Notification, Permitting and Demolition/Renovation Requirements
What this domain tests
This domain tests the regulatory triggers that must be met before renovation or demolition begins: threshold calculations, notification timing and content, permit coordination, and the requirement to remove RACM before demolition. In Delaware, the Department of Natural Resources and Environmental Control administers the federal asbestos NESHAP program, while local governments issue demolition permits.
Core rules and concepts
- NESHAP thresholds: Notification is required when a renovation will remove or strip at least 260 linear feet of RACM on pipes, 160 square feet of RACM on other facility components, or 35 cubic feet of RACM off facility components. Exceeding any one threshold triggers the requirement.
- Demolition: Notify even if no asbestos is present. All RACM must be removed before demolition, and the structure must be wetted as necessary to control visible emissions.
- Timing: Submit the written notification at least 10 working days before the start date. For emergency renovations, notify as soon as possible and no later than the end of the next working day.
- Content: Owner/operator, contractor, site address, start and completion dates, amount and category of RACM, work practices, and the permitted disposal site.
- Permits: A local demolition permit does not replace the DNREC asbestos notification; both may be required.
- Changes: If dates or quantities change, update the notification; do not begin work under an inaccurate notice.
Worked example
A renovation will remove 250 linear feet of pipe insulation, 170 square feet of floor tile, and 40 cubic feet of duct insulation. Pipe insulation is below 260 linear feet, but floor tile exceeds 160 square feet and duct insulation exceeds 35 cubic feet. The project therefore requires notification. If the same job removed only 250 linear feet and 150 square feet, and the duct insulation were nonfriable and left intact, no NESHAP notification would be triggered by those quantities-but local permits and OSHA requirements could still apply.
Traps that cost marks
- Counting calendar days instead of working days for the 10-day notice.
- Assuming demolition with no asbestos needs no notification.
- Applying the threshold to the whole building rather than the amount of RACM to be removed.
- Treating a local demolition permit as a substitute for DNREC notification.
- Forgetting that nonfriable material becomes RACM if it will be cut or ground.