Attachment_A_ROBY_ASBESTOS_REPORT.pdf

TRIANGLE ENVIRONMENTAL MTNF ASB March 20151

Environmental Science and Engineering Inc.

P.O. Box 1026

Rolla, MO 65402

Asbestos Inspection Of

Roby Ranger Station Roby, MO

MARCH 2015

Prepared for

Mark Twain National Forest And

Janet Fraley

TRIANGLE

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TRIANGLE ENVIRONMENTAL MTNF ASB March 20152

TABLE OF CONTENTS

Page No.

1.0 INTRODUCTION

2.0 SUMMARY OF ASBESTOS CONTAINING MATERIAL

3.0 THERMAL SYSTEMS

4.0 SURFACING MATERIALS

4.1 Flooring

4.2 Interior Walls/Ceilings

4.3 Exterior Walls

5.0 MISCELLANEOUS

5.1 Roofing

5.2 Windows

5.3 Insulation

5.4 Thermal wrap

6.0 FINDINGS

7.0 RECOMMENDATIONS

ATTACHMENTS

ATTACHMENT A Inspection Log Sheets/analytical results ATTACHMENT B Missouri Asbestos Inspector License ATTACHMENT C: Management of Nonfriable Asbestos Containing Materials

AND

Asbestos Requirements for Demolition and Renovation Projects

(MODNR)

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ROBY DWELLING AND SMALL GARAGE DEMOLITION/REMOVAL Attachment "A"

TRIANGLE ENVIRONMENTAL MTNF ASB March 20153

1.0 INTRODUCTION

On March 20th, 2015 Triangle Environmental Science and Engineering Inc. was authorized by Janet Fraley (MTNF) to conduct an Asbestos Inspection at.

RANGER STATION, ROBY MO

A 36’x38’ wood constructed, one story, on concrete basement, office building and a 12”X24” garage was inspected.

The inspections were performed on MARCH 20TH 2015 by John Cable. Mr. Cable is an AHERA and Missouri licensed asbestos inspector (Attachment B). Samples of suspect materials were collected and sent to Precision Analysis; Florissant Missouri where they were analyzed for bulk asbestos sample analysis by polarized light microscopy with dispersion staining in accordance with EPA/600/R-93/116 test method, The inspection was conducted within the limitations of customary asbestos inspection procedures on the date of the inspection. Triangle is not responsible for materials that were not evident for visual observations such as those hidden or beneath layers not readily identifiable.

Missouri Department of Natural Resources Air Pollution Control 2009

2.0 SUMMARY

The following items/material were tested and determined to contain/ not contain asbestos.

MTNF INSPECTOR JOHN CABLE

ASBESTOS SAMPLES CERT# 7118071114MOIR12565

DATE 2/24/2015

BUILDING RESIDENTIAL, POTOSI, MO

SAMPLE LOCATION MATERIAL

FRIABLE/

NON FRIABLE ASBESTOS

SQ FT

(APPX)

1 LIVING RM WALL JNT CMPD FRIABLE 5-10% CHRYSOTILE ALL

2 KITCHEN WALL JNT CMPD FRIABLE 5-10%CHRYSOTILE ALL

3 BED RM WALL JNT CMPD FRIABLE 5-10% CHRYSOTILE ALL

4 KITCHEN FLOOR VINLY NONFRIABLE ND 144

5 KITCHEN FLOOR VINLY NONFRIABLE ND 30

6 LIVING WINDOWS CAULK FRIALBE ND ALL

ASSUMED ATTIC

THERMAL

WRAP FRIABLE ASSUMED ACM ALL

A tested sample must have asbestos content >1% to be a regulated Asbestos Containing Material DRYWALL JOINT COMPOUND was determined to contain asbestos

THERMAL WRAP-ATTIC CHIMNEY WAS ASSUMED TO BE ACM.

No other items were identified at the time of inspection evalade Typewritten Text evalade Typewritten Text evalade Typewritten Text evalade Typewritten Text evalade Typewritten Text evalade Typewritten Text evalade

TRIANGLE ENVIRONMENTAL MTNF ASB March 20154

3.0 THERMAL SYSTEMS

Thermal system (boiler unit and HVAC) insulation materials have been known to contain asbestos.

THERMAL WRAP-ATTIC CHIMNEY WAS ASSUMED TO BE ACM.

4.0 SURFACING MATERIALS

4.1 Flooring

Flooring was concrete, wood and vinyl. . Several types of flooring material have been known to contain asbestos. No flooring tested positive for asbestos

4.2 Interior Walls/Ceilings

The interior walls of the structure had gypsum drywall and popcorn ceiling material. Several types of wall material have been known to contain asbestos.

ALL Drywall joint compound tested positive for asbestos.

4.3 Exterior walls

Exterior walls were wood covered. No samples taken

5.0 MISCELLANEOUS

5.1 Roofing

Roofing material was non friable asphalt shingles. No Samples Taken

5.2 Windows

Windows were wooden framed. Caulking on older framed windows has been noted to contain asbestos. No window caulking was determined to contain asbestos.

5.3 Insulation

Several types of friable insulation have been known to contain asbestos. Fiberglass batting insulation was noted no sample taken.

6.0 FINDINGS

As noted in the Sections above, three (3) items tested positive for asbestos. One (1) items was assumed to be asbestos containing material. Log sheets in Attachment A contain location, description, and approximate amount of the materials that were encountered and tested. There were no other suspect materials encountered at the time of the inspection.

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TRIANGLE ENVIRONMENTAL MTNF ASB March 20155

7.0 RECOMMENDATIONS

1. Prior to conducting renovation activities ensure any/all required notification/permit forms required by the State of Missouri are completed prior to the start of any work. The removal/asbestos abatement contractor or the renovation contractor should be in charge of handling these items prior to the start of their particular portions of the project

2. There is no non-friable Asbestos Containing Material (ACM). Removal should be conducted in accordance with MDNR guidance

3. There is friable Asbestos Containing Material (ACM) Removal should be conducted in accordance with MDNR guidance.

4. Any notification/permit forms requiring licensed asbestos inspector information should have a copy of this report along with all its attachments, accompanying those notification/permits.

This report should only be attached and read in its entirety.

5. Ensure that all materials are disposed of properly. Solid waste must be properly disposed of at an approved landfill or transfer facility in accordance with the Solid Waste Management Law.

6. All renovation/demolition activities should be conducted following all required Occupational Safety and Health Administration OSHA guidelines.

Triangle Environmental Science and Engineering Inc. is pleased to help in your environmental property evaluation. If you have any question, please feel free to call anytime. (573-308-0140).

John W. Cable Certified Missouri Asbestos Inspector evalade

MISSOURI DEPARTMENT OF NATURAL RESOURCES

AIR POLLUTION CONTROL PROGRAM

P.O. BOX 176, JEFFERSON CITY, MO 65102-0176

ASBESTOS PROJECT NOTIFICATION

PART A. NOTIFICATION INFORMATION

1. TYPE OF NOTIFICATION (CHECK ONE)

ORIGINAL REVISION CANCELLATION

2. TYPE OF PROJECT NOTIFICATION

160 SQUARE FEET, 260 LINEAR FEET, 35 CUBIC FEET OR MORE OF FRIABLE ASBESTOS MATERIAL INVOLVED*

LESS THAN 160 SQUARE FEET, 260 LINEAR FEET, OR 35 CUBIC FEET OF FRIABLE ASBESTOS MATERIAL INVOLVED

DOES THIS PROJECT INVOLVE STRUCTURAL RENOVATION OR DEMOLITION **

*NOTE: A NON-REFUNDABLE REVIEW FEE OF $100 MUST BE SUBMITTED FOR ANY ASBESTOS ABATEMENT PROJECT INVOLV-

ING 160 SQUARE FEET, 260 LINEAR FEET, 35 CUBIC FEET, OR MORE OF FRIABLE ASBESTOS-CONTAINING MATERIAL, AND FOR PLANNED RENOVATION PROJECTS AS DEFINED IN U.S. EPA REGULATION 40 CFR PART 61 SUBPART M.

**THIS NOTIFICATION DOES NOT SATISFY THE REQUIREMENT FOR DEMOLITION NOTIFICATION. USE FORM NUMBER 780-1923

FOR DEMOLITION NOTIFICATION.

MAKE CHECKS PAYABLE TO MISSOURI AIR POLLUTION CONTROL PROGRAM OR THE APPROPRIATE LOCAL AGENCY.

3. IF AN UNSAFE STRUCTURE IS BEING DEMOLISHED UNDER THE ORDER OF A STATE OR LOCAL GOVERNMENT AGENCY, INCLUDE A COPY OF THE UNSAFE BUILDING DECLARATION AND COMPLETE THE FOLLOWING:

A. NAME OF INDIVIDUAL ORDERING DEMOLITION

B. TITLE

C. AUTHORITY OF THE INDIVIDUAL

D. TELEPHONE NUMBER

4. FOR EMERGENCY RENOVATIONS COMPLETE THE FOLLOWING:

A. DATE AND HOUR OF THE EMERGENCY

B. DESCRIPTION OF THE SUDDEN, UNEXPECTED EVENT

C. EXPLANATION OF HOW THE EVENT CAUSED UNSAFE CONDITIONS OR WOULD CAUSE EQUIPMENT DAMAGE OR AN UNREASONABLE FINANCIAL BURDEN

5. IF A WAIVER OF ANY REQUIREMENT IS REQUESTED, INDICATE THE WAIVER DESIRED AND THE JUSTIFICATION FOR SUCH A

WAIVER. (USE SUPPLEMENTAL SHEET IF NECESSARY)

A. WAIVER

B. JUSTIFICATION

PART B. CONTRACTOR INFORMATION AND AUTHORIZATION

1. ASBESTOS ABATEMENT CONTRACTOR NAME

2. CONTRACTOR ADDRESS

3. CITY

4. STATE

5. ZIP CODE

6. MISSOURI REGISTRATION NUMBER

7. REGISTRATION EXPIRATION DATE

8. ON-SITE SUPERVISOR AND CERTIFICATION NUMBER

9. CONTRACTOR TELEPHONE NUMBER

10a. I CERTIFY THAT AN INDIVIDUAL TRAINED IN THE PROVISIONS OF FEDERAL REGULATION (40 CFR PART 61 SUBPART M) WILL BE ON-SITE DURING THE PROJECT AND PROOF THAT THIS PERSON HAS COMPLETED THE REQUIRED TRAINING WILL BE

AVAILABLE FOR INSPECTION BY THE DEPARTMENT.

10b. BY MY SIGNATURE, I ATTEST THAT ALL ASBESTOS ABATEMENT PROCEDURES SHALL BE PERFORMED IN COMPLIANCE

WITH ALL APPLICABLE STATE AND FEDERAL REGULATIONS.

10c. I HEREBY CERTIFY THAT, TO THE BEST OF MY KNOWLEDGE AND UNDERSTANDING, THE INFORMATION PROVIDED IN THIS

NOTIFICATION IS TRUE AND CORRECT.

11. SIGNATURE 12. DATE

13. PRINTED NAME AND TITLE

MO 780-1226 (5-05)

FOR APCP USE ONLY

DATE RECEIVED CHECK DATE

CHECK NUMBER CHECK AMOUNT

AIR POLLUTION CONTROL PROGRAM

ASBESTOS PROJECT NOTIFICATION

Any person who intends to perform an asbestos abatement project subject to the regulations of the Missouri Department of Natural Resources must provide the information requested in this form to comply with the requirements of the Missouri Air Conservation Law, Chapter 643 RSMo and Missouri State Rule 10 CSR 10-

6.241. Except as provided in 10 CSR 10-6.241, this form is to be completed and returned to the department not less than 10 working days before the intended start date of the project. This notification is for asbestos abatement activities only and does not satisfy the requirement for demolition notification required by 40 CFR Part 61, Subpart M.

Any notification specifying work practices in violation of the applicable regulations will be considered invalid, as will notifications that are incomplete or illegible.

Parts A, B, C, D, E, F, G, and H must be completed for each notification. Notifications lacking the required information will be returned for completion and the 10 working day review period specified in Missouri State Rule 10 CSR 10-6.241 will be recalculated according to the policy of the appropriate agency.

Attach consecutively numbered supplemental pages, as necessary, to provide the information required in this notification form. Each supplemental page must refer to the part number and item to which it pertains, and must identify the project site and notification date. Failure to provide this identifying information will render a notification incomplete.

Mail completed notification and fee to:

AIR POLLUTION CONTROL PROGRAM (ASBESTOS)

P.O. Box 176 Jefferson City, Missouri 65102

NOTE: If the asbestos project is under the jurisdiction of the Kansas City Air Quality Section, St. Louis County Air Pollution Control Branch, the Springfield-Greene County Air Pollution Control Authority, or the City of St.

Louis Division of Air Pollution Control, send this notification directly to the appropriate agency.

PART C. PROJECT DESCRIPTION

1. FACILITY PROJECT NAME

2. ADDRESS

3. PROJECT CITY

4. COUNTY

I

5. STATE

6. ZIP CODE

7. OWNER NAME

8. OWNER ADDRESS

9. OWNER CITY

10. STATE

11. ZIP CODE

12. OWNER CONTACT

13. OWNER TELEPHONE NUMBER

14. BUILDING SIZE

15. NUMBER OF FLOORS

16. AGE IN YEARS

17. PRESENT USE

18. PRIOR USE

PART D. ASBESTOS MATERIALS TO BE DISTURBED

1. DESCRIPTION AND QUANTITY OF FRIABLE ASBESTOS MATERIALS TO BE DISTURBED

MATERIAL

SQUARE FEET

LINEAR FEET

CUBIC FEET

2. DESCRIPTION AND QUANTITY OF NON-FRIABLE ASBESTOS MATERIALS TO BE DISTURBED

3. DESCRIBE THE PROCEDURE FOR THE DETECTION OF ASBESTOS CONTAINING MATERIALS INCLUDING THE ANALYTICAL METHOD EMPLOYED. INCLUDE A COPY OF

THE ASBESTOS INSPECTION REPORT.

PLM IN ACCODANCE WITH EPA/600/R-93/116

PART E. PROJECT SCHEDULE

1. SITE PREPARATION PHASE

START DATE

COMPLETION DATE

TIME

2. ASBESTOS ABATEMENT PHASE

START DATE

COMPLETION DATE

TIME

3. DAILY WORK SCHEDULE

START TIME

QUIT TIME

LUNCH BREAK

PART F. OTHER MISSOURI CERTIFIED PERSONNEL INVOLVED WITH PROJECT

DISCIPLINE NAME

CERTIFICATE

NUMBER

TELEPHONE

1. AIR SAMPLING

PROFESSIONAL

2. INSPECTOR TRIANGLE ENVIRONMENTAL

7112102507MOIR125

573-364-1864

3. MANAGEMENT

PLANNER

4. PROJECT

DESIGNER

PART G. PROJECT DESCRIPTION

1. DESCRIBE ABATEMENT WORK INCLUDING LOCATION IN BUILDING, PLANNED DEMOLITION/RENOVATION, AND METHODS TO BE USED

2. DESCRIBE WORK PRACTICES AND ENGINEERING CONTROLS TO BE USED TO PREVENT EMISSIONS OF ASBESTOS

3. DESCRIBE THE CONTINGENCY PLAN IF UNEXPECTED RACM IS DISCOVERED

PART H. WASTE DISPOSAL

1. NAME OF WASTE TRANSPORTER

2. ADDRESS

3. CITY

4. STATE

5. ZIP CODE

6. CONTACT PERSON

7. TELEPHONE NUMBER

8. WASTE DISPOSAL SITE

9. ADDRESS

10. CITY

11. STATE

12. ZIP CODE

13. CONTACT PERSON

14. TELEPHONE NUMBER

PART I. SUPPLEMENTAL INFORMATION

1. PROJECT SITE

2. NOTIFICATION DATE

3. PART NUMBER

4. ITEM NUMBER

Air Pollution Control Program fact sheet

Management of Nonfriable Asbestos Containing Materials

6/2006

Disclaimer: The statements in this document are intended solely as guidance. This document is not intended, nor can it be relied on, to create any rights enforceable by any party in litigation.

This guidance may be revised without public notice to reflect changes in law, regulation or policy.

Introduction This document is one in a series of fact sheets designed to assist you in becoming aware of the department’s asbestos requirements. This particular document contains information regarding how to properly remove and dispose of nonfriable asbestos containing materials.

Categories of Asbestos Containing Materials There are three categories of asbestos containing materials (ACM). These materials should be identified by a certified inspector prior to any renovation or demolition activities. They are as follows:

• Friable asbestos containing material Any material containing more than one percent asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Examples of friable materials include sprayed or troweled materials such as acoustical ceiling spray or boiler insulation, paper pipe insulation and drop-in ceiling tile.

• Category I nonfriable asbestos containing material Asbestos containing packings, gaskets, *resilient floor covering and asphalt roofing products containing more than one percent asbestos. *(Any vapor barrier on resilient floor coverings is considered friable asbestos.)

• Category II nonfriable asbestos containing material Any nonfriable material, other than category I materials, that contain more than one percent asbestos. Examples of category II materials include asbestos cement wall or roof shingles and cement pipe.

Depending on the type or category of asbestos containing materials present on a project and the work practices used during demolition or renovation to remove them, the materials may or may not be regulated by the department’s asbestos requirements. To determine the applicability of the department’s asbestos requirements, one must determine if the asbestos from your project will meet the definition of Regulated Asbestos Containing Material (RACM).

Regulated Asbestos Containing Material (RACM) includes friable asbestos containing materials;

category I nonfriable materials that have become or will become friable or have been subject to sanding, grinding, cutting, abrading or burning; or category II nonfriable materials that have a high probability of becoming or that have become crumbled, pulverized or reduced to powder due to the work practices used during the course of demolition or renovation.

PUB002156

Removal of Category I and II Nonfriable Materials Most nonfriable materials are not regulated by the department, unless they are in poor condition or are rendered friable by improper work practices during demolition or renovation. Category I nonfriable materials can be left in place during demolition, provided the work practices utilized will not make the material friable. However, for certain types of category I materials, such as floor tile and linoleum, the department generally recommends their removal prior to demolition as these materials could easily be rendered friable during the demolition. Also, leaving these mate-rials in place may increase the quantity of asbestos waste resulting in increased disposal costs.

It should be noted that materials that contain or are coated with asbestos can not be used as clean fill materials. If Category I ACM is left in place, work practices must be implemented to ensure the material is not made friable during removal or demolition. Any activity that will result in the material being subject to sanding, grinding, cutting, abrading, or burning may cause the material to become subject to regulation, depending on the quantity of ACM involved.

If a threshold or regulated quantity of RACM, including Category II materials, will be impacted, they must be removed prior to demolition or renovation activities. Category II materials must be removed in a manner that does not render the material friable. Improper work practices or materials in poor condition are considered RACM. If the material is crumbled, pulverized or reduced to powder during demolition or removal activities, the material may become subject to regulation depending on the quantity of RACM involved.

Any project involving a threshold amount of RACM (160 square feet, 260 linear feet, or 35 cubic feet) must be performed by a registered asbestos abatement contractor. This includes situa-tions where the material was originally nonfriable but is now in poor condition and situations where nonfriable materials will be made friable during demolition, renovation or removal.

Examples of Nonfriable Materials and Acceptable Removal Techniques

• Category I Asphalt Roofing Material is not regulated by the department as long as the material is in good condition and it is not made friable during removal or demolition. This material can generally be left in place during demolition activities, but still must be disposed of at a permit-ted landfill or transfer station. You should contact your disposal facility to determine how they will require this material to be packaged and delivered. Roofing material may be sliced by a manual cutter or knife, however, the use of mechanical devices such as a rotating blade roof cutter or other equipment will render roofing products friable. The Environmental Protection Agency (EPA) has determined that use of this kind of equipment on more than 5,580 square feet of roofing will make the project subject to regulation. If this is the case, then the project must be performed by a registered asbestos abatement contractor in accordance with all applicable asbestos work practice requirements.

• Category I Vinyl or Asphaltic Floor Tile is not regulated by the department as long as the material is in good condition and is not made friable during demolition or renovation activities.

Tile can generally remain in place during demolition, but care must be taken to ensure the material is left largely intact. Since it is difficult to control the degree of breakage that may occur, the department generally recommends that floor tile be removed prior to demolition. Tile may be removed from a structure as an unregulated project if manual methods are used and the tile is removed in largely intact pieces. One acceptable nonfriable removal method would be to flood the tiled area with water to loosen the tile and then popping the material from the subfloor with a spud hoe. Breakage of the tile should be minimized. Other methods include the use of mastic reducers or an infrared heating device to loosen the tile from the glue or mastic before removing the tile with manual tools as discussed above. In both cases, the tile should be adequately wetted with amended water throughout the removal process and prop-erly packaged while wet. This will help to reduce any potential asbestos emissions from the material.

If the tile is not removed in largely intact pieces, even if removed by the manual methods discussed above, it will be considered RACM. In addition, the use of any mechanical devices or bead blasters for removing tile will subject the material to regulation as RACM. The removal of tile as RACM must be performed by a registered asbestos abatement contractor in accor-dance with all applicable asbestos work practice requirements.

• Category I Nonfriable Mastic is not regulated by the department as long as the material is in good condition and is not made friable during demolition or renovation activities. This material must not be dry scraped or sanded. Use a mastic reducing solvent or material having a flashpoint above 140 degrees Fahrenheit to loosen the material from the subfloor. Then use a manual tool such as a spud hoe to remove the material. Any activity that would sand, grind, cut or abrade this material during removal would subject it to regulation as RACM. In this event, the project would be required to be performed by a registered asbestos abatement contractor in accordance with all applicable asbestos work practice requirements.

• Category I Vinyl Sheet Flooring (Linoleum) is not regulated by the department as long as the material is in good condition and is not made friable during demolition or renovation activities.

Sheet vinyl on wooden subflooring can generally remain in place during demolition, but care must be taken to not disturb the vapor barrier as this material is considered inherently friable.

Since most demolition activity will result in the backing being disturbed to some extent, the department would recommend that this material be removed prior to demolition. To remove sheet vinyl as a nonregulated project, the material must be removed adhered to the subfloor, so as to not expose the backing of the material. Exposure of the backing of the sheet vinyl, such as would occur if the material is stripped from the subfloor, will subject the material to regulation if more than a threshold quantity of RACM is disturbed. Removal in this manner must be done by a registered abatement contractor in accordance with all applicable asbestos work practice requirements.

• Category I Caulking is not regulated by the department as long as the material is in good condition and is not made friable during demolition or renovation activities. This material can be left in place during demolition provided it is not rendered friable during the demolition or renovation project. When removing caulking, in the case of window replacement, you may elect to remove the whole window unit. The material should be kept wet and the entire window wrapped for disposal. If the windows are not to be removed, then the caulking should be wetted and removed carefully not to sand, cut, grind, or abrade the material. The material should be containerized for proper disposal at an approved disposal facility. The landfill or transfer station should be contacted for any specific packaging or labeling requirements.

If the material has become brittle and crumbles upon removal, the material should be considered RACM. In this case, the removal must be done by a registered asbestos abate-ment contractor in accordance with all applicable asbestos work practice requirements, if threshold quantities of the material are present.

• Category II Asbestos Cement Siding and Cementitious Wall Board is not regulated by the department as long as the material is in good condition and is not made friable during demoli-tion or renovation activities. This material must be removed prior to demolition or renovation activities that will cause significant breakage, crumbling, or pulverizing of the material. When removing this type of material, the material should be removed manually by either driving the nails through the material or snipping off the nail or screw heads. The panels should be removed largely intact and should be lowered carefully to the ground. The material should be kept wet with amended water to further reduce the possibility of emissions. The material should be wrapped or packaged in accordance with the requirements of the disposal facility that will be used.

Beating, prying and dropping of the panels from an elevated position will likely cause the material to become crumbled and subsequently regulated as RACM. If more than a threshold amount of the material cannot be removed without breaking or crumbling the material, then the project must be performed by a registered asbestos abatement contractor in accordance with all applicable asbestos work practice requirements.

• Category II Asbestos Cement Roofing shingles are not regulated by the department as long as the material is in good condition and is not made friable during demolition or renovation activities. This material must be removed prior to demolition or renovation activities that will result in significant breakage, crumbling or pulverizing of the material. The removal of this material should follow the same protocols as stated above for asbestos cement siding. How-ever, using amended water on the material may not be appropriate if it will compromise the safety of workers removing the material.

Disposal of Nonfriable Materials Nonfriable asbestos containing materials are not subject to the department’s asbestos waste disposal requirements. However, this material is still considered a solid waste and must be properly disposed of at an approved landfill or transfer facility in accordance with the Solid Waste Management Law. You should contact the facility where you plan to dispose of your asbestos waste prior to removal to determine any specific procedures for waste delivery such as packag-ing, wetting, and labeling.

Nonfriable materials that become RACM must be handled in strict accordance with the require-ments for asbestos waste disposal. Projects involving RACM must be performed by registered asbestos abatement contractors who are trained in the provisions for proper handling, packaging and waste disposal. These requirements include packaging the material in leak tight containers or wrapping and properly marking and labeling the bags with an asbestos warning label and information identifying the generator of the waste. The material must be taken to an approved disposal facility, such as a sanitary landfill, that accepts asbestos containing waste.

Notification Requirements Provided the nonfriable ACM is in good condition and not made friable during the course of removal or demolition, there is no requirement for notification to be provided to the department prior to removal during renovation projects. However, the department encourages courtesy notifications to be submitted for these projects. Notification is required for all demolition projects involving regulated structures, regardless of asbestos content.

In the event that the nonfriable ACM is in poor condition (friable) or will be removed in a manner that will make it regulated as RACM, then notification must be provided 10 working days prior to the start of the project. This notice should be provided by the asbestos abatement contractor who is to perform the removal.

Minimizing Exposure For individuals working with nonfriable asbestos containing materials, respiratory protection consisting of high efficiency particulate air (HEPA) filtered respirators is recommended. Dispos-able protective clothing is also advised. An amended water solution consisting of approximately one ounce of liquid detergent to one gallon of water should be used before and during removal to keep the material adequately wet to minimize fiber release. Amended water should not be used on roofing projects where fall hazards exist or near electrical sources. Waste materials should be promptly bagged or wrapped for disposal and taken to a permitted solid waste landfill or transfer station.

While the removal of nonfriable materials may not be regulated under the department’s asbestos requirements, the material can still pose a safety risk if handled improperly. For this reason, the Occupational Safety and Health Administration (OSHA) also has requirements governing asbes-tos removal to ensure adequate protection of the workers performing the removal. For any project involving asbestos, whether regulated by the department or not, the department would recommend the use of trained asbestos professionals that are familiar with the OSHA standards for any asbestos removal work. To learn more about OSHA standards for asbestos removal, you may contact OSHA at one of the numbers listed below.

OSHA in St. Louis (eastern Missouri area) - 1-800-392-7743

OSHA in Kansas City (western Missouri area) – 1-800-892-2674

Asbestos Contact Information For more information on the department’s asbestos requirements, you may contact the department’s Air Pollution Control Program or one of the department’s other offices with the following contact information:

Missouri Department of Natural Resources Air Pollution Control Program P.O. Box 176 Jefferson City, MO 65102

(573) 751-4817

(573) 751-2706 - fax www.dnr.mo.gov/env/apcp Program Home Page

Other Department Offices Kansas City Regional Office Lee’s Summit (816) 622-7000

Northeast Regional Office Macon (660) 385-8000

St. Louis Regional Office St. Louis (314) 416-2960

Southeast Regional Office Poplar Bluff (573) 840-9750

Southwest Regional Office Springfield (417) 891-4300

Environmental Services Office Jefferson City 1-800-361-4827

Local Agencies In Missouri, there are also four local agencies delegated by the department to enforce the asbestos requirements. These local agencies may also have more stringent local ordinances that they enforce as well. Prior to performing a project in one of the following jurisdictions, you should contact the appropriate local agency to determine if any additional requirements apply.

Jurisdiction Agency Telephone

Kansas City proper Kansas City Health Department, (816) 513-6314 Air Quality Section

St. Louis City proper St. Louis Division of Air Pollution Control (314) 613-7300

St. Louis County St. Louis County Health Department (314) 615-8923

Springfield proper Springfield-Greene County Health Department (417) 864-1662

Additional Asbestos Related Guidance Documents For more specific information on the department’s requirements in regard to asbestos, please reference the additional guidance documents listed below or contact the department or appropriate local agency at the contact information listed above.

• Asbestos: What is it and Why is it a Concern?

• Asbestos Requirements for Demolition and Renovation Projects

• Requirements for Fire Training Exercises Involving Structures

• Natural Disaster Assistance for Missouri Citizens - How to Handle Asbestos Containing Debris

Air Pollution Control Program fact sheet

Asbestos Requirements for Demolition and Renovation Projects

6/2006

Disclaimer: The statements in this document are intended solely as guidance. This document is not intended, nor can it be relied on, to create any rights enforceable by any party in litigation.

This guidance may be revised without public notice to reflect changes in law, regulation or policy.

Introduction This document is one in a series of fact sheets designed to assist you in becoming aware of the Department of Natural Resources’ asbestos requirements. This particular document contains information regarding how to determine if your demolition or renovation project is regulated by the department’s air pollution control requirements. It will also help to explain the basic requirements for asbestos inspection, asbestos abatement, and for notification of regulated demolition and renovation projects. Asbestos waste disposal requirements are also covered.

Determining if Your Project Will Involve Regulated Structures The first step in determining if your demolition or renovation project is regulated is to determine the type of structure that will be affected. The department regulates demolition and renovation projects involving institutional, commercial, public, industrial, or residential structures, installa-tions or buildings. The only exception to this regulation is for a singleresidential structure that contains four dwelling units or less. Projects that involve two or more residential structures are not exempt. If the residential structure has been used during the course of its history for any purpose other than residential, such as being converted from residential to office use or con-verted from commercial to residential use then it is no longer exempt. Any single residential structure that is used in fire training exercises is not exempt.

Multiple residential structures being demolished as part of an urban or rural unsafe building or nuisance abatement program may be exempt if they are geographically dispersed from the remaining structures. The department residential structure to be geographically dispersed if it is greater than 500 feet from other structures involved in the demolition or renovation project. Also, the structure must have been used exclusively for residential purposes.

Inspection Requirements Prior to demolition or renovation activities, regulated structures or those areas that will be sub-ject to demolition or renovation activities must be thoroughly inspected to determine if any asbestos containing materials are present. This inspection must be performed by a Missouri-certified asbestos inspector. The inspector should identify all potential asbestos containing materials that may be disturbed by the demolition or renovation activity. Samples of the suspect materials should be collected and submitted for laboratory analysis to determine if they contain asbestos. The asbestos inspector can assume materials to be asbestos containing and avoid additional laboratory analysis. However, an inspector cannot make a determination that a sus-

PUB002157

pect material is non-asbestos containing without laboratory analysis. The inspector should generate a report of his findings from the inspection. The report should indicate all suspect materials that were identified, as well as quantify the amount, location, category and condition of all asbestos containing materials. The report should also include a copy of the analytical results and chain of custody for all samples that were collected.

In the event that a building is structurally unsound, it may not be possible to thoroughly inspect the entire structure. An inspection should be performed in all areas of the building where it is safe to do so. The final inspection report should clearly indicate what areas, if any, were not inspected. These areas of the building will require special handling during demolition, which is explained later in this bulletin.

If you need assistance with finding a Missouri certified asbestos inspector, you may find a list of inspectors on the department’s Web site at www.dnr.mo.gov/env/apcp/Asbestos.htm

Categories of Asbestos Containing Materials There are three categories of asbestos containing materials that may be identified by an inspec-tor.

• Friable asbestos containing material Any material containing more than one percent asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Examples of friable materials include sprayed or troweled materials such as acoustical ceiling spray or boiler insulation, paper pipe insulation and drop-in ceiling tile.

• Category I nonfriable asbestos containing material Asbestos containing packings, gaskets, *resilient floor covering and asphalt roofing products containing more than one percent asbestos. *(Any vapor barrier on resilient floor coverings such as sheet vinyl or tile is considered friable asbestos.)

• Category II nonfriable asbestos containing material Any nonfriable material, other than category I materials, that contain more than one percent asbestos. Examples of category II materials include asbestos cement wall or roof shingles and cement pipe.

Depending on the type or category of the asbestos containing materials identified at a project and the forces that will eventually act upon them during demolition and renovation, the materials may or may not be regulated by the department’s asbestos requirements. To determine the applicability of the department’s asbestos requirements, one must determine if the asbestos from your project will meet the definition of Regulated Asbestos Containing Material (RACM).

Regulated Asbestos Containing Material (RACM) includes friable asbestos containing materials;

category I nonfriable materials that have become or will become friable or have been subject to sanding, grinding, cutting, burning, or abrading; or category II nonfriable materials that have a high probability of becoming or that have become crumbled, pulverized or reduced to powder by the work practices utilized during the course of demolition or renovation.

Requirements for Abatement of Regulated Asbestos Containing Material If the asbestos inspection conducted for your renovation or demolition project indicates 160 square feet, 260 linear feet, 35 cubic feet, or more of RACM (threshold quantities) will be im-pacted by demolition or renovation activities, then all of the RACM must be removed. This removal must be performed by a Missouri registered asbestos abatement contractor.

Abatement contractors are trained in the proper procedures for safely removing and disposing of asbestos containing material and may only employ workers who are trained and subsequently, certified by the department on their projects.

In the event that a building is structurally unsound and it is unsafe to either inspect the building to confirm that no asbestos is present or to remove any RACM identified, the building can be demolished without being inspected or having the RACM removed. However, the demolition must be performed using wet methods and must be performed by a Missouri registered asbes-tos abatement contractor. Upon completion of the demolition, the debris must be inspected by a Missouri-certified asbestos inspector or assumed to contain RACM. If the asbestos inspection reveals that no RACM is present in the debris, then the debris can be handled as normal demoli-tion waste and be removed by a general demolition contractor. If the asbestos inspection re-veals that RACM is present or it is assumed that RACM is present, then all of the demolition debris must be handled as asbestos containing waste, unless the RACM can be isolated from the rest of the debris. All asbestos containing waste must be kept wet until the debris is properly disposed of at an approved sanitary landfill. A registered asbestos abatement contractor must perform the removal of the debris. Upon completion of the debris removal, a site assessment must be done to determine that the area surrounding the demolition site has not been contami-nated with asbestos.

If you need assistance with finding a Missouri registered asbestos abatement contractor, a list of contractors is on the department’s Web site at www.dnr.mo.gov/env/apcp/Asbestos.htm

Requirements for Abatement of Nonfriable Asbestos Containing Materials Most nonfriable materials are not considered RACM unless they are in poor condition or are rendered friable by improper work practices during demolition or renovation. Category I nonfriable materials can generally be left in place during demolition activities provided the method of demolition will not make the material friable. However, for certain types of category I materi-als, such as floor tile and linoleum, the department generally recommends removal prior to demolition as these materials could easily be rendered friable during the demolition process.

Also, leaving these materials in place may increase the amount of material considered as asbes-tos waste and may increase the cost of disposal. If category I ACM is left in place, work prac-tices must be implemented to ensure the material is not made friable during removal or demoli-tion. Any activity that will result in the material being subject to sanding, grinding, cutting, abrad-ing, or burning may cause the material to become subject to regulation, depending on the quan-tity of RACM involved.

If threshold quantities of category II materials will be impacted, then they must be removed prior to demolition or renovation activities. This removal must be performed in a manner that does not render the material friable. If the material is crumbled, pulverized or reduced to powder during the demolition or removal process, the material may become subject to regulation depending on the quantity of RACM involved.

The Occupational Safety and Health Administration (OSHA) has specific work practice stan-dards for friable and nonfriable Category I and Category II asbestos containing materials. While the removal of nonfriable materials may not be regulated by the department, the material can still pose a safety risk if handled improperly. For any project involving asbestos, whether regulated by the department or not, the use of trained asbestos professionals that are familiar with the

OSHA standards for any asbestos removal work should be considered.

In addition, nonregulated asbestos containing material is still considered a solid waste and must be properly disposed of at an approved landfill or transfer facility in accordance with the

Solid Waste Management Law. You should contact the facility where you plan to dispose of your asbestos waste for additional information on how the material should be packaged and delivered to their facility for disposal.

Notification Requirements There are two types of notifications required by the department in regard to demolition and renovation projects, asbestos abatement project notification and demolition project notification.

Asbestos abatement project notifications must be submitted to the department at least 10 work-ing days prior to the start of a regulated asbestos abatement project. This notification period allows the department the time it needs to prepare to inspect the project to ensure that it is being performed in compliance with all of the applicable requirements. In the case of emergency situations, the department can waive the 10 working day notification period.

However, verbal notice must be provided to the department within 24 hours of the onset of the emergency that describes the nature and scope of the emergency, the measures that will be taken to mitigate the situation, and a schedule for asbestos removal. A written notice must then be submitted to the department within seven days of the onset of the emergency.

The second type of notification is demolition notification. Demolition notification must be provided to the department at least 10 working days prior to the demolition of any regulated structure.

This notice is required even if there is no asbestos identified on your project. This notification period provides the department the opportunity to inspect the structure prior to demolition to ensure that all asbestos issues have been properly addressed. A copy of the asbestos inspec-tion report must accompany this notification. In the event a structure is in danger of imminent collapse and has been ordered demolished by a state or local government agency, the depart-ment can waive the 10 working day notification period. In this case, notice should be provided as early as possible before, but no later than the following working day. A copy of the govern-ment order must also be included with the notification.

It is the obligation of both the owner and any contractors involved to ensure that these notices are provided to the department. Failure to submit the notification is in violation of the department’s requirements. The department will issue an approval letter for all asbestos abate-ment and demolition project notifications for regulated projects. Owners or contractors perform-ing these types of projects should not proceed with the project without this approval.

You may obtain copies of the required notification forms from the department’s Web site at www.dnr.mo.gov/env/apcp/Asbestos.htm

Asbestos Waste Disposal Requirements Asbestos waste from regulated projects involving threshold quantities of RACM must be handled in strict accordance with the department’s requirements for asbestos waste disposal. Wastes from these projects must be handled by registered asbestos abatement contractors, who are trained in the provisions for proper waste disposal. These requirements include packaging the material in leak tight containers or wrapping and properly marking and labeling the bags with an asbestos warning label and the information for the generator of the waste. The material must be taken to an approved sanitary landfill or transfer station that accepts asbestos containing waste.

Nonfriable asbestos containing materials that are not made friable are not regulated by the department’s asbestos requirements. However, this material is still considered a solid waste and must be properly disposed of at an approved landfill or transfer facility in accordance with the Solid Waste Management Law. You should contact the facility where you plan to dispose of your asbestos waste prior to removal to determine any specific procedures for waste delivery (packaging, wetting, etc.).

Asbestos Contact Information For more information on the department’s asbestos requirements, you may contact the department’s Air Pollution Control Program or one of the department’s other offices with the following contact information:

Missouri Department of Natural Resources Air Pollution Control Program P.O. Box 176 Jefferson City, MO 65102

(573) 751-4817 - phone

(573) 751-2706 - fax www.dnr.mo.gov/env/apcp Program Home Page

Other Department Offices Kansas City Regional Office Lee’s Summit (816) 622-7000 Northeast Regional Office Macon (660) 385-8000 St. Louis Regional Office St. Louis (314) 416-2960 Southeast Regional Office Poplar Bluff (573) 840-9750 Southwest Regional Office Springfield (417) 891-4300

Local Agencies In Missouri, there are also four local agencies that have been delegated by the department to enforce the asbestos requirements. These local agencies may also have more stringent local ordinances that they enforce as well. Prior to performing a project in one of the following jurisdic-tions, you should contact the appropriate local agency to determine if any additional require-ments apply.

Jurisdiction Agency Telephone Kansas City proper Kansas City Health Department, Air Quality Section (816) 513-6314 St. Louis City proper St. Louis Division of Air Pollution Control (314) 613-7300 St. Louis County St. Louis County Health Department (314) 615-8923 Springfield proper Springfield-Greene County Health Department (417) 864-1662

Additional Asbestos Related Guidance Documents For more specific information on the department’s requirements in regard to asbestos, please reference the additional guidance documents listed below or contact the department or appropri-ate local agency at the contact information listed above.

These documents are available for free download from the department’s Web site at www.dnr.mo.gov/pubs/index.html.

• Asbestos: What is it and Why is it a Concern? PUB2077

• Management of Nonfriable Asbestos Containing Materials PUB2156

• Requirements for Fire Training Exercises Involving Structures PUB2029

• Natural Disaster Assistance for Missouri Citizens - How to Handle Asbestos Containing Debris PUB2121

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