1 DECEMBER 2002
it was built 1920-1978 and has pipe insulation that is wrapped in canvas.
To be certain if a building material contains asbestos, a pre-design survey must be
accomplished to obtain detailed data regarding ACM locations and content in building
areas to be impacted. Samples must be taken by a person trained to do so and
analyzed in an accredited laboratory. The results will indicate whether the material is
positive (>1 percent asbestos) or negative (=<1 percent asbestos). Engineering
Pamphlet (EP) 1110-1-30 details a scope of work for such asbestos surveys.
The OSHA construction industry asbestos standard, 29 CFR 1926.1101
(http://www.access.gpo.gov/nara/cfr/waisidx_01/29cfrv8_01.html) provides detailed
work practice and engineering control requirements for asbestos work.
EPA's National Emission Standards for Hazardous Air Pollutants (NESHAPs) protect
the public from exposure to airborne contaminants, including asbestos. The complete
text is found at http://www.access.gpo.gov/nara/cfr/waisidx_01/40cfr61_01.html.
Sections 140, 141, 145, and 150 apply.
The asbestos NESHAP requires the owner or operator of a demolition or renovation
activity to thoroughly inspect the facility for the presence of asbestos, including
nonfriable ACM. If a threshold amount of asbestos will be disturbed, then the
installation must provide written notification at least 10 days before beginning work, to
the local Pollution Control Agency responsible for NESHAP enforcement in accordance
with Title 40 CFR 61.145(b), "Notification requirements." The installation must also
comply with asbestos emission control requirements contained in Title 40 CFR
61.145(c), "Procedures for asbestos emission control." If less than the threshold
amount of asbestos will be disturbed, only the reporting requirements of Title 40 CFR
61.145(b) apply. Neither the reporting or emission control requirements apply if less
than the threshold amount of asbestos is disturbed in a building undergoing renovation.
The threshold asbestos amounts that trigger the reporting requirements are:
80 linear meters (260 linear feet) of regulated asbestos-containing materials (RACM)
15 square meters (160 square feet) of RACM on other facility components
One cubic meter (35 cubic feet) of facility components where the amount of RACM
previously removed from pipes and other facility components could not be measured
Roofing materials have been specially addressed by EPA in Appendix A to the asbestos
NESHAPS. The notification, wetting, and disposal requirements are defined for
different situations and materials. A/C shingles that are removed and disposed of
without crumbling, pulverizing, or reducing them to powder, are not subject to the
NESHAP waste disposal requirements. This Appendix is not found on the CFR web
site, so please consult your legal office or environmental management function for the