Transcript PennDOT’s Asbestos NESHAP Policy for Bridge Demolition and

PennDOT Asbestos NESHAP Policy for
Bridge Demolition and Rehabilitation
Projects
Sponsored by Highway Administration
Learning Objectives
• PennDOT NESHAP Bridge Policy
• Bridge A,B,C Lists and Appropriate Actions
• Bridge Inspections and Regulatory Notification
National Emission Standard for Asbestos
• Asbestos - 40 CFR 61 Subpart M: Sec. 61.145
• Facility is: “Any institutional, commercial,
public, industrial, or residential building
(including any structure installation or building
containing condos or individual dwelling units
operated as a residential cooperative; any ship;
and any active or inactive waste disposal site.”
Regulated Asbestos Containing Materials
• Regulated Asbestos Containing Materials
(RACM)
• Friable ACM
• Non-Friable ACM - that has been made friable
or has a high likelihood of becoming friable
– Category 1
– Category 2
ACM Examples - Bridges
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Utility pipes and related insulation
Mastics/caulks/adhesives
Joint filler/sealant
Bearing pads
PennDOT Policy
• US EPA approval
– NESHAP compliance
– Reduce regulatory burden
– Saves the public money
• Consolidated Notification
– The SEMP Section obtains Asbestos NESHAP Bridge
Lists from Bridge Design & Tech. Division, Bur. Project
Delivery and submits to all regulatory agencies.
– List will NOT be updated once submitted to Agencies.
Bridge Management System
• Bridge ACM Categories
– List A – No RACM
– List B – Unknown RACM
– List C – Known RACM
PennDOT Policy Flowchart
PennDOT Policy Flowchart
List A Category Bridges
• The Bridge Design & Tech. Division, Bur. Project
Delivery Prepares the Asbestos NESHAP Bridge
List from the District’s CY Bridge Letting and the
Bridge ACM Status from the Bridge Management
System (BMS) Database
• Is the bridge on the A, B, or C lists?
• List A Bridges
– No RACM
– No further regulatory action is required.
List B Category Bridges
• Bridges identified as List B: Unknown ACM
• Inspection is required: provide report to Environmental
Manager
• Based on asbestos inspection ACM status field should
be changed from List B to lists A or C, if rehabilitation
project.
• If RACM is identified it must be abated prior to
rehabilitation /demolition
• Agency notification at least 10 days prior to abatement
List C Category Bridges
• Known RACM
• RACM must be abated prior to rehabilitation
/demolition
• No further regulatory action: NESHAP notification
completed via consolidated annual notification
Other Bridges
• Bridge not on List A, B, or C?
– Is the bridge span under 20 feet?
Inspections
• When should you perform an inspection?
– Before a bridge that is on list B is
demolished/rehabilitated.
– By contractor due to health and safety concerns.
• Inspection Options:
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PennDOT Qualified Staff
Environmental/Design Consultants
PennDOT Remediation Contract
General Contractor (Special Provision to Contract)
Individual District Notifications
• District responsible for individual notifications:
– B List
• All demolitions RACM or no RACM
• Renovations where identified RACM is to be
disturbed
– Bridges not on annual consolidated notification
– Emergency situations
– Let dates postponed to next calendar year
Notifications - Forms
• PADEP Asbestos Abatement and
Demolition/Renovation Form 270-FM-AQ0021
– 10 working days prior
– No fax copies accepted
• No RACM and RACM form instructions available
in Pub 611
• Emergency repairs
Notification - Local
• Allegheny County
– 260 linear feet on pipes
– 160 square feet for other facility components
• City of Philadelphia
– Exceeding 80 linear feet on pipes
– 40 square feet for other facility components
Notification: State
• Use this address
Regular Mail
ASBESTOS NOTIFICATION
DEP BUREAU OF AIR QUALITY
PO BOX 8468
HARRISBURG, PA 17105-8468
• Except for:
– City of Philadelphia
– Allegheny County
Notification: Allegheny County only
• Two copies (one original signature)
• Submitted within 10 working days of project start
• Use following address:
Allegheny County Health Department
Air Quality Program
Building 7
301 39th Street
Pittsburgh, PA 15201-1891
Attn: Asbestos Abatement Permitting
Notification: City of Philadelphia
• Minor asbestos projects
– 5 calendar days prior to start date
• Major asbestos projects
– Permit application 10 calendar days prior to the start
City of Philadelphia
Department of Public Health
Air Management Services
Asbestos Control Unit, 3rd Floor
321 University Avenue
Philadelphia, PA 19104-4597
Notification: Federal
• US EPA Region III:
Asbestos NESHAP Coordinator (3WC32)US EPA Region III
Asbestos Section
1650 Arch Street
Philadelphia, PA 19103
NESHAP PennDOT References
• Publication 611 Section 7.0
• Publication 281 Section 4.4.1
• Publication 100A 5E10-17
Conclusions
• PennDOT NESHAP Bridge Policy
• Bridge A,B,C Lists and Appropriate Actions
• Bridge Inspections and Regulatory Notification
Questions and Answers
• Any Questions
Copyright © 2012 by the Commonwealth of Pennsylvania. All rights reserved. No part of this publication may be reproduced,
stored in a retrieval system, or transmitted in any form or by any means electronic, mechanical, photocopying, recording or
otherwise without prior written permission by PennDOT.
This training course was developed in partnership with the Pennsylvania Department of Transportation’s Business Leadership
and Administrative Services Office and the Business Leadership and Administrative Services Office and the Bureau of Project
Delivery and Apex Companies, LLC. It is offered as part of the Pennsylvania Department of Transportation’s Highway
Administration Comprehensive Training Plan exclusively through the Technical Training and Development Section.
.