Asbestos NESHAP
FIRE-DAMAGED BUILDINGS
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
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
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 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
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
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
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
Based on the Pictures Below, How
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
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
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
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”
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
SUSPECT ACM DISCOVERY
DURING DEMOLITION
During Demolition You Find This!
Or You Find This!
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,
ASBESTOS INSPECTION AND
POINT COUNTING
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
How Can This Benefit You?
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
