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Information from DEQ on requirements to do training burns in relation to
Asbestos Air Quality regulations
See DEQ Air
Quality web site for more information and contact information.
YOU HAVE TO GET A
DEQ PERMIT BEFORE DOING ANY TRAINING BURNS THAT INVOLVE STRUCTURES.
Letter from John Podolinsky (This was handed out at the 2003 MSVFFA
Convention)
Date: June 10, 2003
Subject: Intentional Burning of Facilities and Asbestos
To: Fire Fighting Officials
From: John Podolinsky, State of Montana, Department of Environmental Quality,
Asbestos Control Program
This letter concerns the intentional burning of facilities and
asbestos-containing materials found
in many facilities. Asbestos is a hazardous air pollutant and exposure to
asbestos can cause
asbestos-related illnesses. As such, it is regulated by the Environmental
Protection Agency
(EPA, 40 CFR Part 61, Subpart M), the Occupational Health & Safety
Administration (OSHA,
29 CFR 1910.1001 & 29 CFR 1926.1101), and the State of Montana. According to
EPA’s
National Emission Standards for Hazardous Air Pollutants (NESHAP), if a facility
is demolished
by intentional burning, all asbestos-containing material including non-friable
asbestos-containing
material must be removed in accordance with asbestos and firefighter training
regulations before
burning. Furthermore, the State of Montana must be notified of the demolition by
intentional
burning and that a Firefighter Training Open Burn Permit must be obtained.
Prior to intentionally burning a facility, the owner or operator (the
operator would be the fire
department or fire official in charge of the burn) must have the facility
inspected for asbestos.
The person inspecting for asbestos must be properly trained to conduct asbestos
inspections.
Furthermore, the inspector must be accredited, or licensed, by the State of
Montana’s Asbestos
Control Program as an asbestos inspector. The inspection must identify any
asbestos-containing
materials in and on the facility. Asbestos-containing materials may include pipe
and boiler
insulation, ceiling and wall materials, building insulation, vermiculite, floor
coverings such as
vinyl tile and linoleum and their associated mastics, roofing materials, siding
materials,
fireproofing materials, and other materials. All asbestos-containing materials
must be removed
from the facility prior to the intentional burn. Depending on the type,
location, and quantity of
asbestos-containing material, its removal must be permitted through the Asbestos
Control
Program. Additionally, only asbestos abatement personnel accredited by the
Asbestos Control
Program who follow proper asbestos abatement, transportation, and disposal
procedures can
conduct asbestos removal activities.
The reason for removing all asbestos-containing material prior to a burn is
to prevent the
emission or release of asbestos fibers. In many materials the asbestos fibers
might be bound
within a matrix such as asphalt, vinyl, or cement; however, when the material is
burned the
matrix will generally burn and asbestos fibers may be released. This presents a
hazard not only
to the public, but also to you as a firefighter.
Regardless of whether asbestos is found in or on the facility, notification
of the demolition by
intentional burning is required. This notification must be made at least ten
(10) days prior to the
burn. Notifications of demolitions and applications for asbestos abatement
project permits are
made to the Asbestos Control Program using the Montana Asbestos Abatement
Project Permit
Application And NESHAP Demolition/Renovation Notification form enclosed with
this letter.
In many cases, residential dwellings are intentionally burned by fire
departments for fire training
exercises. Be aware that these facilities are regulated because the structure is
being used for
institutional purposes and considered an institutional building under the NESHAP
definition of
"facility." Enclosed is an EPA letter dated December 3, 1992, that provides
interpretive
information concerning intentional burns and asbestos.
For your reference I have enclosed a copy of the NESHAP regulation that
governs facility
demolition and renovation activities (40 CFR Part 61, Subpart M). I have marked
sections of the
regulation, which pertain to demolition by intentional burning. Also, I have
enclosed a list of
companies who do asbestos-related work in Montana; they may assist you with
consulting,
abatement, and testing services. If you would like to learn more about asbestos
regulations, how
to become accredited as an asbestos inspector, or if you have any other asbestos
questions, please
contact me or Pierre Amicucci at the Asbestos Control Program at (406) 444-3490
or
www.deq.state.mt.us/pcd/awm/acp/.
Lastly, intentional burns are also regulated by the Department of
Environmental Quality under
the Administrative Rules of Montana (ARM) Title 17, Chapter 8, Subchapter 6 -
Open Burning.
Please note that a Firefighter Training Open Burn Permit is required prior to
conducting
intentional burns. For more information regarding the open burning regulations,
contact David
Aguirre at (406) 444-3490.
Reference links:
NESHAP
40 CFR 61 - Subpart M
http://www.epa.gov/asbestos/200261CFR.pdf
http://www.epa.gov/asbestos/200261CFR.txt
NESHAP Notification Form
http://www.deq.state.mt.us/Asbestos/Forms/ACP_NESHAP_Permit_App.pdf
Contractors Consultants Laboratories
http://www.deq.state.mt.us/Asbestos/Forms/ACP_Cons_Cont_Lab_lst.pdf
Asbestos Control Program Description
http://www.deq.state.mt.us/Asbestos/index.asp
Open Burning Regulations
http://www.deq.state.mt.us/dir/legal/Chapters/CH08-06.PDF
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Montana State Volunteer Firefighters Association
