Demolition & Renovation

Renovation

Renovation or Demolition?

Renovation

For NESHAP purposes, a Renovation project involves the removal of asbestos-containing materials for the purpose of performing renovations within a structure.

Demolition

If any load-bearing members of a structure or large component will be removed in the scope of a project, the NESHAP requirements for Demolition would apply.

Renovation Project Requirements

The NESHAP defines a regulated asbestos renovation project as one which will disturb Regulated Asbestos Containing Material (RACM) which exceeds any of these quantities:

>259 Linear Feet >159 Square Feet >34 Cubic Feet
This applies to linear material, such as pipe or pipe wrap This applies to flat/surface building materials such as flooring or drywall This applies to piled materials, such as those resulting from a ceiling collapse

If the renovation project does not meet or exceed these thresholds, please submit a Courtesy Notification (see below) for District review. Otherwise, the following Asbestos NESHAP requirements will apply:

  • Asbestos Inspection/Survey:   To determine the quantities of asbestos-containing material to be removed in the project, an Asbestos Survey should be conducted. This survey must be conducted by a Cal-OSHA Certified Asbestos Consultant, who will provide a report of the results. Alternatively, if the operator is opting to treat all of the material as RACM and will notify as such, the survey may be bypassed.
  • Notification Submission: To be submitted 10-working-days prior to the commencement of abatement work.
    • Asbestos Notification: A completed and signed Asbestos Notification Form must be submitted.
    • Asbestos Survey: Provide a copy of the asbestos survey report unless all disturbed material will be treated as RACM.
    • Notification Fees: Per Rule 3050, pay the required notification fees -- these may be paid online or via check with the notification materials.  (See "Fee Rule" below)
    • Renovation Permit Release Form: The applicant completes the top portion of the form to include with the notification, and the District will return the signed Release form upon satisfaction of the NESHAP requirements.  The municipality who will issue the applicable permit needs to receive this form with the District's approval affixed.  
Fee Rule - Renovation Projects
The fees required by District Rule 3050 are not determined by the structure's size or footprint.
Current Rule

Per Rule 3050, Notification Fees are determined by a tier structure of the Regulated Asbestos Content (RACM) quantities.

The total fee is calculated as the sum of the fees assessed for any regulated asbestos content of each of these categories:
Linear Feet Square Feet Cubic Feet
Linear material, such as pipe and pipe wrap Flat/surface materials such as drywall, flooring, roofing, mastics, etc. Piled material, such as materials piled during a fire suppression
Regulated Renovation Project Fee Tiers of Regulated Asbestos Containing Material (RACM)
See Current Rule for fee amounts
Tier 1* 260-499 Linear Feet 160-499 Square Feet 35-109 Cubic Feet
Tier 2 500-999 Linear Feet 500-999 Square Feet 110-218 Cubic Feet
Tier 3 1,000-2,499 Linear Feet 1,000-2,499 Square Feet 219-547 Cubic Feet
Tier 4 2,500-4,999 Linear Feet 2,500-4,999 Square Feet 548-1,094 Cubic Feet
Tier 5 5,000-9,999 Linear Feet 5,000-9,999 Square Feet 1,095-2,188 Cubic Feet
Maximum Fee Any Regulated Asbestos quantities in excess of Tier 5
*If the RACM amounts are less than the Tier 1 minimum thresholds, the project is exempt from NESHAP requirements. The District should be provided a Courtesy Notification.
Courtesy Notificaton

Renovation projects may be exempt from the NESHAP requirements if:

  1. The total disturbance of all building materials is less than the thresholds above OR
  2. The asbestos survey report conducted by a CAL-OSHA Certified Asbestos Consultant confirms that the RACM quantities do not exceed any of the regulated thresholds OR
  3. The renovation is occurring at a site which qualifies for the Residential Exclusion.

To ensure verification that the project is exempt from the NESHAP requirements, please submit a Courtesy Notification to the District, which includes:

  • The Asbestos Notification Form, which provides the details of the project scope
  • The Asbestos Survey Report (if "option b" above applies to the project) prepared by a Certified Asbestos Consultant.
  • The Renovation Permit Release form. The District will affix the approval upon review of the submitted courtesy notification and return the release. The permitting municipality (city of county) may require this release prior to issuing the applicable permit.

NOTE: No notification fee nor waiting period applies to courtesy notifications.

Where to Send the Notification for Review and Approval

The notification documents can be sent by mail or email.  Please include proof of payment of the notification fees (except for Courtesy Notification) with the submission.  Select the corresponding office for the county where the project is located.

San Joaquin, Stanislaus, or Merced County
Northern Region Office
4800 Enterprise Way
Modesto, CA 95356
(209) 557-6400
asbestos.north@valleyair.org
Madera, Fresno, or Kings County
Central Region Office
1990 E Gettysburg Ave
Fresno, CA 93726
(559) 230-5950
asbestos.central@valleyair.org
Tulare or Kern* County
Southern Region Office
34946 Flyover Ct
Bakersfield, CA 93308
(661) 392-5500
asbestos.south@valleyair.org
*Valley Air Basin portions