Qi Ocq y) f col'5 I$°3' c/> 5 l-qj O CD coO 00 S9 ' o K Co cĞ m 5 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 ------- 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. 12 13 14 P 16 17 18 19 20 / r 22 23 24 25 26 2j/ / 28 İL 30 31 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. ------- |