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EPA 910-F-00-009
vvEPA
United States	Region 10
Environmental Protection 1200 Sixth Avenue
Agency	Seattle WA 98101-1128
Guidelines
For Submitting National
Emissions Standards for
Hazardous Air Pollutants
(NESHAP) Asbestos
Notification Forms for
Renovations and
Demolitions

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The Environmental Protection Agency's (EPA)
Region 10 office has prepared the following
guidelines for submitting asbestos notifications
to help you comply with the regulations. Mis-
takes can result in delays to your projects and
can lead to enforcement actions and penalties.
Please read the guidelines carefully and call us
if you have questions.
Original notifications must be delivered by
mail, delivery service, or in person. Faxed
originals are not acceptable. Please do not
send an advance fax copy because it can result
in confusion and delays when the mailed original
arrives. If you believe a notification is unusual
or needs clarification, feel free to call ahead of
time, so we'll understand it when it arrives. Mail
notifications to the address listed on the EPA
Region 10 web site (www.epa.gov/r10earth - Go
to the asbestos listing in the Index). Please call
for this information if you do not have internet
access.
Notifications must be postmarked or hand
delivered at least 10 working days before the
start of the asbestos removal or demolition. Do
not count from the day you sign the notification
unless it will be delivered or postmarked the
same day. Working days are defined as Mon-
day through Friday, including holidays. We
count ten days including the day of postmark,
with work starting on day 11. The easiest way to
calculate is to look at a monthly calendar, and
move straight down two weeks from the day of
postmark; that's the day you can start. That is,
Sun.
Mon.
Tues.
Wed.
Thurs.
Frl.
Sat.
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Notice	First day
mailed	work may
begin
You will find a copy of our notification form at
the web site listed in the first column. We also
can fax or mail a copy or send you an electronic
version. It is slightly different than the standard
form we have suppljed in the past. You are not
required to use this\form, but the information on
this form is required by the regulations. Be sure
to include all of the Required information in your
notification. Include a complete address for the
facility. Include thelamounts of asbestos to be
removed and, for a demolition, the amounts of
non-friable asbestos to remain in place. Under
the "description of planned renovation or demoli-
tion work" include the types and amounts of
asbestos materials\involved, if these are not
specified elsewhere in the notice. Note also that
EPA's use of "Category I" and "Category II" refer
to different types of, non-friable asbestos, and
are not the same designations as the Occupa-
tional Safety and Health Administration's
(OSHA) "Class I" a\id "Class II" asbestos. For
more information about the differences, refer to
the OSHA and NESHAP asbestos regulations.
Most important, watch for typing errors.
Common mistakes.include leaving off zeroes in
the asbestos amounts, incorrect dates, mis-
spelled addresses, and incorrect phone num-
bers. These mistakes can seriously affect
whether and when\you can legally conduct the
work.
If you submit yoiir notification with a removal
contractor name of "To Be Determined" because
the bid is still out, make sure that you remem-
ber to submit a revision with the chosen
contractor's name \before work begins.
For infdrmation about the
NESHAP regulations
call kPA Region 10:
1-800-424-4372
The following are important requirements that
often are not followed:
•	A revised notification must be submitted when
the amount of asbestos changes by at least
20 percent.
•	A revised notification must be submitted when
the start date changes.
•	When changing to a later start date, you must
revise your notification before the original
start date.
•	When the start date is changed to an earlier
date, there must still be 10 working days
from the date of the change to the start
of the project.
•	When a project will continue past the end date
listed on the notification, submit a revision
before the original end date. If work contin-
ues without a revision, you are working
without a notification.
These all constitute violations, but are not the
only violations and we will at a minimum send
warning letters for them. Even these simple
violations could result in an action with financial
penalties.
Revisions can and should be submitted by
fax when possible; do not follow up with a hard
copy. We will fax back the first page of a
revision with a date stamp, so that you will be
sure that we received it. Make sure your
revision includes your fax number. Sometimes
there will be a delay of a day in faxing back the
notice, generally when we are out of the office.
Refer to the web site listed above for our current
fax number. A cover sheet is not necessary (but
is okay). You can simply include a line on the
revision, Attn: Asbestos NESHAP Program.
Many revision styles are acceptable, but please
draw attention to the changed portion(s). We
have enclosed a short and easy revision that
several contractors use. This is an example of a
changed start date.
Thank you for your attention to these guide-
lines. Many of the notifications that we receive
are clear and accurate, and those make our
record keeping much easier. Our goal is to help
you comply with the notification requirements.
Please feel free to call if you have any ques-
tions.

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