EPA NESHAP Regulations
EPA NESHAP (National Emissions Standard for Hazardous Air Pollutants) is a vital regulatory framework with major requirements for facilities, activities, responsibilities, and materials regulated under its purview. This overview sheds light on the NESHAP discussion issues, facilities regulated, key requirements before demolition or renovation, regulated community waste generators, regulated activities, and asbestos-containing materials classifications.
Download Presentation
Please find below an Image/Link to download the presentation.
The content on the website is provided AS IS for your information and personal use only. It may not be sold, licensed, or shared on other websites without obtaining consent from the author. If you encounter any issues during the download, it is possible that the publisher has removed the file from their server.
You are allowed to download the files provided on this website for personal or commercial use, subject to the condition that they are used lawfully. All files are the property of their respective owners.
The content on the website is provided AS IS for your information and personal use only. It may not be sold, licensed, or shared on other websites without obtaining consent from the author.
E N D
Presentation Transcript
EPA NESHAP National Emissions Standard for Hazardous Air Pollutants 40 CFR 61 Subpart M
As you will see from the following slides, the EPA NESHAP does not usually apply to transite pipe removal. However, if correct work practices are not followed, the NESHAP may be triggered, and serious non-compliance could result. This section is presented for your information, but it should be taken very seriously. Federal EPA recently settled a case against a transite pipe contractor that resulted in a 4 million dollar plus penalty under the NESHAP.
NESHAP DISCUSSION ISSUES MAJOR REQUIREMENTS WHAT FACILITIES ARE REGULATED WHAT ACTIVITIES ARE REGULATED WHO IS RESPONSIBLE WHAT MATERIALS ARE REGULATED THRESHOLD AMOUNTS ?
MAJOR REQUIREMENTS Before Demolition or Renovation INSPECT TO IDENTIFY ALL ASBESTOS NESHAP NOTIFICATION TO EPA REQUIRED REMOVAL BEFORE DISTURBANCE RACM PROPER PROCEDURES FOR REMOVAL PROPER WASTE DISPOSAL WASTE SHIPMENT RECORDS
NESHAP Facilities ALL STRUCTURES, INSTALLATIONS, OR BUILDINGS EXCEPT RESIDENTIAL THROUGH 4 UNITS INCLUDES SHIPS, WASTE SITES, PIPELINES, AND JUST ABOUT EVERYTHING ELSE
REGULATED COMMUNITY WASTE GENERATOR: THE OWNER/OPERATOR OF A FACILITY PRODUCING ASBESTOS CONTAINING WASTE MATERIAL (ACWM) (It s the building owner and the contractor)
REGULATED ACTIVITIES DEMOLITION OR RENOVATION IMPACTING OR CAUSING REGULATED ASBESTOS CONTAINING MATERIAL (RACM)
REGULATED ASBESTOS CONTAINING MATERIAL FRIABLE ACM CATEGORY I NON-FRIABLE WHICH HAS BECOME FRIABLE CATEGORY I NON-FRIABLE WHICH HAS BEEN/WILL BE SANDED, GROUND, CUT OR ABRADED CATEGORY II NON-FRIABLE WHICH PROBABLY WILL BECOME/HAS BECOME FRIABLE Or, EPA declares the material RACM because of mechanical disturbance.
NON-FRIABLE ACM CATEGORIES CATEGORY I NON-FRIABLE RESILIENT/PLIABLE ROOFING, FLOORING, PACKINGS, AND GASKETS CATEGORY II NON-FRIABLE Anything that is not RACM or CAT I. (TYPICALLY ASBESTOS CEMENT PRODUCTS)
FRIABLE vs NON-FRIABLE ALL ACM: FRIABLE NON-FRIABLE (RACM) (Cat. I & Cat. II) FRIABLE: FULLY REGULATED (RACM) CAT I : GENERALLY NOT REGULATED CAT II : REQUIRED REMOVAL PRE-DEMO NOT REGULATED FOR DISPOSAL
THRESHOLD AMOUNTS OF RACM FOR DEMOLITION OR RENOVATION 260 LINEAR FEET ON PIPE 160 SQUARE FEET ON ALL OTHER SURFACES 35 CUBIC FEET IF UNABLE TO MEASURE OTHERWISE (i.e.. Waste Pile or Debris) RENOVATION BELOW THRESHOLD: NO APPLICABILITY OF THE REGULATION DEMOLITION BELOW THRESHOLD: DEMO NOTIFICATION ONLY
NESHAP APPLICABILITY DEMOLITION INSPECTION RENOVATION NOTIFICATION NOTIFICATION REQUIRED REMOVAL REQUIRED REMOVAL WET METHODS WET METHODS TRAINED PERSON TRAINED PERSON LEAK-TIGHT WASTE LEAK-TIGHT WASTE LABELING LABELING PROPER DISPOSAL PROPER DISPOSAL RACM: 260 Linear Ft. 160 Square Ft. 35 Cubic Ft. DEMO NOTIFICATION (even with no asbestos) NO REGULATION
61.141 Selected Definitions ASBESTOS CONTAINING WASTE MATERIAL(ACWM): RACM & materials contaminated w/asbestos DEMOLITION: Wrecking/taking out of load supporting structural members EMERGENCY RENOVATION: Sudden, unexpected event FACILITY: Everything except 1-4 dwelling units ORDERED DEMOLITION: By state/local gov t agency RENOVATION: Altering, stripping or removal of RACM from a facility component WORKING DAY: Monday through Friday including holidays
61.145 DEMOLITION & RENOVATION: (a) Applicability: Mandates an inspection to identify all asbestos as either RACM, Category I, or Category II ACM, before being disturbed by demolition or renovation. (a)(1)-(3): Threshold amounts for demo (a)(4): Threshold amounts for renovation (a)(4)(iii): Annual O & M notification (a)(4)(iv): Emergency Renovation
61.145 DEMOLITION & RENOVATION: (b): Notification (1) Delivery (2) Update as necessary (3) 10 working days - Changes to start date (4) Elements of the notification (5) Use the notification form
61.145 DEMOLITION & RENOVATION: (c): Procedures For Emission Control (1) Remove RACM before disturbance (2) Component removal intact (3) Stripping of RACM in place (4) Stripping from removed component (5) Disposing of intact component (6) Rules for removal of RACM (7) Freezing temperatures/dry removal (8) AHERA Contractor/Supervisor (9) Wetting for ordered demo (10) Removal for intentional burning
61.150 WASTE DISPOSAL: (a) No visible emissions - Adequately wet - Leak-tight containers - Label containers - Cat. I and Cat. II exemptions (b) Disposal at approved site ASAP - Cat. I exemption (and Cat. II) (c) Mark waste vehicles loading & unloading (d) Waste Shipment Record for transport off generator site (e) WSR available upon request
WASTE CONTAINER LABELS: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER & LUNG DISEASE HAZARD OSHA: RQ ASBESTOS DOT: NA 2212 GENERATOR NAME EPA: SITE ADDRESS
