos-
containing packings, gaskets, resilient floor covering and asphalt roofing products) should be
considered nonfriable if they have not been sanded, ground, burned, or abraded; and Category
II materials such as asbestos-cement products taken out before demolition may be reported as
nonfriable also.
Item 7 asks for the quantity of waste in cubic meters or cubic yards. You may report in the
units that you are most comfortable using, but you are expected to make a good faith effort to
report correctly. Some helpful conversion factors are provided below:
Drums and barrels used as asbestos-waste containers are typically of 35 gallons capacity.
Gallons can be converted to cubic yards by multiplying gallons by 0.00379. In our example, 35
gallons x 0.00379 - 0.133 cubic yards for the volume of a drum or barrel.
Plastic bags have a nominal volume of 0.1 cubic yards, but when they contain asbestos waste
their volume is assumed to be about 0.075 cubic yards.
Cubic yards can be changed to cubic meters by multiplying cubic yards by 0.765. The drum
for which we calculated a volume of 0.133 cubic yards would have a volume of 0.133 x 0.765 =
0.102 cubic meters.
Follow the instructions given in Figure 1 to complete Items 8 and 9. When you turn the waste
over to the transporter, require the transporter to acknowledge receipt of the asbestos waste by signing
the WSR at Item 10: retain a copy of the WSR signed by the transporter for your files.
B. Transporter
At the time that you take possession of the load of waste, ask the generator for a WSR.
Acknowledge receipt of the asbestos waste by signing the WSR at Item 10; return a copy of it
to the generator. If you turn the shipment over to a second transporter require him to
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acknowledge receipt of the shipment by signing the WSR at Item 11. It is recommended that
you retain a copy of the signed document for your files when you surrender the WSR to a
second transporter. The transporter who delivers the waste shipment to the waste disposal
site should surrender the WSR to the disposal site operator. It is recommended that you keep
a copy of the WSR signed by the disposal site operator for your files as a matter of good
business practice.
C. Waste Disposal Site Operator
Waste disposal site operators are not expected to open bags or other containers to verify that
the material is asbestos: if a WSR accompanies the shipment, that is sufficient verification.
You must complete Items 12 and 13 of the WSR according to the instructions in Figure 1 and
send a copy of the WSR according to the name and address listed in Item 2 of the WSR. The
disposal site operator should check to see that the numbers of containers reported in WSR
Item 6 and the quantities reported in WSR Item 7 appear to be correct. Any discrepancy
should be noted in Item 12.
If the WSR indicates a truckload of asbestos waste, ask the driver if he knows the truck's cargo
capacity. If he cannot tell you the capacity, estimate it by multiplying the length by the width
by the height of the cargo compartment (all in feet) and divide by 27 cubic feet to obtain cubic
yards. If you know the capacity of a trucksay 20 cubic yardsand you judge it to be half-
full, estimate the load as 10 cubic yards.
Item 12 is also used to note improperly enclosed or uncovered waste.
H. REPORTING REQUIREMENTS
The revised NESHAP now includes reporting requirements for generators and waste disposal
site operators. Generators are required to submit exception reports if they do not receive a copy of the
WSR signed by the disposal site owner or operator within 45 days of the date the shipment was
accepted by the first transporter. Disposal site operators must file reports of discrepancies between the
quantities of waste indicated on the WSR and the quantities actually received, as well as reports of
improperly enclosed or uncovered waste.
A. Exception Report
If you as a generator of a shipment of asbestos waste do not receive a copy of the WSR signed
by the disposal site operator within 35 days after you turned the waste over to the first
transporter, you must take steps to locate the waste shipment.
First, contact the transporter and verify the fact that the waste was delivered to the waste
-disposal site specified in Item 3 of the WSR. If the transporter has not delivered the shipment,
determine the reason for the delay, and when it will be delivered. If the transporter has
delivered the waste to the specified waste disposal site, inquire if a copy of the WSR signed by
the disposal site operator can be made available to you. (The transporter is not required to
obtain or keep a copy signed by the disposal site operator: however, some may do so as a
matter of good business practice.) Next contact the disposal site operator and determine why
you have not received a copy of the WSR signed by him. Request that the disposal site
operator send a signed copy of the WSR to you immediately.
If you have not received a signed WSR from the disposal site operator within 45 days after
you turned the waste over to the initial transporter, you must submit a written exception
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report to the responsible NESHAP program agency (see Appendix A for a list of agencies and
their jurisdictions). The report should include a copy of the WSR in question as well as a
cover letter that explains what you have done to locate the shipment, and the results of your
search.
B. Discrepancy Report
As a waste disposal site operator, you will be checking the WSR that accompanies each
asbestos waste shipment that arrives at your site to make sure that the information on the
WSR accurately describes the waste shipment. If you see that there is a discrepancy between
the number of containers shown on the WSR and the number that you count in the truck you
should note this in Item 12 of the WSR and contact the generator to determine if there is a
reasonable explanation for the discrepancy. If you are able to reconcile the apparent
discrepancy, make a note of it on the WSR and forward it to the generator as you would
normally do.
If you are unable to resolve the discrepancy within 15 days of accepting the waste, you must
send a written discrepancy report immediately to the responsible agency in whose jurisdiction
the generator of the waste is located. The discrepancy report should describe the discrepancy
in question and the steps you have taken to obtain an explanation for it, such as how and
when you attempted to reach the generator. A copy of the shipment's WSR must accompany
the discrepancy report.
C. Report of Improperly Enclosed or Uncovered Waste
Disposal site operators will check asbestos waste shipments arriving at their sites and are
expected to look for significant amounts of improperly enclosed or uncovered waste before the
material is disposed of. If significant amounts of improperly enclosed or uncovered waste are
discovered in a shipment (see discussion under WSR), note it in Item 12 of the WSR and send,
by the following working day, a written report of the problem to the specific agency
responsible for administering the NESHAP program for the jurisdiction where the job site is
located (identified on the WSR). If the disposal site is located in a different jurisdiction than
the job site, you should also send a copy of the WSR to the agency responsible for the disposal
site. The written report should describe the improperly enclosed or uncovered waste in
sufficient detail that the responsible agency can determine the urgency of the situation and
what action to take. A copy of the WSR must be submitted along with the written report.
HI. RECORDKEEPING REQUIREMENTS
New requirements for recordkeeping are set for waste generators and waste disposal sites.
Generators must keep copies of all WSR's for at least 2 years. In addition to keeping WSR's for at
least 2 years, active waste disposal sites must also keep records of the asbestos-containing waste
material located within the site.
A. Waste Generator
As a waste generator, you must retain copies of all WSR's, including WSR's signed by the
owner or operator of the waste disposal site where the waste was deposited for at least 2
years. The WSR's should be kept in chronological order in a secure, water-tight file. You are
expected to provide copies of WSR's upon request of the responsible agency and to make the
WSR file available for inspection during normal business hours.
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B. Active Waste Disposal Site Operator
You, the waste disposal site operator, are required to keep copies of WSR's that you have
received for at least 2 years. The WSR's should be kept in chronological order in a secure,
water-tight file. You are expected, further, to provide copies of WSR's upon request of the
responsible agency and to make the WSR file available for inspection during normal business
hours.
Another new requirement is that you now must maintain up-to-date records that indicate the
location, depth and area, and quantity of asbestos containing waste material within the
disposal site on a map or diagram of the disposal area.
You have the option of either restricting the asbestos waste to specified areas within the
disposal site or depositing it throughout the site. In making this decision you should consider
the future use of the property after the disposal site has been closed. By restricting the area
where asbestos waste is deposited you will be able to preserve more of the property for future
use. However, if you choose to deposit asbestos waste throughout the site, the responsible
agency would consider that the entire disposal area contains asbestos.
When you open a new trench (or area) for asbestos waste disposal, place stakes in the ground
at the comers of the trench. Take precautions to see that the stakes are kept where they are
originally positioned and are not broken during the time that the trench is being filled. When
you have filled the trench, call in a land surveyor. The surveyor will use the stakes to
determine the location of the asbestos deposit within the disposal site. Ask the surveyor to
prepare a map or diagram of the disposal site that shows the location(s) and surface
dimensions of the asbestos deposit.
Before beginning to fill a new trench with asbestos waste, measure the maximum depth of the
trench, record it, and save it to put on the map provided by the surveyor. Use the data
provided in Item 7 of the WSR's to obtain the quantity of asbestos-containing waste material.
Add up the cubic yards (cubic meters) of waste indicated on the WSR's for all of the asbestos
waste shipments that are deposited in the trench up until the time that it is full and is closed.
Also, put the total quantity of asbestos-waste deposited at the site on the map provided by the
surveyor.
The map should be kept current until the time that the waste disposal site is closed. At
closure you must submit a copy of records of asbestos waste disposal locations and quantities
to the agency responsible for administering the NESHAP program in your area. The
surveyor's map or diagram of the disposal site with the location and surface dimensions of the
asbestos deposit(s), maximum depth of the deposit(s) and asbestos waste quantities fulfills this
requirement and should be submitted to the Administrator. See Figure 2 for an example of a
map.
Within 60 days of closing your waste disposal site you must record on the deed to the waste
disposal site the following information:
The land has been used for the disposal of asbestos-containing waste material,
The survey plot and record of the location and quantity of asbestos containing waste
disposed of within the disposal site have been filed with (name of responsible agency), and
The site is subject to 40 CFR 61 Subpart M.
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In some states, a Notation of Deed form can be used to add this information to a deed, while
in others it may be easier to prepare a new deed than it is to annotate an existing deed. You should
contact the Register of Deeds at the county seat of the county in which your disposal site is located to
learn the rules that cover deeds and for instructions on how to proceed.
IV. SOURCE REPORTING REQUIREMENTS FOR DISPOSAL SITE OPERATORS
Another new requirement is that, within 90 days of the effective date of this rule, you are
required to report certain information about your asbestos waste disposal operations to the responsible
asbestos NESHAP program agency (see Appendix A for a list of agencies). Section 61.153 of the
asbestos NESHAP requires that you report the following information:
A brief description of the waste disposal site, which would include such information as the
location and size of the disposal facility.
A description of the method or methods that will be used to comply with the asbestos
NESHAP, or a description of alternative methods that will be used. Methods to be used, such
as covering asbestos waste daily with 6 inches of nonasbestos cover or the use of dust
suppressants should be reported. Other information that might be reported includes
procedures to prevent public access to the asbestos waste disposal area, such as the use of
warning signs and fencing. You must report this information using the format in Appendix A
of Part 61 of Title 40 of the Code of Federal Regulations (40 CFR).
In addition to the information listed above, you as the waste disposal site operator, must also
report the following information required by the source reporting requirements of Section 61.10 of
Subpart, Part 61 of 40 CFR.
Name and address of the owner or operator.
The location of the source.
The type of hazardous pollutants emitted by the stationary source.
A brief description of the nature, size, design, and method of operation of the stationary
source including the operating design capacity of the source. Identify each point of emission
for asbestos.
The average weight per month of asbestos being processed by the source over the last 12
months preceding the date of the report.
If there is a change in any of the information listed above, you must report the changes to the
appropriate agency within 30 days after they occur.
-------
| Generator |
( Transporter
V
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10
in
O
Q.
(SI
5
1. Work site name and mailing address
2. Operator's name and address
Owner's name
3. Waste disposal site (WOS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
agency
6. Containers
No. Type
Owner's
telephone no.
Operator's
telephone no.
WDS
phone no.
7. Total quantity
m3 (yd3)
8. Special handling instructions and additional information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are 1n all
respects 1n proper condition for transport by highway according to
applicable international and government regulations.
Printed/typed name & title
10. Transporter 1 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/ typed name & title
, Address and telephone no.
12. Discrepancy Indication space
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
13. Waste disposal site
owner or operator: Certification of receipt of asbestos materials
covered bv this manifest except as noted in item 12.
Printed/typed name & title
Signature
Month Day Year
(Continued
Figure 1. Waste Shipment Record
-------
INSTRUCTIONS
Waste Generator Section (Items 1-9)
1. Enter the name of the facility at which asbestos waste 1s generated and
the address where the facility 1s located. In the appropriate spaces,
also enter the name of the owner of the facility and the owner's phone
number.
2. If a demolition or renovation, enter the name and address of the company
and authorized agent responsible for performing the asbestos removal.
In the appropriate spaces, also enter the phone number of the operator.
3. Enter the name, address, and physical site location of the waste
disposal site (WDS) that will be receiving the asbestos materials. In
the appropriate spaces, also enter the phone number of the WDS. Enter
"on-slte" 1f the waste will be disposed of on the generator's property.
4. Provide the name and address of the local, State, or EPA Regional office
responsible for administering the asbestos NESHAP program.
5. Indicate the types of asbestos waste materials generated. If from a
demolition or renovation, Indicate the amount of asbestos that 1s
- Friable asbestos material
- Nonfrlable asbestos material
6. Enter the number of containers used to transport the asbestos materials
listed 1n Item 5. Also enter one of the following container codes used
1n transporting each type of asbestos material (specify any other type
of container used 1f not listed below):
DM - Metal drums, barrels
DP - Plastic drums, barrels
BA - 6 mil plastic bags or wrapping
7. Enter the quantities of each type of asbestos material removed 1n units
of cubic meters (cubic yards).
8. ' Use this space to Indicate special transportation, treatment, storage
or disposal or Bill of Lading Information. If an alternate waste
disposal site 1s designated, note 1t here. Emergency response
telephone numbers or similar information may be Included here.
NOTE: The waste generator must retain a copy of this form.
(continued)
Figure 1. Waste Shipment Record
-------
9. The authorized agent of the waste generator must read and then sign
and date this certification. The date 1s the date of receipt by
transporter.
Transporter Section (Items 10 & 11)
10. & 11. Enter name, address, and telephone number of each transporter
used, 1f applicable. Print or type the full name and title of
person accepting responsibility and acknowledging receipt of
materials as listed on this waste shipment record for transport.
Enter date of receipt and signature.
NOTE: The transporter must retain a copy of this form.
Disposal Site Section (Items 12 & 13)
12. The authorized representative of the WDS must note 1n this space any
discrepancy between waste described on this manifest and waste actually
received as well as any improperly enclosed or contained waste. Any
rejected materials should be listed and destination of those materials
provided. A site that converts asbestos-containing waste material to
nonasbestos material 1s considered a WDS.
13. The signature (by hand) of the authorized WDS agent Indicates
acceptance and agreement with statements on this manifest except as
noted In Item 12. The date 1s the date of signature and receipt of
shipment.
NOTE: The WDS must retain a completed copy of this form. The WDS must
also send a completed copy to the operator listed 1n Item 2.
Figure 1. Waste Shipment Record
9
-------
Route No. 55 2.5 miles to Raleigh, N.C.
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Waste
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s m 100'
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. Asbestos
8 Waste
00 Disposal
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Maximum dep
Area Quantity- 10.
1378'
Not to scale
Iron rod
Stone monument
Surface
400' N60°-00'W-
Flgure 2. Example plat of waste disposal site showing asbestos waste disposal area.
-------
Appendix A
Local, State, and EPA Regional Agencies
Responsible for Administering
The Asbestos NESHAP Program
n
-------
EPA Regions
Region 1 Asbestos NESHAP Coordinator
Air Management Division
U.S. EPA
JFK Federal Building
Boston, MA 02203
(617) 565-3265
States: CT, MA, ME. NH. RI, VT
Region 2 Asbestos NESHAP Coordinator
Air & Waste Management
Division
U.S. EPA
26 Federal Plaza
New York. NY 10278
(212) 264-6770
States: NJ, NY. PR. VI
Region 3 Asbestos NESHAP Coordinator
Air. Toxics & Radiation
Management Division
U.S. EPA
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-6550
States: DC, DE. MD, PA. VA, WV
Region 4 Asbestos NESHAP Coordinator
Air. Pesticide & Toxic Division
U.S. EPA
345 Courtland Street, N.E.
Atlanta. GA 30365
(404) 347-5014
States: AL, FL, GA, KY, MS. NC,
SC.TN
Region 5 Asbestos NESHAP Coordinator
Air & Radiation Division
U.S. EPA
230 South Dearborn Street
Chicago. IL 60604
(312)353-6793
States: IL. IN. MI. MN, OH. WI
Region 6 Asbestos NESHAP Coordinator
Air. Pesticides & Toxics Division
U.S. EPA
1445 Ross Avenue, Suite 1200
Dallas. TX 75202-2733
(214) 655-7223
States: AR, LA, NM. OK, TX
Region 7 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7018
States: 1A, KS, MO, NE
Region 8 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 294-7685
States: CO. MT. ND, SD, UT, \VY
Region 9 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1135
States: AZ. CA, HI, NV
Region 10 Asbestos NESHAP Coordinator
Air & Toxics Division
U.S. EPA
1200 6th Avenue
Seattle. WA 98101
(206) 442-1757
States: AK. ID, OR. WA
12
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Region 1 State contacts
Region 2 State Contacts
REGION 1
REGION 2
Connecticut Damlen Houlihan
U.S. EPA
JFK Federal Building, Room
2313
Boston. MA 02203
(617) 565-3265
Maine Bruce Buck
Dept. of Environmental
Protection
State House. Station 17
Augusta. ME 04333
(207) 582-8740
Massachusetts Metro Boston and North
John MacAuley
Dept. of Environmental
Protection
5 Commonwealth Avenue
Woburn. MA 01801
(617) 935-2160
Southeast
Vacant. Inquiries are being
temporarily handled by the Metro
Boston and North office (above)
Central
Greg Levins
Dept of Environmental
Protection
75 Grove Street
Worcester. MA 01605
(508) 792-7692
Western
Roberta Ken
Dept. of Environmental
Protection
436 Dwlght Street
Springfield. MA 01103
(413)784-1100
New Hampshire John Le Febvre
Air Resources Division
Dept. of Environmental Services
64 N. Main St, Caller Box 2033
Concord. NH 03302-2033
(603) 271-1370
Rhode Island Damlen Houlihan
U.S. EPA
JFK Federal Building. Room
2313
Boston. MA 02203
(617) 565-3265
Vermont Damlen Houlihan
U.S. EPA
JFK Federal Building. Room
2313
Boston. MA 02203
(617) 565-3265
New Jersey Robert Fltzpatrick
U.S. EPA
Air and Waste Management
Division
26 Federal Plaza
New York. NY 10278
(212) 264-6770
New York Robert Fltzpatrick
U.S. EPA
Air and Waste Management
Division
26 Federal Plaza
New York. NY 10278
(212) 264-6770
Puerto Rico Commonwealth of Puerto Rico
Environmental Quality Board
P.O.Box 11785
Santurce, PR 00910
U.S. Virgin U.S. Virgin Islands Dept. of
Islands Conservation and Cultural
Affairs
P.O. Box 578
Charlotte Amalie, St. Thomas
U.S. Virgin Islands 00801
Region 3 State Contacts
REGION 3
Delaware New Castle County
Jim Walmer
Dept. of Natural Resources and
Environmental Control
715 Grantham Lane
Newcastle. DE 19720
(302) 323-4542
Kent or Sussex County
Dave Burke
Delaware Dept of Natural
Resources
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-4791
District of John Holmes
Columbia DC Dept of Consumer and
Regulatory Affairs
2100 Martin Luther King Avenue
S.E.
Washington, DC 20020
(202) 783-3181
13
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Region 3 State Contacts
Region 4 State Contacts
Maryland John McQuade
Air Management Administration
Maryland Dept. of the
Environment
2500 Broenlng Highway
Baltimore. MD 21224
(301) 631-3200
Pennsylvania Dean Van Orden
Division of Hazardous Air
Pollutants
Bureau of Air Quality Control
Dept. of Environmental
Resources
P.O. Box 2357
Harrlsburg. PA 17105-2357
(717) 787-9257
Allegheny County (Pittsburgh)
Fred Ebel
Bureau of Air Pollution Control
Allegheny County Health
Dept.301 39th Street
Pittsburgh, PA 15201
(412) 578-8133
Philadelphia
EdCTNeil
Air Management Services
Dept. of Public Health
500 South Broad Street
Philadelphia. PA 19146
(215) 875-5678
Virginia Charles King
Virginia Air Pollution Control
Board
9th Street Office Building.
Room 801
Richmond. VA 23219
(804) 786-6079
For Notification*
Virginia Dept. of Labor and
Industry
Division of Occupational Health
Enforcement
P.O. Box 12064
- Richmond. VA 23241
(804) 786-8009
West Virginia Paul Rader
West Virginia Air Pollution
Control Commission
1558 Washington Street, East
Charleston. WV 25311
(304) 348-4022
REGION 4
Alabama
Florida
Ludwig C. Hoffmann, III
Air Division
Alabama Dept. of Environmental
Management
1751 W.L. Dickinson Drive
Montgomery, AL 36109
(205) 271-7861
Jefferson County
Gerald Coker
Jefferson County Dept. of Health
P.O. Box 2648
Birmingham, AL 35202
Contact: Joe Wilson
(205) 930-1210
Huntsville
Charles Terrell
Natural Resources and
Environmental Management
Dept.
City of Huntsville
2033-C Airport Road
Huntsville, AL 35801
(205) 883-3645
EdPalagyl
Bureau of Air Regulation
Florida Dept. of Environmental
Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee. FL 32301
(904) 488-1344
Duval County
Pat Patterson
Div. of Bio-Environmental
Services
Duval County Dept. of Health,
Welfare, and Bio-
Environmental Sciences
421 West Church Street,
Suite 412
Jacksonville, FL 32202
(904) 630 3638
Hillsborough County
Sheila Luce
Hillsborough County
Environmental Protection
Commission
1410 North 21st Street
Tampa, FL 33605
(813) 272-5530
14
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Region 4 State Contacts
Georgia
Kentucky
Palm Beach County
Jim Hearn
Air Pollution Control
Palm Beach County Health Dept.
901 Evernla Street
West Palm Beach. FL 33402
(407) 355-3070
Broward County
BillHahne
Broward County Environmental
Quality Control Board
621 South Andrews
Fort Lauderdale, FL 33301
(305) 765-4441
Dade County
Frank Echanlque or Peter Basil
Dade County Dept. of
Environmental Resource
Management
Metro Government Ctr.,
Suite 1310
111 Northwest First Street
Miami. FL 33128
(305) 858-0601
Pinellas County
Eric Fehrmann
Division of Air Quality
Pinellas County Dept. of
Environmental Management
161OO Fairchild Drive
Building V102
Clearwater, FL 34622
(813) 530-6522
Marvin Bradford
Asbestos Licensing and
Certification Unit
Environmental Protection
Division
Georgia Dept. of Natural
Resources
156 Trinity Avenue, Suite 315
Atlanta. GA 30303
(404) 656-4999
Parker Moore
Division for Air Quality Control
Frankfort Office Park
18 Reilly Road
Frankfort. KY 40601
(502) 564-2150
Jefferson County
Jerry Schlatter
Jefferson County Air Pollution
Control District
850 Barrett Avenue
Louisville, KY 40204
(502) 625-6000
Mississippi
North Carolina
South Carolina
Jimmy Asblll
Office of Pollution Control
Mississippi Dept. of
Environmental Quality
P.O. Box 10385
Jackson. MS 39289-0385
(601) 961-5171
Pat Curran
Division of Environmental
Management
Asbestos Hazard Management
Branch P.O. Box 27687
Raleigh. NC 27611
(919) 733-0820
Mecklenburg County
Dan Hardin
Air Quality Section
Environmental Management
Division
Mecklenburg County Dept. of
Environmental Protection
1200 Blythe Boulevard
Charlotte. NC 28203
(704) 376-4603
Porsyth County
Robert Fulp. Director
Forsyth County Environmental
Affairs Dept.
537 North Spruce Street
Wlnston-Salem. NC 27101
Contact: Michael Hastings
(919) 727-8060
Western North Carolina
Ronald Boone, Director
Western North Carolina Regional
Air Pollution Control Agency
Buckingham County Courthouse
P.O. Box 7215
Ashevllle. NC 28801-3569
Contact: David Brigman
(704) 255-5655
Dick Sharpe
South Carolina Dept. of Health
and Environmental
Control
2600 Bull Street
Columbia. SC 29201
Contact: Jean Wheeler
(803) 734-4750
15
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Region 4 State Contacts
Region 5 State Contacts
Tennessee Robert Foster
Division of Air Pollution Control
Tennessee Dept. of Public Health
Customs House, 4th Floor
701 Broadway
Nashville. TN 37247-3101
Contact: Jackie Waynlck
(615) 741-3931
Chattanooga-Hamilton County
J. Wayne Cropp, Director
Chattanooga-Hamilton County
Air Pollution Control Bureau
3511 Rossvllle Boulevard
Chattanooga. TN 37404
Contact: Jim Weyler
(615) 867-4321
Memphis-Shelby County
Helen Keith, Manager
Air Pollution Control
Memphis-Shelby County Health
Dept.
814 Jefferson Avenue
Memphis, TN 38105
Contact: Jinneal Clark
(901) 576-7653
Nashville-Davidson County
Paul Bontrager, Director
Metropolitan Health Dept.
Pollution Control Division
Nashville-Davidson County
311 Twenty-Third Avenue. North
Nashville. TN 37203
Contact: Fred Hugglns
(615) 340-5653
Knoz County
Terry Harris. Director
Knox County Dept of Air
Pollution Control
400 Main Avenue
City/County Building. Room 459
Knoxvllle. TN 37902
Contact: Lynne Liddington
(615) 521-2488
REGION 5
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Otto Klein
Division of Air Pollution Control
Illinois Environmental Protection
Agency
P.O. Box 19276
Springfield, IL 62794-9276
(217) 785-1743
Frank Profit
Asbestos Section
Office of Air Management
Indiana Dept. of Environmental
Management
P.O. Box 6015
Indianapolis, IN 46206-6015
Contact: Deborah Dubenetzky
(317)232-8373
Keshav Singh
Air Quality Division
Michigan Dept. of Natural
Resources
P.O. Box 30028
Lansing, MI 48909
(517) 335-1588
David Crowell or Steve Giddlngs
Division of Air Quality
Minnesota Pollution Control
Agency
520 Lafayette Road
St. Paul. MN 55155
(612) 296-7653/296-7513
Tom Hadden
Division of Ah- Pollution Control
Ohio Environmental Protection
Agency
P.O. Box 1049
Columbus. OH 43266-0149
(614) 644-2270
Joe Brehm
Bureau of Air Management
Wisconsin Dept. of Natural
Resources
P.O. Box 7921
Madison. WI 53707
(608) 267-7541
16
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Region 6 State Contacts
REGION 6
Arkansas
Texas
Louisiana
New Mexico
Oklahoma
Arkansas Dept of Pollution
Control and Ecology
8001 National Drive. P.O. Box
9583
Little Rock, AR 72219
Contact: Jeff Purtle
(501) 562-7444
Asbestos Unit Coordinator
Louisiana Dept. of Environmental
Quality
P.O. Box 44096
Baton Rouge. LA 70804-4096
Contact: Chris Roberie
(504) 342-9056
Bernalillo County
Air Pollution Control Division
Environmental Health and
Energy Dept.
P.O. Box 1293
Albuquerque. NM 87103
Contact: Steve Walker
(505) 768-2637
Outside Bernalillo County
Air Quality Bureau
NM Environmental Improvement
Division
P.O. Box 968
Santa Fe. NM 87504-0968
Contact Bill Hargraves
(505) 827-OO62
Air Quality Service
Oklahoma State Dept of Health
P.O. Box 53551
Oklahoma City. OK 73152
Contact: Tom Hudson
(405) 271-5220
Oklahoma City-County
Air Quality Section
Oklahoma City-County Health
Dept
921 N.E. 23rd Street
Oklahoma City, OK 73105
Contact: Curt Goeller
(405) 427-8651
Tulsa City-County
Air Pollution Control Program
Tulsa City-County Health Dept.
4616 East 15th Street
Tulsa. OK 74112
Contacts: Ray Bishop or Grady
Baron
(918) 744-1000
Texas
Municipal
Offices
Director of Compliance Division
Texas Air Control Board
6330 Highway 290 East
Austin. TX 78723
Contact: Jeanne Philqulst
(512)451-5711
(Submit notifications to Texas
regional offices)
Dallas
Air Pollution Control Program
Environmental Health Division
Dept. of Health and Human
Services
320 E. Jefferson, LL-13
Dallas. TX 75203
Contacts: Gary Burlbaw or Roger
Jayroe
(214) 948-4435
El Paso
Air Pollution Control Program
El Paso City Health Dept.
222 South Campbell
El Paso, TX 79901
Contact: Jesus J. Reynoso
(915) 543-3646
Galveston County
Environmental Control Services
Galveston County Health District
P.O. Box 939
LaMarque.TX 77568
Contact: Karen Alexander
(409) 938-7221
Houston
Bureau of Air Quality Control
Houston City Health and Human
Services Dept.
7411 Park Place Blvd.
Houston. TX 77087
Acting Contact: Henry H.
Branham
(713) 640-4200
Fort Worth
Environmental Health Division
Fort Worth Public Health Dept.
1800 University Drive
Fort Worth. TX 76107
Contact: Gene Rattan
(817) 870-7281
Contact: Gerald Bearden
(817) 870-7289
17
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Region 6 State Contacts
Texas Air
Control Board
Regional
Offices
Region 1
Archer, Baylor, Brown,
Callahan, Childress, Clay,
Coleman, Comanche, Cottle,
Eastland, Fisher, Foard,
Hardeman. Haskell, Jack,
Jones, Kent, Knoz, Mitchell.
Montague, Nolan, Runnels,
Scurry, Shackelford. Stephens,
Stonewall, Taylor,
Throckmorton, Wichita,
Wilbarger and Young Counties
Winona Henry, Director
Commerce Plaza Office Building
1290 South Willis. Suite 205
Abilene, TX 79605
(915) 698-9674
Region 2
Armstrong, Bailey, Briscoe,
Carson, Castro, Cochran.
Colllngsworth, Crosby, Dallam,
Deaf Smith. Dickens, Donley,
Floyd, Garza, Gray, Hale, Hall,
Hansford, Hartley, HemphUl,
Hockley. Hutchinson, King,
Lamb, Lipscomb, Lynn,
Lubbock, Moore, Motley,
Ochiltree. Oldham. Farmer,
Potter. Randall, Roberts,
Sherman, Swisher, Terry,
Wheeler and Toakum Counties
Gerald Hudson. Director
Briereroft South #1
5302 South Avenue Q
Lubbock, TX 79412
(806) 744-0090
Region 3
Bastrop. Bell, Blanco, Bosque,
Brazos, Burleson, Burnet,
CaldweU, Coryell. Falls,
Fayette, Freestone, Grimes,
Hamilton, Hays, Hill.
Lampasas, Lee, Leon. Llano,
Limestone, Madison.
McClennan, Milam, Mills,
Robertson, Travis, Washington
and Williamson Counties
Eugene Fulton, Director
5OO Lake Air Drive. Suite 1
Waco, TX 76710-5887
(817) 772-9240
Region 4
Cameron. Hidalgo. Jim Hogg.
Starr, Webb, Willacy and Zapata
Counties
Robert Guzman, Director
Matz Building. Room 204
513 East Jackson
Harllngen. TX 78550
(512) 425-6010
Region 5
Aransas, Bee, Brooks, Calhoun,
Dewitt, Duval. Goliad, Jackson,
Jim Wells, Kennedy, Kleberg.
Lavaca, Live Oak, McMullen,
Nneces, Refugio, San Patricio,
and Victoria Counties
Tom Palmer. Director
1231 Agnes St.. Suite #103
Corpus Christ!, TX 78401
(512) 882-5828
Region 6
Andrews, Borden, Coke.
Concho, Crane. Crockett,
Dawson, Ector, Gaines,
Glasscock, Howard, Irion.
Loving, Martin, McCulloch,
Menard, Midland, Pecos,
Reagan, Reeves. San Saba,
Schleicher. Sterling, Sutton.
Terrell, Tom Green, Upton,
Ward, and Winkler Counties
Charley Sims, Director
1901 East 37th Street. Suite 101
Odessa, TX 79762
(915) 367-3871
Region 7
Austin, Brazoria, Chambers,
Colorado, Fort Bend, Galveston,
Harris. Liberty, Matagorda,
Montgomery. Walker, Waller,
and Wharton Counties
Herbert W. Williams. Jr.. Director
5555 West Loop. Suite 300
Bellalre.TX 77401
(713) 666-4964
Regions
Collin, Cooke, Dallas. Denton,
Ellis, Erath, Fannin, Grayson,
Hood, Hunt, Johnson,
Kaufman, Palo Pinto. Parker,
Rockwall, Somervell. Tarrant,
and Wise Counties
Melvln Lewis. Director
6421 Camp Bowie Blvd.. Suite
312
Fort Worth. TX 76116
(817) 732-5531
RegionO
Atascosa, Bandera. Bezar.
Comal, Dimmit, Edwards. Frio.
GUlespie, Gonzales, Guadelupe.
Karnes, Kendall, Kerr, Kimble.
Kinney. La Salle. Mason.
Maverick, Medina, Real,
Uvalde, Val Verde, Wilson, and
Zapata Counties
James Menke, Director
4335 Pledras West. Suite 101
San Antonio. TX 78228
(512) 734-7981
18
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Region 6 State Contacts
Region 10
Angelina, Hardin, Houston,
Jasper, Jefferson,
Nacogdoches, Newton, Orange.
Polk, Sabine, San Augustine,
San Jacinto. Shelby, Trinity,
and Tyler Counties
Vic Fair. Director
4605-B Concord Road
Beaumont, TX 77703
(409) 838-0397
Region 11
Brewster, Culbertson. El Paso,
Hndspeth, Jeff Davis, and
Presidio Counties
Manuel Agulrre. P.E.. Director
1200 Golden Key Circle, Suite
369
El Paso, TX 79925
(915) 591-8128
Region 12
Anderson, Bowie, Camp. Cass,
Cherokee. Delta, Franklin,
Gregg, Harrison, Henderson,
Hopkins, Lamar, Marion,
Morris. Panola. Rains, Red
River. Rusk, Smith, Titus,
Upshur, Van Zandt, Upshur and
Wood Counties
Richard Leard. P.E., Director
1304 South Vine Avenue
Tyler. TX 75701
(214) 595-2639
Region 7 State Contacts
Nebraska
REGION 7
Iowa
Kansas
Missouri
Kurt Eskew
Air and Toxic Division
U.S. EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7618
Gary Miller
Asbestos Control Program
Kansas Dept. of Health and
Environment
Forbes Field, Building 740
Topeka, KS 66620-0001
(913) 296-1550
MlkeTharpe
Chief of Enforcement
Air Pollution Control Program
Missouri Dept. of Natural
Resources
P.O. Box 176
Jefferson City, MO 65102
(314) 751-4817
Greene County-Springfield
Ron Boyer or Bryan Adams
Air Pollution Control
Health Unit
Greene County-City of Springfield
Health Dept.
227 East Chestnut Expressway
Springfield, MO 65802
(417) 864-1663
Kansas City
Paul Stableln or Jennifer Logan
Kansas City Air Quality Program
414 East Twelfth Street, 21st
Floor
Kansas City. MO 64106
(816) 274-2501
St. Louis
Ronald Stelnkamp
Division of Air Pollution Control
City Hall, Room 419
St. Louis, MO 63103
(314) 662-3334
St. Louis County
Dan Overton
St. Louis County Air Pollution
Branch
111 South Meramec Avenue
Clayton, MO 63105
(314) 854-6912
Nebraska Dept. of Environmental
Control
P.O. Box 94877
State House Station
Lincoln, NE 68509
(402) 471-2186
Jacqueline Fiedler
Division of Asbestos Control
Nebraska Dept. of Health
301 Centennial Mall South
P.O. Box 94877
Lincoln. NE 68509-5007
(402) 471-2541
Lincoln-Lancaster County
Gary Walsh
Air Pollution Control Section
Division of Environmental Health
Lincoln-Lancaster County Health
Dept.
2200 St Marys Avenue
Lincoln. NE 68502
(402) 471-8039
Omaha
Chester Black
Air Quality Control Division
5600 South 10th Street
Omaha, NE 68107
(402) 444-6015
19
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Region 8 State Contacts
Region 9 State Contacts
REGION 8
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Alan Savllle or Steve Fine
Compliance Monitoring and
Enforcement Section
Air Pollution Control Division
Stationary Sources Program
Colorado Dept. of Health
4210 East llth Avenue
Denver, CO 80220
(303) 331-8509
Denver
Jack Bendixon
Denver Dept. of Health and
Hospitals
605 Bannock
Denver, CO 80204
(303) 893-6243
Warren Norton
Air Quality Bureau
Dept. of Health and
Environmental Sciences
Cogswell Building
Helena. MT 59620
(406) 444-3454
Ken Wangler
State Dept. of Health and
Consolidated Laboratories
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
(701) 224-2348
Office of Air Quality and Solid
Waste
Division of Water and Natural
Resources
Joe Foss Building
Pierre. SD 57501
(605) 773-3153
Kent Bott
Bureau of Air Quality
Dept. of Health
P.O. Box 16690
Salt Lake City, UT 84116-0690
(801) 538-6108
Salt Lake City County
Donald K. Horsley
Salt Lake City County Health
Dept
610 South 200 East
Salt Lake City. UT 84111
(801) 534-4516
F. Gerald Blackwell
Air Quality Division
Dept. of Environmental Quality
122 West 25th Street
Cheyenne. WY 82002
(307) 777-7391
REGION 9
Arizona
California
Wayne Hunt
Office of Air Quality
Arizona Dept. of Environmental
Quality
2005 North Central Avenue
Room 603C
Phoenix, AZ 85004
(602) 257-2276
Pima County
John Bartlett
Plma County AQCD
150 West Congress Street
Tucson, AZ 85701
Maricopa County
Stephen Olson
Maricopa County APCD
P.O. Box 2111
Phoenix, AZ 85001
(602) 258-6381 x506
California Air Resources Board
1101 "R" Street
Sacramento, CA 95812
Contact: Francis Mateo
(916) 322-3976
For Information:
Charles Kersey
GARB Compliance Division
P.O. Box 2815
Sacramento. CA 95812
(916) 322-8272
Alameda. Contra Costa, Marin,
Napa. San Francisco, San
Mateo, Santa Clara, South
Sonoma and South Solano
Counties
Public Information
Bay Area AQMD
939 Ellis Street
San Francisco, CA 94109
(415)771-6000x210
Fresno County
Bob Bashian
Fresno County APCD
P.O. Box 11867
Fresno. CA 93775
(209) 445-3239
Hnmboldt. Del Norte. Trinity
Counties
Leonard Hen-
North Coast Unified AQMD
5630 South Broadway
Eureka. CA 95501
(707) 443-3093
20
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Region 9 State Contacts
Kern County
Jon Adams
Kcm County APCD
2700 "M" Street. Suite 275
Bakersfleld, CA 93301
(805) 861-3682
King* County
Mark Polndexter or Chuck Hanna
Kings County APCD
330 Campus Drive
Hanford, CA 93230
(209)584-1411
Lake County
John Thompson
Lake County AQMD
883 Lakeport Blvd.
Lakeport. CA 95453
(707) 263-7000
Los Angeles, Orange. Riverside.
and San Bernardino (except
Desert
Portion) Counties
Paul Aunchman
South Coast AQMD
9150 Flair Drive
El Monte. CA 91731
(818) 572-6195
Maderm County
BillSturk
Madera County APCD
135 West Yosemlte Avenue
Madera. CA 93637
(209) 675-7823/24/25
Mendocino County
Philip Towle
Mendodno County APCD
Courthouse
Uklah, CA 95482
(707) 463-4354/5458
Merced County
John Lathrop
Roland Brooks. Asst APCO
Environmental Health
Merced County APCD
385 East Thirteenth Street
Merced. CA 95340
(209) 385-7391
Modoc County
Clinton B. Greenbank
Modoc County APCD
202 West Fourth Street
Alturas. CA 96101
(916) 233-3939 x401
Mono. Inyo, and Alpine
Counties
Larry Cameron or Duane Ono
Great Basin Unified APCD
157 Short Street
Bishop. CA 93514
(619)872-8211
Monterey County
EdKendlg
Monterey Bay Unified APCD
1164 Monroe Street. Suite 10
Salinas, CA 93906-3596
(408)443-1135
Northern Sonoma County
George Erdman
Northern Sonoma County APCD
109 North Street
Healdsburg, CA 95448
(707)433-5911
Sacramento County
Asbestos Coordinator
Sacramento Metropolitan AQMD
8475 Jackson Road, Suite 215
Sacramento, CA 95826
(916) 386-6650
San Bernardino County
(Desert Portion)
Richard Wales or Steve Jenkins
San Bernardino County APCD
15428 Civic Drive. Suite 200
Victorville. CA 92392
(619) 243-8200
San Diego County
Jimmy Cooksey
San Diego County APCD
9150 Chesapeake Drive
San Diego. CA 92123
(619) 694-3340
San Joaquin County
San Joaquin County APCD
P.O. Box 2009
Stockton, CA 95201
ATTN: Lakhmlr Grewal
APCD Director
(209) 468-3400
Contact: Jim Czarneckl
(209) 468-3476
Ban Luis Obispo County
San Luis Oblspo County APCD
2156 Sierra Way. Suite B
San Luis Oblspo. CA 93401
(805) 549-5912
Santa Barbara County
George F. Use. n
Santa Barbara County APCD
240 East Highway 246. Suite 207
Buellton, CA 93427
(805) 686-5012
21
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Region 9 State Contacts
Region 10 State Contacts
awaii
svada
Stanislaus County
Mark Macedo
Stanislaus County APCD
1716 Morgan Road
Modesto, CA 95351
(209) 525-4152
Tulare County
Joel Martins
Environmental Health Division
Tulare County APCD
Health Building
County Civic Center
Vlsalla. CA 93291
(209) 733-6441
Ventura County
Jay Nicholas
Ventura County APCD
800 South Victoria Avenue
Ventura, CA 93009
(805) 654-5031
Yolo and Northern Solano
Counties
Bill Schuldt
Yolo-Solano County APCD
P.O. Box 1006
Woodland. CA 95695
(916) 666-8146/47
Ken Hall
Clean Air Branch
Hawaii Dept of Health
P.O. Box 3378
2611 Kllihau Street
Honolulu. HI 96801
(808) 543-8200
Washoe County
Brian Wright
Environmental Health/Air
Quality
Washoe County District Health
Dept
P.O.Box 11130
1001 East Ninth Street
Reno, NV 89520
(702) 328-2620
Clark County
Harold Glasser
Air Pollution Control Division
Clark County Health District
P.O. Box 4426
Las Vegas. NV 89127
(702) 383-1276
REGION 10
Alaska
Idaho
Oregon
For Notification
Tom Wilson
Alaska Operations Office
U.S. EPA
Room 537, Federal Building
222 W. 7th Ave. #19
Anchorage, AK 99513-7588
(907) 271-5083
For Disposal
Alaska Dept. of Environmental
Conservation
3601 C Street, Suite 1350
Anchorage, AK 99503
(907) 563-6529
Tim Trumbull
U.S. EPA
422 W. Washington Street
Boise, ID 83702
(208) 334-1626
Sara Armltage
State Asbestos Program
Oregon Dept. of Environmental
Quality
811 S.W. 6th Avenue
Portland, OR 97204
(503) 229-5186
Lane County
Tom Freeman
Lane Regional Air Pollution
Control Authority (LRAPA)
225 North 5th Street. Suite 501
Springfield. OR 97477
(503) 726-2514
22
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Region 10 State Contacts
Washington Ken Fukutoml
Washington Dept. of Ecology
4350 150th Avenue NE
Redmond. WA 98502
(206) 867-7107
Tri-Connties
J. Phillip Cooke
Trl-Countles Air Pollution Control
Authority
650 George Washington Way
Rlchland, WA 99352
(509) 946-4489
Northwest
Terry Nyman
Northwest Air Pollution Authority
302 Pine Street, Suite 207
Mount Vemon, WA 98273
(206) 428-1617
Olympic
Chuck Peace
Olympic Air Pollution Control
Authority
120 East State Avenue
Olympia. WA 98103
(206) 586-0593 xlOO
Puget Sound
Joe Eng
Puget Sound Air Pollution
Control Agency
200 West Mercer Street, Room
205
Seattle, WA 98119-3958
(206) 296-7335
Sonthwect
Richard Serdoz
Southwest Air Pollution Control
Authority
1308 N.E. 134th St.. Suite D
Vancouver. WA 98685-2747
(206) 574-3058
(800) 633-0709
Spokane
Ron Edgar
Spokane County Air Pollution
Control Authority
W. 1101 College Avenue.
Room 230
Spokane, WA 99201
(509) 456-4727 x!05
Takima County
Yakima County Clean Air
Authority
County Courthouse
Yakiina, WA 98901
(509) 575-4116
23
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State Index
Page
Alabama 14
Alaska 22
Arizona 20
Arkansas 17
California 20
Colorado 20
Connecticut 13
Delaware 13
District of Columbia 13
Florida 14
Georgia 15
Hawaii 22
Idaho 22
Illinois 16
Indiana 16
Iowa 19
Kansas 19
Kentucky 15
Louisiana 17
Maine 13
Maryland 14
Massachusetts 13
Michigan 16
Minnesota 16
Mississippi 15
Missouri 19
Montana 20
Nebraska 19
Nevada 22
New Hampshire 13
Page
New Jersey 13
New Mexico 17
New York 13
North Carolina 15
North Dakota 20
Ohio 16
Oklahoma 17
Oregon 22
Pennsylvania 14
Puerto Rico 13
Rhode Island 13
South Carolina 15
South Dakota 20
Tennessee 16
Texas 17
Utah 20
Vermont 13
U.S. Virgin Islands 13
Virginia 14
Washington 23
West Virginia 14
Wisconsin 16
Wyoming 20
24
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Item 5 - Common Questions On The Asbestos NESHAP
-------
NESHAP
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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
-------
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.
-------
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 dean Air Act (CAA) requires the U. S. Environmental Protection Agency (EPA) to
develop and enforce regulations to protect die 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 minimising the release of
asbestos fibers during activities involving the processing, handling, and disposal of
asbestos-containing material. Accordingly, die 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 die building
and/or die 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 die Asbestos NESHAP or for answers to questions not
covered in this pamphlet, contact die delegated State or local agency or die
appropriate EPA Regional Office listed on page 24.
December 1990
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Asbestos NESHAP Questions
General What Is the purpose of the Asbestos NESHAP regulation?
Information
The purpose is to protect the public health by minimizing 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, die Asbestos NESHAP does specify
zero visible emissions to the outside air from activity relating to the transport and
disposal of asbestos waste.
December 1990
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Asbestos Nr£:->J I" _:.
Who is responsible tor enforcing the Asbestos NES-A^ e'.sr.CL-cc?
Under Section 112 of the dean 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.
As of October 1990, approximately 45 states.
V .: i; r ': .
As defined in the regulation, a "facility" 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 mat 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 severe! two-family units, are the units defined es e f sclllty?'
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
(RACM) 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.
December 1990
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Asbestos NESHAP Quesaons
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 stili regulated by the Asbestos
NESKAP?
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.
December 1990
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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 tne 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 tor 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
parries decide together who will notify. If neither provide adequate notice, EPA can
hold either or both parties liable.
December 1990
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Asbestos NESHAP Ouecacns
When a condominium complex Is being renovated, who as owner, Is
responsible for submitting e 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 e forrr. or forms* 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 fesllltlss In which no asbestos Is present require
nctlflcstlon?
Yes. All demolitions that meet the definition of facility must notify.
When I notify regarding a renovation, what date do I consider the start
date?
For a renovation, the start date is die 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 I 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 die removal or die demolition, if no removal is
required. The waiting period is necessary to give inspectors time to visit the site
before activity begins.
December 1990
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Asbestos NESHAP Questions
Does the 10-day notification requirement refer to calendar' days or
working* 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-scheduied 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 Question;
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 die change relates to the amount of RACM involved, you need
only revise die notification if die 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 die revision is
necessary, and should dien mail or hand deliver a written notice. If you delay die
start date of a project, EPA must receive die revised notification no later than die
original start date. If you plan to begin work before die date specified in die original
notice, EPA must receive die revised notice at least 10 working days before die
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 die facility is planned which would disturb die ACM
and it exceeds die direshold amount.
December 1990
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Asbestos NESKAP Questions
What does 'adequately wef 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 bcticm 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)(lll) states that the operator must transport the
materials to the ground via dust tight chutes or containers If It has been
removed or stripped mora 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 !s being
ci'srec undsr 5n or;sr of 3 St^-a cr :.zz^.:
, do all ihs 'err:-' -~':'~-.-^, rcvc-r^'j -v^c-.^r ^ ^p
No. The regulations which do apply are specified in §61.145 (a) (3) of die
regulation.
If a facility Is being demc;Ljr2
-------
Ar:>es:oc Ni^KA? v'-'_:'J.;.i'
All contaminated debris which cannot be segregated and cleaned should be disposed
of as asbestos waste.
Friable LT:C
NorvFricMe
Asbestos
What Is tri£b!e
lr.ins meterial?
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.
YVrtst !s non-triLbie ACKv
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-friable 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 die 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
December 1990
11
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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.
December 1990
12
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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 the 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?
December 1990
13
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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.
December 1990
14
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Asoestos Nr.SH.AP 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 dean Air Act to inspect any facility and
die 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.
December 1990
15
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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.
December 1990
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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
Penalttes
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.
December 1990
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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.
December 1990
18
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Asbestos NESHA? C^c:i::_-
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.
Yes. NARS information is available through EPA Regional Offices under the
provisions of the Freedom of Information ACL
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.
December 1990
19
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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.
December 1990
20
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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 (RAC). The addresses and
phone numbers of both the RAC 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 NVLAP at (301)975-4016.
December 1990
21
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Glossary of Terms
Glossary of Terms
AHERA
CAA
CERCLA
EPA
EHSD
Friable Asbestos
Material
Glovebag
NARS
NESHAP
NIOSH
NIST
NVLAP
OSHA
Paniculate
Asbestos
Material
RACM
The Asbestos Hazard Emergency Response Act, passed by Congress in 1986
dean 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 Tide 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
December 1990
22
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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 nonfriable ACM that has a high probability of becoming or has
become crumbled, pulverized, or reduced to powder by die forces expected to act on
the material in the course of demolition or renovation operations regulated by the
Asbestos NESHAP.
RCRA Resource Conservation and Recovery Act
TSCA 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.
December 1990
23
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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
IL, 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
December 1990
24
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AHERA and NESHAP Coordinators
AHERA and NESHAP Coordinators
Region
NESHAP
AHERA
Region 6
AR, LA, NM
OK.TX
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Div.
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7233
Regional Asbestos Coordinator
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7244
Region 7
IA, KS
MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7618
Regional Asbestos Coordinator
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7020
Region 8
CO, MT, ND
SD, UT, WY
Asbestos NESHAP Coordinator
Air & Waste Management Div.
US EPA
One Denver Place
999 18lh Street
Suite 500
Denver, CO 80202-2405
(303) 294-7685
Regional Asbestos Coordinator
US EPA
One- Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1442
Region 9
AS, CA, HI,
NV, AZ, GU,
TT
Asbestos NESHAP Coordinator
Air Management Division
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1135
Regional Asbestos Coordinator
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1128
Region 10
AK, ID
OR, WA
Asbestos NESHAP Coordinator
Air & Toxics Management Div.
US EPA
1200 6th Avenue
Seattle, WA 98101
(206) 442-1757
Regional Asbestos Coordinator
US EPA
1200 6lh Avenue
Seattle, WA 98101
(206) 442-4762
December 1990
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Item 6 - The Asbestos Informer
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EPA 340/1-90-020
The Asbestos Informer
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
December, 1990
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What Is
asbestos?
Asbestos is a mineral. It is mined in much
the same way that other minerals, such as
iron, lead, and copper, are. Asbestos is com-
posed of silicon, oxygen, hydrogen, and
various metal cations (positively charged
metal ions).
There are many varieties of asbestos: the
three most common are chrysotile, amosite,
and crocidolite. Chrysotile fibers are pliable
and cylindrical, and often arranged in
bundles. Amosite and crocidolite fibers are
like tiny needles.
The first commercial asbestos mine - a
chrysotile mine - opened in Quebec,
Canada, in the 1870's. Crocidolite asbestos
was first mined in South Africa during the
1980's. Amosite asbestos also comes from
Africa and was first mined in 1916.
Unlike most minerals, which turn into dust
particles when crushed, asbestos breaks up
into fine fibers that are too small to be seen
by the human eye. Often individual fibers
are mixed with a material that binds them
together, producing asbestos containing
material (ACM).
Why has
asbestos been
so widely
used?
Asbestos appealed to manufacturers and
builders for a variety of reasons. It is strong
yet flexible, and it will not burn. It
conducts electricity poorly, but insulates
effectively. It also resists corrosion.
Asbestos may have been so widely used
because few other available substances
combine the same qualities.
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How many
products
contain
asbestos?
How long has
asbestos been
In use?
One study estimated that 3,000 different
types of commercial products contained
asbestos. The amount of asbestos in each
product varied from as little as one percent
to as much as 100 percent. Many older
plastics, paper products, brake linings, floor
tiles and textile products contain asbestos, as
do many heavy industrial products such as
sealants, cement pipe, cement sheets, and
insulation.
The final Asbestos Ban and Phaseout Rule
prohibits the manufacture, processing and
importation of most asbestos products.
Asbestos was first used in the United States
in the early 1900's, to insulate steam
engines. But until the early 1940's, asbestos
was not used extensively. However, after
World War II, and for the next thirty years,
people who constructed and renovated
schools and other public buildings used
asbestos and asbestos -containing materials
(ACM) extensively. They used ACM pri-
marily to fireproof, insulate, soundproof,
and decorate. The Environmental
Protection Agency (EPA) estimates that there
are asbestos containing materials in most of
the nation's approximately 107,000 primary
and secondary schools and 733,000 public
and commercial buildings.
How are people
exposed to
asbestos?
When asbestos fibers are in the air, people
may inhale them. Because asbestos fibers
are small and light, they can stay in the air
for a long time.
-------
People whose work brings them into contact
with asbestos - workers who renovate
buildings with asbestos in them, for
example - may inhale fibers that are in the
air: this is called occupational exposure.
Workers' families may inhale asbestos fibers
released by clothes that have been in contact
with ACM: this is called paraoccupational
exposure. People who live or work near
asbestos- related operations may inhale
asbestos fibers that have been released into
the air by the operations: this is called
neighborhood exposure.
The amount of asbestos a worker is exposed
to will vary according to
The concentration of fibers
in the air
Duration of exposure
The worker's breathing rate (workers
doing manual labor breathe faster)
Weather conditions
The protective devices the worker wears
It is estimated that between 1940 and 1980,
27 million Americans had significant
occupational exposure to asbestos.
People may also ingest asbestos if they eat
in areas where there are asbestos fibers in
the air.
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When is ACM
most likely to
release
asbestos
fibers?
Damaged ACM is more likely to release
fibers than non-damaged ACM. In a 1984
survey, EPA found that approximately 66
percent of those buildings that contained
asbestos contained damaged ACM.
If ACM, when dry, can be crumbled by hand
pressure - a condition known as "friable" - it
is more likely to release fibers than if it is
"non-friable." Fluffy, spray-applied asbestos
fireproof ing material is generally considered
"friable." Some materials which are con-
sidered "non-friable," such as vinyl-asbestos
floor tile, can also release fibers when
sanded, sawed or otherwise aggressively dis-
turbed. Materials such as asbestos cement
pipe can release asbestos fibers if broken or
crushed when buildings are demolished,
renovated or repaired.
ACM which is in a heavy traffic area, and
which is therefore often disturbed, is more
likely to release fibers than ACM in a
relatively undisturbed area.
How can
asbestos be
identified?
While it is often possible to "suspect" that a
material or product is/or contains asbestos
by visual determination, actual
determinations can only be made by
instrumental analysis. Until a product is
tested, it is best to assume that the product
contains asbestos, unless the label, or the
manufacturer verifies that it does not.
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Does asbestos
exposure cause
health
problems?
The EPA requires that the asbestos content
of suspect materials be determined by
collecting bulk samples and analyzing them
by polarized light microscopy (PLM). The
PLM technique determines both the percent
and type of asbestos in the bulk material.
EPA Regional Offices can provide
information about laboratories that test for
asbestos.
Some people exposed to asbestos develop
asbestos-related health problems; some do
not. Once inhaled, asbestos fibers can easily
penetrate body tissues. They may be
deposited and retained in the airways and
lung tissue. Because asbestos fibers remain
in the body, each exposure increases the
likelihood of developing an asbestos-related
disease. Asbestos related diseases may not
appear until years after exposure. Today we
are seeing results of exposure among
asbestos workers during World War II. A
medical examination which includes a
medical history, breathing capacity test and
chest x-ray may detect problems early.
Scientists have not been able to develop a
"safe" or threshold level for exposure to
airborne asbestos. Ingesting asbestos may
be harmful, but the consequences of this
type of exposure have not been clearly
documented. Nor have the effects of skin
exposure to asbestos been documented.
People who touch asbestos may get a rash
similar to the rash caused by fiberglass.
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What Illnesses
are associated
with asbestos
exposure?
Asbestosls
Asbestosis is a serious, chronic, non-
cancerous respiratory disease. Inhaled
asbestos fibers aggravate lung tissues, which
causes them to scar. Symptoms of asbestosis
include shortness of breath and a dry
crackling sound in the lungs while inhaling.
In its advanced stages, the disease may
cause cardiac failure. There is no effective
treatment for asbestosis; the disease is
usually disabling or fatal. The risk of
asbestosis is minimal for those who do not
work with asbestos; the disease is rarely
caused by neighborhood or family exposure.
Those who renovate or demolish buildings
that contain asbestos may be at significant
risk, depending on the nature of the
exposure and precautions taken.
Lung Cancer
Lung cancer causes the largest number of
deaths related to asbestos exposure. The
incidence of lung cancer in people who are
directly involved in the mining, milling,
manufacturing and use of asbestos and its
products is much higher than in the general
population. The most common symptoms
of lung cancer are coughing and a change in
breathing. Other symptoms include
shortness of breath, persistent chest pains,
hoarseness, and anemia.
People who have been exposed to asbestos
and are also exposed to some other
carcinogen - such as cigarette smoke - have
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a significantly greater risk of developing
lung cancer than people who have only
been exposed to asbestos. One study found
that asbestos workers who smoke are about
90 times more likely to develop lung cancer
than people who neither smoke nor have
been exposed to asbestos.
Mesothelioma
Mesothelioma is a rare form of cancer
which most often occurs in the thin
membrane lining of the lungs, chest,
abdomen, and (rarely) heart. About 200
cases are diagnosed each year in the United
States. Virtually all cases of mesothelioma
are linked with asbestos exposure. Approxi-
mately 2 percent of all miners and textile
workers who work with asbestos, and 10
percent of all workers who were involved in
the manufacture of asbestos-containing gas
masks, contract mesothelioma.
People who work in asbestos mines,
asbestos mills and factories, and shipyards
that use asbestos, as well as people who
manufacture and install asbestos insulation,
have an increased risk of mesothelioma. So
do people who live with asbestos workers,
near asbestos mining areas, near asbestos
product factories or near shipyards where
use of asbestos has produced large
quantities of airborne asbestos fibers.
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The younger people are when they inhale
asbestos, the more likely they are to develop
mesothelioma. This is why enormous
efforts are being made to prevent school
children from being exposed.
Other Cancers
Evidence suggests that cancers in the
esophagus, larynx, oral cavity, stomach,
colon and kidney may be caused by
ingesting asbestos. For more information
on asbestos-related cancers, contact your
local chapter of the American Cancer
Society.
Who regulates The U.S. Environmental Protection Agency
asbestos? an<^ me Occupational Safety and Health
Administration (OSHA) are responsible for
regulating environmental exposure and
protecting workers from asbestos exposure.
OSHA is responsible for the health and
safety of workers who may be exposed to
asbestos in the workplace, or in connection
with their jobs. EPA is responsible for
developing and enforcing regulations
necessary to protect the general public from
exposure to airborne contaminants that are
known to be hazardous to human health.
The EPA's Worker Protection Rule (40 CFR
Part 763, Subpart G) extends the OSHA
standards to state and local employees who
perform asbestos work and who are not
covered by the OSHA Asbestos Standards, or
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What Is EPA's
position about
asbestos In
buildings and
what to do
about It?
by a state OSHA plan. The Rule parallels
OSHA requirements and covers medical
examinations, air monitoring and reporting,
protective equipment, work practices, and
recordkeeping.
In addition, many State and local agencies
have more stringent standards than those
required by the Federal government. People
who plan to renovate or remove asbestos
from a building of a certain size, or who
plan to demolish any building, are required
to notify the appropriate federal, state and
local agencies, and to follow all federal,
state, and local requirements for removal
and disposal of regulated asbestos-
containing material (RACM).
EPA's advice on asbestos is neither to rip it
all out in a panic nor to ignore the problem
under a false presumption that asbestos is
"risk free." Rather, EPA recommends a
practical approach that protects public
health by emphasizing that asbestos
material in buildings should be located, that
it should be appropriately managed, and
that those workers who may disturb it
should be properly trained and protected.
That has been, and continues to be, EPA's
position. The following summarizes the five
major facts that the Agency has presented in
congressional testimony:
FACT ONE:
Although asbestos is hazardous, human risk
of asbestos disease depends upon exposure.
FACT TWO:
Prevailing asbestos levels in buildings - the
levels school children and you and I face as
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building occupants - seem to be very low,
based upon available data. Accordingly, the
health risk we face as building occupants
also appears to be very low.
FACT THREE:
Removal is often not a school district's or
other building owner's best course of action
to reduce asbestos exposure. In fact, an
improper removal can create a dangerous
situation where none previously existed.
FACT FOUR:
EPA only requires asbestos removal in order
to prevent significant public exposure to
asbestos, such as during building renovation
or demolition.
FACT FIVE:
EPA does recommend in-place management
whenever asbestos is discovered. Instead of
removal, a conscientious in-place
management program will usually control
fiber releases, particularly when the
materials are not significantly damaged and
are not likely to be disturbed.
What are EPA's
regulations
governing
asbestos?
10
TSCA
In 1979, under the Toxic Substances Control
Act (TSCA), EPA began an asbestos technical
assistance program for building owners,
environmental groups, contractors and
industry. In May 1982, EPA issued the first
regulation intended to control asbestos in
schools under the authority of TSCA; this
regulation was known as the Asbestos-in-
Schools Rule. Starting in 1985, loans and
grants have been given each year to aid
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Local Education Agencies (LEAs) in
conducting asbestos abatement projects
under the Asbestos School Hazard
Abatement Act (ASHAA).
AHERA
In 1986. the Asbestos Hazard Emergency
Response Act (AHERA; Asbestos Containing
Materials in Schools, 40 CFR Part 763,
Subpart E) was signed into law as Title II of
TSCA. AHERA is more inclusive than the
May 1982 Asbestos-in-Schools Rule. AHERA
requires LEAs to inspect their schools for
asbestos containing building materials
(ACBM) and prepare management plans
which recommend the best way to reduce
the asbestos hazard. Options include
repairing damaged ACM, spraying it with
sealants, enclosing it, removing it, or
keeping it in good condition so that it does
not release fibers. The plans must be
developed by accredited management
planners and approved by the State. LEAs
must notify parent, teacher and employer
organizations of the plans, and then the
plans must be implemented.
AHERA also requires accreditation of
abatement designers, contractor supervisors
and workers, building inspectors, and school
management plan writers. Those
responsible for enforcing AHERA have
concentrated on educating LEAs, in an effort
to ensure that they comply with the
regulations. Contractors that improperly
remove asbestos from schools can be liable
under both AHERA and NESHAP. For more
information on AHERA, request the
pamphlet entitled "The ABC's of Asbestos in
Schools" from the EPA Public Information
Center.
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ASBESTOS BAN & PHASEOUT RULE
In 1989 EPA published the Asbestos:
Manufacture, Importation, Processing, and
Distribution in Commerce Prohibitions; Final
Rule (40 CFR Part 763, Subpart I). The rule will
eventually ban about 94 percent of the asbestos
used in the U.S. (based on 1985 estimates). For
example, asbestos containing drum brake linings
and roof coatings will be banned. The rule will
be implemented in three stages between 1990
and 1997.
NESHAP
The Clean Air Act (CAA) of 1970 requires
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 Emission Standards for
Hazardous Air Pollutants (NESHAP).
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 promulgated the Asbestos NESHAP in
40 CFR Part 61, Subpart M. The Asbestos
NESHAP has been amended several times,
most recently in November 1990. For a
copy of the Asbestos NESHAP contact the
Asbestos NESHAP Coordinators listed in the
Appendix.
What are the
basic
requirements
of the Asbestos
NESHAP?
The Asbestos NESHAP is intended to
minimize the release of asbestos fibers
during activities involving the handling of
asbestos. Accordingly, it specifies work
practices to be followed during renovations
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of buildings which contain a certain
threshold amount of friable asbestos, and
during demolitions of all structures,
installations, and facilities (except apartment
buildings that have no more than four
dwelling units). Most often, the Asbestos
NESHAP requires action to be taken by the
person who owns, leases, operates, controls,
or supervises the facility being demolished
or renovated (the "owner"), and by the
person who owns, leases, operators, controls
or supervises the demolition or renovation
(the "operator").
The regulations require owners and
operators subject to the Asbestos NESHAP to
notify delegated State and local agencies
and/or their EPA Regional Offices before
demolition or renovation activity begins.
The regulations restrict the use of spray
asbestos, and prohibit the use of wet applied
and molded insulation (i.e., pipe lagging).
The Asbestos NESHAP also regulates
asbestos waste handling and disposal.
Why was the
Asbestos
NESHAP
recently
amended?
The Asbestos NESHAP was amended for
several reasons. EPA wanted to clarify
existing regulatory policies, and to add
regulations which explicitly address
monitoring and recordkeeping at facilities
which mill, manufacture, and fabricate
asbestos. Also, because of the high risk
associated with the transfer and disposal of
ACM, EPA also wanted to strengthen the
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What sources
are now
covered by the
asbestos
NESHAP?
requirements which govern asbestos waste
disposal by requiring tracking and
recordkeeping. Furthermore, EPA
determined that the Asbestos NESHAP
needed to take into account the availability
of improved emission controls. EPA also
wanted to make the NESHAP consistent
with other EPA statutes that regulate
asbestos.
The following activities and facilities are
currently regulated by the Asbestos
NESHAP:
The milling of asbestos.
Roadways containing ACM.
The commercial manufacture of products
that contain commercial asbestos.
The demolition of all facilities.
The renovation of facilities that contain
friable ACM.
The spraying of ACM.
The processing (fabricating) of any
manufactured products that contain
asbestos.
The use of insulating materials that
contain commercial asbestos.
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What were the
major
changes to the
Asbestos
NESHAP?
The disposal of asbestos-containing waste
generated during milling, manufacturing,
demolition, renovation, spraying, and
fabricating operation
The closure and maintenance of inactive
waste disposal sites.
The operation of and reporting on
facilities that convert asbestos containing
waste material into nonasbestos material.
The design and operation of air cleaning
devices.
The reporting of information pertaining
to process control equipment, filter
devices, asbestos generating processes,
etc.
Active waste disposal sites.
Milling, Manufacturing, and Fabricating Sources
Businesses which are involved in asbestos
milling, manufacturing, and fabricating now
must monitor for visible emissions for at
least 15 seconds at least once a day (during
daylight hours), and inspect air cleaning
devices at least once a week. The facilities
must maintain records of the results, and
submit each quarter a copy of the visible
emissions monitoring records if visible
emissions occurred during the quarter.
Facilities that install fabric filters (to control
asbestos emissions) after the effective date
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of the revision must provide for easy
inspection of the bags.
Demolition and Renovation
All facilities which are "demolished" are
subject to the Asbestos NESHAP. The
definition of demolition was expanded to
include the intentional burning of a facility,
in addition to the "wrecking or taking
out . . . any load-supporting structural
member of a facility."
Owners and operators of all facilities which
are to be demolished, and of facilities that
contain a certain amount of asbestos which
are to be renovated, must now provide more
detailed information in notifications,
including the name of the asbestos waste
transporter and the name of the waste
disposal site where the ACM will be
deposited. Owners and operators must give
a 10-day notice for planned renovations and
demolitions. They must renotify EPA in
advance of the actual start date if the
demolition or renovation will begin on a
date other than the one specified in the
original notification. Telephone re-
notifications are permitted, but must be
followed by written notice.
Starting one year after promulgation of the
regulation, a person trained in the
provisions of the Asbestos NESHAP, and in
the methods of complying with them, must
supervise operations in which ACM is
stripped, removed or otherwise handled.
This supervisor is responsible for all on-site
activity.
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Before wetting is suspended, the EPA
administrator must approve. When wetting
of asbestos during its removal is suspended
due to freezing temperatures, owners or
operators must measure the air temperature
in the work area three times during the
workday, and must keep those records for at
least two years.
The revisions also clarify EPA's position
regarding the handling and treatment of
non-friable asbestos material. The owner
and operator must inspect the site for the
presence of non-friable ACM, and include in
the notification an estimate of how much
non-friable ACM is present. Also, the owner
and operator must describe the procedures
to be followed if unexpected ACM is found
in the course of demolition or renovation,
and if non-friable asbestos becomes friable
in the course of renovation or demolition.
Waste Transport end Disposal
Vehicles used to transport ACM must be
marked according to new guidelines during
loading and unloading. Labels indicating
the name of the waste generator and the
location where the waste was generated
must be placed on containers of RACM.
When ACM waste is transported off-site, a
waste shipment record (WSR) must be given
to the waste site operator or owner at the
time that the waste is delivered to the waste
disposal site. The owner or operator must
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send a signed copy of the WSR back to the
waste generator within 30 days, and attempt
to reconcile any discrepancy between the
quantity of waste given on the WSR and the
actual amount of waste received. If, within
15 days of receiving the waste, the waste site
owner or operator cannot reconcile the
discrepancy, he or she must report that
problem to the same agency that was
notified about the demolition or renovation.
New disposal sites must apply for approval
to construct, and must notify EPA of the
startup date. Existing disposal sites must
supply EPA with certain information
concerning their operations, such as the
name and address of the owner or operator,
the location of the site, the average weight
per month of the hazardous materials being
processed, and a description of the existing
emission control equipment.
If a copy of the WSR signed by the waste
site owner or operator is not received by the
waste generator within 35 days of the date
that the waste was accepted by the initial
transporter, the waste generator must
contact the transporter and/or disposal site
owner or operator to determine the status of
the waste shipment. If a signed copy of the
WSR is not received within 45 days of the
date that the waste was accepted by the
initial transporter, the waste generator must
submit a written report to the same agency
that was notified about the demolition or
renovation.
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Owners of disposal sites must record on the
deed to the disposal site that the property
has been used for ACM disposal. They must
also keep records that show the location,
depth, area and volume of the asbestos
waste; they must indicate on the deed that
these records are available.
Owners of inactive disposal sites must
obtain written approval before they excavate
or otherwise disturb ACM waste that has
been deposited on the site.
Where Can I There are ten EPA Regional Offices around
get more *he country. You can obtain more
Information? information about the Asbestos NESHAP by
contacting your EPA Regional Office's
NESHAP coordinator or the appropriate
State or local agency. You can obtain more
information about AHERA by contacting
your EPA Regional Asbestos Coordinator
(RAC). The addresses and phone numbers
of both the RAC and NESHAP coordinators
for EPA 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 Office of the Federal Register
(202-382-5475) can send you copies of any
regulations published in The Federal
Register, including the Asbestos NESHAP.
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Finally, 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.
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AHERA and NESHAP Coordinators
AHERA and NESHAP Coordinators
Region
NESHAP
AIIERA
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
Asbestoi 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
IL, 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
NESHAP
AHERA
Region 6
AR, LA, NM
OK, TX
Asbestos NESHAP Coordinator
Air, Pesticides & Toxics Div.
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214) 655-7233
Regional Asbestos Coordinator
US EPA
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
(214)655-7244
Region 7
IA, KS
MO, NE
Asbestos NESHAP Coordinator
Air & Toxics Division
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7618
Regional Asbestos Coordinator
US EPA
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7020
Region 8
CO, MT, ND
SD, UT, WY
Asbestos NESHAP Coordinator
Air & Waste Management Div.
US EPA
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 294-7685
Regional Asbestos Coordinator
US EPA
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1442
Region 9
AS, CA, HI,
NV, AZ, GU,
TT
Asbestos NESHAP Coordinator
Air Management Division
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1135
Regional Asbestos Coordinator
US EPA
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1128
Region 10
AK, ID
OR, WA
Asbestos NESHAP Coordinator
Air & Toxics Management Div.
US EPA
1200 6th Avenue
Seattle, WA 98101
(206) 442-1757
Regional Asbestos Coordinator
US EPA
1200 6th Avenue
Seattle, WA 98101
(206) 442-4762
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