AZ Asbestos Abatement cheat sheet

NESHAP for asbestos (40 CFR Part 61, Subpart M) applies to owners and operators of demolition and renovation activities on facilities; a facility is any institutional, commercial, public, industrial, or residential structure, installation, or building.

Regulated asbestos-containing material (RACM) means: friable asbestos material; Category I nonfriable ACM that has become friable; Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or Category II 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 it.

Category I nonfriable ACM includes asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products; Category II nonfriable ACM is any nonfriable material other than Category I (for example, asbestos cement siding or transite pipe).

Threshold trigger: a renovation is regulated when the amount of RACM to be stripped, removed, dislodged, cut, drilled, or similarly disturbed is at least 160 square feet on facility components, at least 260 linear feet on pipes, or at least 35 cubic feet off facility components where length could not be measured before stripping.

Demolition of a facility that is a public or commercial structure is regulated regardless of the amount of asbestos present; a demolition of a residential building with four or fewer dwelling units is exempt unless it is part of a larger regulated activity.

A thorough inspection for asbestos, including sampling and analysis or documented assumption of presumed asbestos-containing material, must be conducted before a renovation or demolition begins; the owner/operator bears this duty.

Order of work rule: RACM must be removed before any activity that would disturb it, and all RACM must be removed from a facility being demolished before the structure is demolished, except where removal is impossible or would cause a greater hazard.

A written determination or record of the inspection, and the basis for any exemption (for example, an exemption for a residential building of four or fewer units or an order-of-work exemption), must be kept and made available to the Administrator on request.

AHERA (40 CFR Part 763, Subpart E) requires local education agencies to inspect each school building for asbestos-containing material and to develop and update an asbestos management plan; inspections are performed by accredited inspectors.

Five AHERA accreditation disciplines: inspector, management planner, project designer, contractor/supervisor, and worker; each requires a training course, an examination, and refresher training within the discipline-specific interval.

Refresher intervals: inspector, management planner, project designer, and contractor/supervisor accreditations are renewed annually; worker accreditation is renewed annually as well, and all require successful completion of a refresher course.

An inspector who samples material must be accredited; a management planner interprets inspection results and develops response actions, and must be accredited as a management planner (and typically holds inspector accreditation as a prerequisite).

Bulk sampling follows a documented scheme: for a homogeneous area of surfacing material, at least three samples; for thermal system insulation, at least three samples; for miscellaneous material, at least two samples, with additional samples where the material is not uniform.

Laboratory analysis must use an accredited method under the NVLAP program (for example, polarized light microscopy per the EPA interim method), and the laboratory report identifies the percentage and type of asbestos fibers found.

Presumed asbestos-containing material (PACM): thermal system insulation and surfacing material in buildings constructed before the applicable cutoff dates are presumed to contain asbestos unless sampled and shown otherwise; the presumption must be communicated to employees and occupants.

Accreditation certificates and training records must be available at the work site during abatement, and an accredited contractor/supervisor must be present on site at all times during abatement work.

The owner or operator must submit a written notification of renovation or demolition to the delegated state or local agency (or the EPA Regional Office where no delegation exists) at least 10 working days before the work begins.

Notification contents include: name, address, and telephone of the owner/operator; description and location of the facility; estimate of the approximate amount of RACM to be removed in square feet, linear feet, or cubic feet; scheduled start and completion dates; and the name and address of the waste disposal site.

A revised notification is required when the start date changes or when the amount of RACM changes by more than 20 percent; the revision must be submitted as soon as possible and before the original start date where practicable.

Emergency renovations (resulting from a sudden, unexpected event such as a broken pipe or a fire) may proceed without the 10-working-day wait, but notification must be made as soon as possible and before the next working day, with a follow-up written notification.

A notification is not required for an ordered demolition (demolition ordered by a government agency because the structure is structurally unsound and in danger of imminent collapse), but the agency must be notified as soon as possible.

A single notification may cover a project; amendments can be handled by phone with written follow-up depending on the delegated agency's rules, and the delegated program's requirements control where they are more stringent than the federal rule.

Notification must include the name and location of the waste disposal site and, where applicable, the transporter, because the disposal site must be a permitted site that accepts asbestos waste.

Keep a copy of the notification and any amendments with the on-site project records; the notification number and start date are the reference points used by inspectors during site visits.

The abatement project's start date in the notification begins the regulated period; work must not begin before the notified start date and must be completed by the notified completion date, with revisions filed if either date changes.

On-site records include: the notification and amendments; the inspection report and sampling results; accreditation certificates for the contractor/supervisor and workers; the work plan and abatement plan; and daily logs recording start and stop times and the amount of RACM removed.

A daily log or project record documenting the dates and hours of abatement, the areas worked, the amount of material removed, and the waste generated is the primary evidence that work stayed within the notified window.

The contractor/supervisor must be accredited and on site at all times while abatement is in progress; worker accreditation records must be available for each worker present.

Personal and area air monitoring records, if collected, are retained with the project file; the federal NESHAP does not itself set a numeric worker exposure limit, but OSHA (29 CFR 1926.1101) sets a permissible exposure limit of 0.1 fibers per cubic centimeter as an 8-hour time-weighted average.

Waste shipment records must reconcile with the project duration: the number and dates of waste shipments, the manifest numbers, and the disposal site receipts should show that all removed material left the site before completion.

A project that runs past the notified completion date requires a revised notification; a project that is completed early should be documented with the actual completion date in the project log.

Records must be retained and made available to the Administrator on request; the NESHAP requires the owner/operator to keep the notification, inspection records, and waste shipment records, and delegated states may impose longer retention periods.

Asbestos waste is a regulated waste under the NESHAP; it must be wetted, bagged or wrapped in leak-tight containers, labeled with the required warning, and transported to a permitted disposal site that accepts asbestos-containing waste.

A waste shipment manifest (or a comparable tracking form required by the receiving state) records the generator, the transporter, the quantity and type of waste, the disposal site, and the dates of shipment and receipt.

The generator retains a copy of the manifest, the transporter keeps a copy, and the disposal site signs and returns a copy to the generator; the returned receipt is the proof of disposal.

If a completed manifest with the disposal site's signature is not received within the required interval (commonly 35 days for hazardous waste-style tracking, or as the delegated asbestos program specifies), the generator must investigate and document the discrepancy.

Waste containers must remain sealed and labeled until they reach the disposal site; containers must not be opened, compacted, or transferred in a way that could release fibers.

The disposal site must be identified in the notification; if the disposal site changes, the notification must be revised and the records updated accordingly.

Quantities on manifests should reconcile with the estimated RACM removed in the notification; unexplained discrepancies between the removal estimate and the shipped quantity are a common inspection finding.

Retain manifests, disposal receipts, and any discrepancy reports with the project file for the period required by the delegated program, and make them available to the Administrator on request.