|The purpose of this document is to outline the environmental requirements for fire training exercises. Structures demolished by intentional burning are subject to the asbestos regulations, National Emission Standards for Hazardous Air Pollutants (NESHAP) found in 40 Code of Federal Regulations (CFR) Part 61 Subpart M. These are adopted in Title 129 – Nebraska Air Quality Regulations. State, Local, Industrial and Rural Fire departments who burn residential structures or buildings for fire training purposes must comply with all Air Quality Regulations. Guidance documents and forms for asbestos can be found on the Department website at: http://dee.ne.gov. The following is a summary of the requirements (also see Figure 1, Fire Training Responsibility Flow Diagram).
Fire Department Responsibilities
When the fire department takes control of a structure, they are required to:
- Have a thorough inspection for asbestos conducted by a licensed inspector or obtain a copy of final inspection report indicating there is no asbestos present.
- Submit a completed Nebraska Fire Training Demolition Notification to the Nebraska Department of Environment and Energy (NDEE), Air Quality Division at least 10 working days before burning.
- If asbestos is present after taking control of the structure, all Regulated Asbestos Containing Material (RACM) must be removed prior to fire training.
- Meet all requirements of the Nebraska State Fire Marshal. Contact them at (402) 471-9471.
Property Owner Responsibilities
Following the fire training exercise, properly dispose of ash and residue at a Municipal Solid Waste Landfill (MSW landfill).
Note: Residential homeowners (four or less dwellings) are not subject to the NESHAP and can remove asbestos prior to the fire departments taking control of the structure. However, the Department encourages proper procedures and protective equipment be used.
- Taking possession: The fire department becomes the operator for NESHAP purposes when they take possession of a building and therefore become subject to the asbestos requirements. For example, an agreement with the property owner or other authority, such as from the city for abandoned properties, would qualify as transfer of authority to the fire department.
- Inspections: To meet the "thorough inspection" requirement a licensed inspector must identify all suspected Asbestos-Containing Materials (ACM). Sample the ACM and send out for laboratory analysis or all suspected materials must be assumed to contain asbestos, and be removed. Suspect asbestos-containing materials include floor tile, linoleum, pipe and boiler insulation, heat duct wrap and joint tape, cementitious siding and roofing, asphalt based roofing, ceiling tiles, joint compound, sprayed-on-texturing, etc. See Figure 2 for schematic examples.
- Notification: Fire departments must submit a "Nebraska Fire Training Demolition Notification" to NDEE at least 10 working days prior to the training exercise or if asbestos is present, prior to any removal activity that would break up, dislodge or disturb the asbestos material. Working days means Monday through Friday and includes any holidays that fall on any of the days Monday through Friday; weekend days are excluded. The notification can be mailed, express delivered or hand delivered to the NDEE. This demolition notification does not combine with, supersede, or replace any or all of those permit documents required by the State Fire Marshal's Office or the State Department of Health and Human Services asbestos requirements.
- When a structure is being demolished by intentional burning, all RACM must be removed including non-friable ACM. The Nebraska Department of Health and Human Services regulates asbestos removal projects. Contact them at (402) 471-0549 for further questions and guidance.
- Ash & Residue Disposal: Once a structure has been destroyed by fire, the ashes and residue must be managed properly according to the Title 132 – Integrated Waste Management Regulations. Only brick, concrete block and concrete rubble may be left on the site or used for beneficial fill. Any ashes and remaining structure residue (wood, shingles, metal, furniture, plastic, glass, tile) must be cleaned up and hauled to a permitted MSW landfill for disposal. (Also see Permitted Facility List in the Integrated Waste Management Program and "Construction and Demolition Waste in Nebraska" Guidance Document Publication on the NDEE Web Page.)
Why the requirements?
It is important to follow these guidelines in order to ensure that the public health and the welfare of the fire fighters conducting the training are protected from asbestos exposure. When some types of asbestos are burned, its matrix is broken down and fibers are more easily released causing an inhalation hazard. Asbestos fibers will remain in the air almost indefinitely and can travel long distances. For more information regarding asbestos see the General Asbestos Information guidance.
Note: other State of Nebraska regulations may apply. The Nebraska Department of Health & Human Services Asbestos program has asbestos regulations and licensure requirements for removing and working with asbestos in Nebraska. Contact them at (402) 471-0549.
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Nebraska Department of Environment and Energy
P.O. Box 98922
Lincoln, NE 68509-8922
To view this, and other information related to our agency, visit our web site at http://dee.ne.gov.