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  • Asbestos NESHAP

    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, the EPA established National Emissions Standards for Hazardous Air Pollutants (NESHAP) to protect the public.  Asbestos was one of the first hazardous air pollutants regulated under Section 112.  On March 31, 1971, the EPA identified asbestos as a hazardous pollutant, and on April 6, 1973, the EPA first promulgated the Asbestos NESHAP in 40 CFR Part 61.

    The Pima County Department of Environmental Quality (PDEQ) administers their asbestos program under Title 17 of the Pima County Code (PCC).  The Asbestos NESHAP has been adopted by reference in PCC Section 17.16.530.  The program's intent is to minimize the release of asbestos-containing material.  Accordingly, the Asbestos NESHAP specifies work practices to be followed during demolitions and renovations of all structures, installations, and buildings (excluding residential buildings that have four or fewer dwelling units).  In addition, the regulations require the owner of the building and/or the operator to notify PDEQ before any demolition, or before renovations of buildings that contain a certain threshold amount of asbestos or asbestos containing materials. 

    Who needs to submit a Notification and apply for an Asbestos NESHAP Activity Permit?

    Find out if your work requires an Asbestos NESHAP Activity Permit and Notification submittal by going to the Asbestos NESHAP Activity Permit and Notification Applicability Guidance in the tab below.

    How to apply for an Asbestos NESHAP Activity Permit and Submit Notification

    If your work requires an Asbestos NESHAP Activity Permit and Notification submittal, you can apply for the permit and submit notification online, by email, in person, or by mail.  Payment may be cash, check or credit card. 

    Note:  Separate applications and fees are required for Renovation versus Demolition projects.

    ASBESTOS NESHAP START DATE CALENDAR - PDEQ makes this useful tool available to assist PDEQ staff and the regulated community with determining the correct "Start Date" for your project.  Find the workday, including holidays, your notification is either postmarked or submitted to PDEQ.  Look at that day on the calendar and the "Start Date" is clearly identified for you to put on your notification.

    How much does the permit cost?

    Permit fees are based on the type of work being conducted and can be determined from the Fee Schedule.  Separate fees are required for renovation and demolition permits.

    What are the Asbestos NESHAP Rules?

    Federal rules for Asbestos NESHAP are provided in the Standards & Definitions.

    FAQs and Additional Information

    For answers to frequently asked questions, and additional information:
            Understanding the Asbestos NESHAP
            OSHA Standards
            Asbestos in the Home

    Report a Complaint

    If you are observing activities which may be in violation of the Asbestos NESHAP, you may File a Complaint with PDEQ.

    The Pima County Department of Environmental Quality (PDEQ) has delegated authority from the U.S. EPA to enforce the Asbestos NESHAP within Pima County, excluding Tribal Lands.  The Asbestos NESHAP requires submittal of Notification to PDEQ of subject Demolition and Renovation activities.  Additionally, the Pima County Code requires that an Asbestos NESHAP Activity Permit be obtained from PDEQ for such subject Demolition and Renovation activities.  PDEQ has combined these requirements in the Asbestos NESHAP Notification & Activity Permit Application.

    Please review PDEQ’s Understanding the Asbestos NESHAP for assistance in answering the following questions. The answers to the following questions will determine if submitting an Asbestos NESHAP Notification Activity Permit Application is required.

    • Is the facility regulated by the Asbestos NESHAP?
    • Is the activity a demolition?
    • Does the renovation activity include stripping or removal of RACM from a facility in amounts that meet or exceed the thresholds of:
      1. 160 square feet of facility components, or;
      2. 260 linear feet of pipes, or;
      3. 35 cubic feet of facility components where the length or area could not be measured previously?
    If the facility is not regulated by the Asbestos NESHAP, then an Asbestos NESHAP Notification Activity Permit Application is not required.
     

    If the facility is regulated by the Asbestos NESHAP, and demolition will occur, then an Asbestos NESHAP Notification Activity Permit Application is required.

    If the facility is regulated by the Asbestos NESHAP, and renovation that includes stripping or removal of threshold amounts of RACM will occur, then an Asbestos NESHAP Notification Activity Permit Application is required.

    If you would like to print out a checklist to use in making your applicability determination click the following link: Asbestos NESHAP Applicability Checklist Note: This checklist is for guidance only, and not required for submittal to PDEQ.

    If your work requires an Asbestos NESHAP Notification & Activity Permit, you can apply for the permit by Email, in person, or by mail.  Cash, check, debit/credit Mastercard and Visa are accepted forms of payment. 

    Apply and Pay Online for an Asbestos NESHAP Activity Permit and submit Notification

    To apply and pay online, simply complete the application in the link below, upload the Asbestos NESHAP Notification form, and enter credit card information (Visa, Mastercard).  You will print and save your permit and receipt at your convenience. 

    Note: The Asbestos NESHAP Activity Permit does not fulfill the Notification requirement of the Federal Asbestos NESHAP notification of Renovation and Demolition. You must submit a completed Notification form online, by email to Air.Notices@pima.gov , mail, or hand-delivery to begin the required minimum 10-working day notification period in advance of demolition or renovation activity. 

    Online Permitting Portal (See DEQ Create an Application) https://permits.pima.gov/acaprod/

    PDF instructions for online application process

    Apply by Email for an Asbestos NESHAP Activity Permit and Submit Notification

    To apply by Email, you may print the notification and activity permit application.

    Complete the application and scan it as an Adobe PDF file.  Attach it to your Email and submit it to Air.Notices@pima.gov identified at the top of the PDEQ Asbestos NESHAP Notification and Activity Permit application form.

    PDEQ will call you when the application is received, and you may provide payment by any of the following methods:

    • Provide payment by phone using a credit card by calling (520) 724-7400
    • Pay in person at 33 N. Stone Avenue, Suite 700 (7th Floor) using cash, check or credit card
    • Pay by mailing a check to the address shown above

    PDEQ will Email you your permit if a valid email address is provided, otherwise your permit and receipt will be mailed to you.

    Apply In Person for an Asbestos NESHAP Activity Permit and Submit Notification

    To apply in person, you may print the notification and activity permit application and complete it prior to visiting our office.  

    For applications submitted in person, payment may be made at the front desk and the permit will be issued immediately.  PDEQ is located at 33 N. Stone Avenue (southwest corner of Stone Avenue & Pennington Street), 7th Floor.  Payment can be made by credit card (Mastercard or Visa), cash or check.

    Apply by Mail for an Asbestos NESHAP Activity Permit and Submit Notification

    To apply by mail, you may print the notification and activity permit application.

    Complete the application and mail to:

    PDEQ
    33 N. Stone Avenue
    Suite 700
    Tucson, AZ  85701

    PDEQ will call you when the application is received, and you may provide payment by any of the following methods:

    • Provide payment by phone using a credit card by calling (520) 724-7400
    • Pay in person at 33 N. Stone Avenue, Suite 700 (7th Floor) using cash, check or credit card
    • Pay by mailing a check to the address shown above

    PDEQ will email you your permit if a valid email address is provided, otherwise your permit and receipt will be mailed to you.

    Fee Schedule for Asbestos NESHAP Activity Permits

    The Fee Schedule for Asbestos NESHAP Activity Permits is based on the type of work being conducted:

    • Separate applications are required for Renovation versus Demolition projects.
    • Separate fees are required for Renovation versus Demolition permits.

    PCC Table 17.12.540
    NESHAP Activity Permit Fee Schedule
    Demolition $420
    Renovation $420
    Cash, Check, Debit/Credit Mastercard or Visa Accepted 

    Note:  A Demolition project may require abatement of Regulated Asbestos-Containing Material (RACM) prior to removing load-supporting structural members of a facility and would require only a single application and a single fee for Demolition.

    Alternatively, the owner(s)/operator(s) may choose to submit a separate application and fee for Renovation to abate the RACM.

    Stipping or removal of RACM from a facility in a location that will not be demolished requires a separate application and fee for Renovation.
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    Department of Environmental Quality

    33 N. Stone Ave., Suite 700
    Tucson, AZ 85701

    Phone: (520) 724-7400
    Fax: (520) 838-7432


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