Notification Requirements and Submission
When Notification Is Required
The NESHAP requires written notification to the delegated state or EPA regional office before demolition or renovation that exceeds the applicable threshold. Notification must be submitted at least 10 working days before work begins, and the notification period runs from receipt by the agency. A candidate must know that the 10-working-day clock excludes weekends and federal holidays and that late submission is a violation even if the work is otherwise compliant.
What the Notification Must Contain
Notifications identify the owner and operator, the facility, the type of operation, the amount and type of asbestos affected, the start and completion dates, the waste disposal site, and the name of the supervisor. Common traps include:
- Naming the wrong disposal site or changing it without amending the notification.
- Failing to amend the notification when start dates, scope, or disposal locations change.
- Confusing the notification with the permit or with the waste manifest.
Emergencies and Amendments
Emergency renovations may proceed before notification under limited conditions, but the agency must be notified as soon as practicable and no later than the end of the following working day. Ordinary changes require an amended notification; a revised notification is not a substitute for a new one when the project is reclassified.
Worked Example
A contractor plans to start a renovation on the 1st of the month. Counting back 10 working days from the start date, the notification must be received by the agency no later than the close of business on the calculated date, accounting for weekends and holidays. If the start slips, an amended notification is required before the new start date.
Rule of Thumb
Count back 10 working days, confirm agency receipt, and amend in writing for any change in dates, scope, or disposal site.