Asbestos is the generic term for a group of naturally occurring, fibrous minerals with high tensile strength, flexibility, and resistance to heat, chemicals, and electricity. Asbestos was a popular component in commercial products from the early 1900’s to the 1970’s and is found in building construction materials such as:
- sprayed-on fireproofing
- sprayed-on or textured ceiling material
- pipe and boiler insulation
- floor tiles and associated mastics
- cement pipe and sheeting
- roofing felts and shingles
- ceiling tiles
- drywall and joint compounds
- acoustical products
Unlike most minerals, asbestos breaks up into fine, light fibers invisible to the naked eye that can only be seen under a microscope. Intact and undisturbed asbestos-containing material (ACM) usually does not pose a health risk. It becomes a problem when asbestos fibers are released into the air due to damage, disturbance, or deterioration over time.
Asbestos fibers enter the body when a person inhales or ingests airborne particles that become embedded in the tissues of the respiratory or digestive systems. Exposure to asbestos can cause disabling or fatal diseases such as asbestosis, an emphysema-like condition; lung cancer; mesothelioma, a cancerous tumor that spreads rapidly in the cells of membranes covering the lungs and body organs; and gastrointestinal cancer. The symptoms of these diseases generally do not appear for 20 or more years after initial exposure.
The Clean Air Act (CAA) requires the U. S. Environmental Protection Agency (EPA) to develop and enforce regulations to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health. In accordance with Section 112 of the CAA, EPA established National Emissions Standards for Hazardous Air Pollutants (NESHAP) to protect the public. On March 31, 1971, EPA identified asbestos as a hazardous pollutant, and on April 6, 1973, EPA first promulgated the Asbestos NESHAP in 40 CFR Part 61.
The purpose of the asbestos NESHAP is to protect the public health by minimizing the release of asbestos when buildings containing asbestos are demolished or renovated. EPA delegates the responsibility of enforcing the asbestos NESHAP to state and local agencies. The Tennessee Department of Environment and Conservation, Division of Air Pollution Control, is responsible for enforcing these regulations for the state of Tennessee with the exception of Davidson, Hamilton, Knox, and Shelby counties. Demolition and asbestos renovation activities conducted in these counties are under the jurisdiction of a local air agency which is the point of contact for notification and permitting requirements.
The information contained herein is intended to inform contractors and building owners of the notification requirements for asbestos renovation activity and the demolition of buildings in addition to providing information for commonly asked questions regarding asbestos related topics. Comments or questions may be directed to the Tennessee Asbestos NESHAP program at (615) 532-0554.
Persons involved with the removal of Regulated Asbestos-Containing Material (RACM) during facility renovation and/or demolition must file a notification with the Tennessee Division of Air Pollution Control (APC). A notification is required for the removal, renovation and/or demolition of asbestos where quantities exceed 260 linear feet or more on pipes, 160 square feet or more on other facility components, or 35 cubic feet or more off facility components where the length or area could not be measured previously. Notification to APC is required of any demolition (includes intentional burning) even if there is no asbestos.
Exemptions include non-friable asbestos containing materials, packings, gaskets, resilient floor covering and asphalt roofing products that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.
A completed Notification of Asbestos Demolition or Renovation Application (Form CN-1055) must be submitted at least 10 working days before the asbestos stripping or removal work begins. Information requested includes:
- Type of notification: original or revised
- Name, address and telephone number of both the facility owner and operator and the asbestos removal contractor owner or operator
- Type of operation: demolition or renovation
- Whether or not asbestos is present in the building
- Name, address and site location of the facility
- Procedure and analytical method used to detect the presence of RACM
- Approximate amount of asbestos in the work area
- Dates for asbestos removal or renovation/demolition
- Description of planned demolition/renovation work methods to be used
- Description of work practices and engineering controls to be used to prevent emission of asbestos
- Waste transporter and disposal site name, address and telephone number
- Name of government agency if demolition was ordered by a government agency
Upon receiving a completed application, the Division reviews the application and contacts the applicant within 10 days if there are any deficiencies. If the application is accepted, the applicant will not be contacted and may proceed with the planned activity.
What Fees Are Required?
My Rights And Responsibilities After The Notification Is Approved
- The applicant may proceed with the planned activities and must comply with the procedures for asbestos emission controls and other requirements of the Tennessee Asbestos Rules.
The Division's Rights And Responsibilities After The Notification Is Approved
- The Division has the right to conduct site inspections when deemed necessary. Violations of any standards or procedures can result in civil penalties up to a maximum of $25,000 per day.
Contact For Applications, Assistance And Other Information
Applicants located in Davidson, Hamilton, Knox or Shelby counties must contact the applicable county air permit agency. For all other counties, applications and assistance can be obtained by contacting the Division of Air Pollution Control. New applicants who need more than one permit can contact their Environmental Field Office for further assistance.
- Notifications for Demolition and/or Asbestos Renovation activities conducted at state owned facilities in the counties of Davidson, Hamilton, Knox, and Shelby are to be submitted to the Tennessee Department of Environment and Conservation, Division of Air Pollution Control.
Applicants may refer to the following publications for further information:
The intent of the following guidance is to provide a summary of requirements pertaining to the demolition of buildings and the handling of asbestos containing material when structures have been deemed structurally unsound and in danger of imminent collapse by a state or local government agency. When a facility has been damaged by fire or by a natural disaster, for example, there may be a tendency to overlook certain hazards that are not immediately life threatening.
Given the health hazards associated with asbestos, it is reasonable that adequate measures be taken during emergency situations to minimize exposure to such material from the demolition of buildings. To the extent feasible, efforts should be made to adhere to the following guidance in order to comply with federal and state regulations.
Federal asbestos regulations are contained in 40 CFR sections 61.140 through 61.160. In addition, the OSHA regulations on asbestos are also applicable.
This guidance applies to all nonresidential buildings (e.g., commercial and public buildings) and residential buildings with five or more dwelling units that are structurally unsound and in danger of imminent collapse.
This guidance applies to a group of residential structures that are structurally unsound and in danger of imminent collapse and are a part of a government ordered demolition. Such structures are considered an “installation” in the asbestos NESHAP, and is defined as any group of buildings or structures, which includes residential structures, at a single demolition site that are under the control of the same owner or operator (or owner or operator under common control) including a contractor hired to demolish this group of structures.
This guidance does not apply, but is recommended, to private individuals who contract directly with a demolition contractor for the demolition of a single residential structure they own having four or fewer dwelling units.
This guidance does not apply to the demolition of a damaged building that is not unsound and in danger of imminent collapse. Buildings of this classification are regulated by more stringent requirements.
If a building has been totally destroyed by fire or a natural disaster, the asbestos NESHAP does not apply to subsequent activities. If the building is only partially damaged, the asbestos NESHAP applies to the portion which remains standing.
It is unsafe to enter a structurally unsound building. A thorough inspection of a building to determine the amount, types, and location of asbestos containing building materials is not required.
A building may be known to have asbestos containing products. Such products may include: asbestos-cement corrugated sheet, asbestos-cement flat sheet, asbestos pipeline wrap, roofing felt, vinyl-asbestos floor tile, asbestos-cement shingle, millboard, asbestos-cement pipe, surfacing or spray-applied materials, and vermiculite-attic insulation.
All structures (both residential and commercial) built before 1975 may contain significant amounts of asbestos. In particular, large structures built before 1975 typically contain asbestos pipe wrap, siding, ceiling tiles, and other building materials high in asbestos content. Note that structures built after 1975 may also contain asbestos.
Persons conducting demolitions should formally notify the Air Pollution Control division as early as possible prior to the start of the demolition, but in any event, no later than the following workday after starting the demolition.
At least one person, either a government official or private contractor, trained in the asbestos NESHAP regulations should be on site or available by cell phone during the demolition to provide assistance or guidance.
PPE: In all instances, workers should use equipment specifically designed to protect them from asbestos exposures during demolition and handling of debris, especially respirators, as required by OSHA.
Use of water: Heavy equipment used for demolition may cause asbestos to be disturbed. It is very important to wet the structure before and during demolition to prevent the migration of asbestos fibers.
It is recommended to knock down each structure wall-by-wall, folding it in on itself to minimize the excess breakage of asbestos containing material. Debris should be handled in a way to minimize excess breakage.
Burning: Structures may not be demolished by burning unless approved by a Regional TDEC Environmental Field Office at 1-888-891-TDEC (8332). If approval is granted, there is absolutely no burning allowed unless all asbestos-containing material is removed in accordance with the asbestos NESHAP prior to burning. This also applies to residential structures containing asbestos.
If it is known that asbestos is present but cannot be safely removed or segregated, dispose of all the debris as if it is asbestos containing material.
When feasible, segregate and place asbestos containing material into leak tight wrapping. If the volume of the material precludes use of leak proof wrapping, continue to wet the material and use heavy lifting equipment to place the asbestos containing material into waiting dump trucks. Whenever possible, use a plastic liner in the bottom of the bed of the dump truck to minimize the leakage of contaminated water from the truck. If the asbestos containing material has been further broken up during the loading process, wet it down again after it is loaded into the truck.
Cover the dump truck with a tarp, sealing it so that debris and dust cannot be released during transport.
Placard (with a large sign) each dump truck as it is being loaded and unloaded with asbestos containing building materials. The placard should read:
"DANGER, ASBESTOS DUST HAZARD, CANCER AND LUNG DISEASE HAZARD, Authorized Personnel Only"
Transport the asbestos containing material to a landfill permitted to receive asbestos. Contact the Division of Solid Waste Management at 1-888-891-TDEC for a list of approved landfills.
Waste shipment records must be maintained by the owner or operator of the demolition activity and the owner and/or operator of the landfill.
If you have any questions about this guidance, please contact the Division of Air Pollution Control, Asbestos NESHAP Program, at asbestos.NESHAP.Program@tn.gov or 615-532-0554.
The following Enviromental Field Offices (EFO) Regions have approval to accept Friable Asbestos.
|Bradley County LF
|Meadow Branch LF
|Rhea County LF
|Cedar Ridge LF
|West Camden Sanitary LF
|Northwest TN Disposal
|Jackson-Madison Co. LF
|Iris Glen Environmental Ctr.
|Ecosafe Systems, LLC
|Charlie Appleby, Jr.
|Chestnut Ridge LF
|Matlock Bend LF
|Volunteer Regional LF
|Lakeway Sanitation & Recycling
|Middle Point LF
|Bi-County Solid Waste