Be Prepared For Your Next Training Burn
Information from DEQ on requirements to do training burns in relation to Asbestos Air Quality regulations can be found on their website.
Department of Environmental Quality
Waste and Underground Tank Management Bureau Asbestos Control Program
1520 E. Sixth Avenue
P.O. Box 200901
Helena, MT 59620-0901
Office Phone: 406-444-5300
YOU MUST GET A DEQ PERMIT AND NOTIFY EPA 10 DAYS 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 click here.
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.