Demolition and Renovation Operations
What the domain tests
This domain tests NESHAP demolition and renovation rules under 40 CFR 61 Subpart M: inspection, ACM and RACM determinations, notification thresholds, removal before demolition, work practices, and waste handling.
Core rules
- Before demolition or renovation, a thorough inspection must identify ACM. ACM contains more than 1% asbestos; the 3% figure is not the NESHAP definition.
- RACM includes friable ACM, Category I nonfriable ACM that becomes friable or is sanded/ground/cut/abraded, and Category II nonfriable ACM likely to be crumbled or pulverized.
- Written notification is required at least 10 working days before demolition, and before renovation when RACM reaches 260 linear feet on pipes, 160 square feet on other components, or 35 cubic feet off components. All demolitions require notification, even with no asbestos.
- RACM must be removed before demolition or renovation that would disturb it; use wet methods, avoid visible emissions, and dispose as asbestos waste.
- Keep inspection reports, notifications, waste manifests, and training records.
Worked example
A renovation will disturb 180 square feet of ACM ceiling tile and 200 linear feet of ACM pipe insulation. The pipe amount is below 260 linear feet, but 180 square feet exceeds the 160-square-foot threshold, so written notification is required at least 10 working days before work. The owner cannot wait for the contractor to 'call it in' on the start date; the notification must be timely and accurate. Removal must precede disturbance, and the waste must be handled as asbestos waste.
Traps that cost marks
Using 3% as the ACM cutoff; counting calendar days instead of working days; assuming a renovation below one threshold never needs notice; and treating notification as approval. Emergency renovations still have notification duties. Category I material is not automatically exempt if it will be abraded.