Asbestos NESHAP ISSUES AND QUESTIONS
FIRE-DAMAGED BUILDINGS HOW DOES THE NESHAP APPLY?
After the Fire Is Out Building condition can vary widely from smoke damage to complete destruction with variations in between Insurance company/owner arranges to secure the building and surroundings from entry A disaster restoration service often provides water, fire, and contents restoration services This may involve renovation and/or demolition of the structure or part of the structure
What is Required by the Asbestos NESHAP for Burned Structures? First, if there is no structure or building remaining, the NESHAP is not applicable There is no facility to renovate or demolish Any work performed is clean-up and disposal Usually, some load supporting structure of the burned building is left for demolition or re-building /renovation
What is Required by the Asbestos NESHAP for Renovation/Demolition? As we learned earlier: Thorough inspection for asbestos Notification for renovation/demolition Removal of friable asbestos-containing material (ACM) or ACM likely to become friable Work practices must be observed Waste disposal How do you comply for burned buildings?
How Do You Do a Thorough Inspection for Asbestos When a Fire Has Occurred? If no load supporting structure remains, no inspection is required If any load supporting structure remains for renovation or demolition, thorough inspection is required
How Do You Do a Thorough Inspection for Asbestos When a Fire Has Occurred? Use an Accredited Inspector (as required by NCDHHS) Inspect, sample and test suspect materials in all areas that can be accessed safely Estimate the quantity and assess the condition of the suspect material Was the suspect material burned, subject to high temperature, made friable, or was it unharmed? For suspect friable materials, do point counting if initial Polarized Light Microscopy (PLM) testing is < 10% asbestos
Based on the Inspection Results, How Do You Comply With NESHAP? If NESHAP quantities are present, pri0r to renovation or demolition: Unburned friable ACM (Regulated ACM or RACM) and Category II ACM must be removed Category I ACM (resilient flooring and roofing) that is heat damaged, but not burned, is friable and must be removed Non-fire damaged Category I ACM may remain in place or be removed if it will not be made friable RACM and Category I ACM that has burned has released asbestos into the structure, and the entire structure is RACM and is subject to NESHAP
What NESHAP Compliance Issues May Result From Areas Not Inspected? Areas not inspected are presumed to contain RACM RACM that has burned has released asbestos into the structure, and the entire structure is RACM and is subject to NESHAP
Based on the Pictures Below, How Must the ACM be handled to Comply With NESHAP?
What If the Structure is Unsafe and RACM Cannot Be Safely Removed? If the building can be made safe by shoring, bracing, adding flooring, etc., do so, then do asbestos removal in compliance with NESHAP The municipality can order demolition of the structure when imminent danger is present and/or when there are significant violations of building code standards The order must come from an agency that regulates building safety
Notification for Ordered Demolition If the municipality has ordered demolition: Submit a NESHAP notification as early as possible, but not later than the following working day MCAQ recommends requesting a 10-working day waiver prior to demolition so we can evaluate the circumstances and provide confirmation or denial The notification must include all of the required information (see the form), AND The name, title, and authority of the ordering agency representative; The date the order was issued; The date the demolition was ordered to begin A copy of the order must be attached to the notification
Work Practice Requirements for Ordered Demolitions The structure must be presumed to contain RACM because a thorough inspection for asbestos cannot be safely done Remove facility components that are covered or coated with or contain RACM that can be safely removed before demolition Prior to and during the wrecking operation, adequately wet the portion of the facility that contains RACM One supervisory person with approved current training in the provisions of the asbestos NESHAP and the means of complying with them must be present for the duration of the demolition
Work Practice Requirements for Ordered Demolitions All demolition debris is asbestos-containing waste material (ACWM) and must be adequately wetted after demolition and during handling and loading into the container for disposal Discharge no visible emissions to outside air All demolition debris (ACWM) must be disposed of in a NESHAP landfill ACWM does not need to be sealed in leak-tight containers or wrappings but may be transported and disposed of in bulk (lined and covered trucks, etc.)
Asbestos Inspection and Removal In Unsafe Structures Some burned structures are deemed to be unsafe because structural members are weak or collapsing, but demolition has not been ordered and they cannot be made safe NESHAP still requires a thorough inspection for asbestos including Category I and Category II nonfriable ACM in all areas that can be accessed safely Areas not inspected must be presumed to contain RACM because a thorough inspection for asbestos cannot be safely done
Asbestos Inspection and Removal In Unsafe Structures If RACM is not burned, it must be removed in all areas that can be accessed safely prior to demolition Category I ACM need not be removed if it is not friable Before and during the wrecking operation, adequately wet the portion of the facility that contains RACM RACM need not be removed before demolition if it was not accessible for testing and, therefore, was not found until after demolition began and, as a result, cannot be safely removed All debris must be considered ACWM ACWM must be kept adequately wet at all times until disposed
SUSPECT ACM DISCOVERY DURING DEMOLITION HOW DO YOU COMPLY WITH THE NESHAP REQUIREMENTS?
During Demolition You Find This! Do You Know What It Is?
Or You Find This! Do You Know What It Is? What Do You Do?
When You Don t Know STOP! First, do your machine operators know how to recognize suspect ACM? Consider adding awareness of suspect ACM to demolition operator training If the discovered material is friable or may become friable, adequately wet it and cover it until disposition is made For thorough inspection, sample and test the new suspect ACM for asbestos If it is RACM or ACM likely to be made friable, remove it in accordance with NESHAP before resuming demolition
ASBESTOS INSPECTION AND POINT COUNTING NESHAP REQUIREMENTS
What Does the NESHAP Say About Asbestos Inspection and Point Counting? The answer is: not much! 40 CFR 61.145(a): prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM 40 CFR 61.141 Definitions: Friable asbestos material means any material containing more than 1 percent asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. If the asbestos content is less than 10 percent verify the asbestos content by point counting using PLM.
How Can This Benefit You? Consider the following scenario:
School Building for Demolition Specifications Building is 40,000 square feet Ceiling (30,000 sq.ft.) is textured skim coat 2% asbestos Flat, built-up roofing and flashing-10% asbestos Demolition job is turnkey Lowest bid gets the work What can you do (legally) to turn in the lowest possible bid?
NESHAP Considerations Ceiling is RACM and must be removed prior to demolition - $$$ ACWM (RACM ceiling) must be disposed of in NESHAP landfill - $$$ Roofing material in good condition may be left in place for demolition All waste except RACM ceiling can be taken to C&D landfill - $ Anything else to consider?
Point Counting! Demolition contractor calls the asbestos laboratory The retained ceiling sample is enough to do point counting using PLM Asbestos result by point counting is 0.75% Conclusion: Ceiling is not RACM Asbestos removal is not needed - $$$$$$ saved Contractor gets the demolition job!!
Summary Consider using point counting when initial asbestos test results for friable asbestos are over 1% but less than 10% The low cost of the additional test may eliminate much higher RACM removal and disposal costs Caution! Regulations other than NESHAP may need to be considered for compliance
NESHAP CONTACT INFORMATION MCAQ Main Telephone Number: (704) 336-5430 Rick Nelson: (704) 336-6865 Richard.Nelson@MecklenburgCountyNC.gov Ruth Jacquot: (704) 336-5418 Ruth.Jacquot@MecklenburgCountyNC.gov