Mendocino County Air Quality Management District

Demolition or Renovation?

Demolition
The primary distinction of a demolition project is the removal of a load-bearing member of the structure, installation, or building together with any related handling operations. Additionally, the intentional burning of a building (such as fire-fighting agency training burns) or the separation of a structure from its foundation prior to relocation is considered a demolition.

Renovation
If no load-bearing members will be removed, the project would generally be classified as a Renovation for NESHAP purposes.d

The Asbestos NESHAP stipulates the following requirements:

Asbestos Inspection/Survey: All of the potentially-asbestos-containing (“suspect”) material in the structure to be demolished must be tested/surveyed for asbestos content. Within District boundaries, this survey must be conducted by a Cal-OSHA Certified Asbestos Consultant, who will provide a report of the results.

Notification Submission. Must be submitted 10-working-days prior to the commencement of any regulated asbestos abatement:
Asbestos Notification: A completed and signed Asbestos Notification Form must be submitted.
Asbestos Survey: Provide a copy of the asbestos survey report

Asbestos Containing Material Abatement: Before the demolition may commence, all of the regulated asbestos abatement must be completed by a state-certified asbestos abatement contractor.
If there is no regulated asbestos (RACM) to be abated, only the demolition activity will be subject to the 10-working-day waiting period starting from the date of notification.

The Asbestos NESHAP provides a residential exclusion for the demolition (partial or otherwise) of a residence. For the purpose of this exclusion, a “residence” is defined as ONE residential structure consisting of four or fewer living units under one roof. This exclusion exempts a project from the Asbestos NESHAP requirements*, provided that ALL of the following are true:

The project involves ONE residence as originally constructed (e.g, multiple manufactured homes joined together to form a single habitation are considered multiple residences)
The residence has not been used for commercial purposes (e.g., farm-worker housing, clergy housing, or homes under mobile home park ownership)
The operator (including the owner and/or the demolition contractor) will not disturb another human-habitable structure (past or present) within the site, generally determined as the vicinity of a city block
The residence is not on mixed-use property
The intention of the project is to retain the residence as — or replace the residence with — one residence OR to leave the land vacant AND
Not subdivide the property AND
Not repurpose the land for a use other than one residence
The residence cannot otherwise be determined to be a regulated facility
*Although NESHAP requirements may not apply, other regulatory agencies may have other requirements.

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