TDEC Air Pollution Control Live Fire Training Requirements

In addition to any local air quality or pollution control authority requirements, the rules of the Tennessee Department of Environment and Conservation’s Division of Air Pollution Control, Chapter 1200-3-4, Open Burning, prohibit open burning except as specifically exempted by Rule 1200-3-4-.04 Exceptions to Prohibition. Section (1)(c) of that rule specifically addresses fires set for training purposes at fire training academies or for local fire department training.

It is important to note that all structures used for live fire training are subject to the Federal asbestos requirements found in 40 CFR Part 61, Subpart M: National Emission Standards for Hazardous Air Pollutants for Asbestos. Subsequently, all structures used for live fire training must be thoroughly inspected for asbestos, and if asbestos is found, the removal process must be done in accordance with the Federal requirements.

When a structure is considered for live fire training, the Division of Air Pollution Control recommends that the Fire Control Agency complete the following steps in the order that they appear:

1. Complete a thorough asbestos inspection on the acquired structure.
2. If fire training will proceed, submit the intent to demolish notification to the Division. Remember, the notification must be submitted no fewer than ten (10) working days prior to beginning demolition activities regardless of if asbestos is present. Notification forms (CN-1055) are available from TDEC’s internet site and may be submitted electronically to Asbestos.NESHAP.Program@tn.gov. Please note that this notification is separate from, and in addition to, the certification requirement found in item #5 of this list.
3. Remove all asbestos containing material in accordance with Federal, State, and Local requirements. There should be at least one on-site representative, trained in the provisions of Subpart M and the means of complying with it, present during the removal activities.
4. Remove all vinyl siding, carpet, vinyl flooring, asphalt roofing materials, and any other materials expressly prohibited in Rule 1200-03-04-.03. Note that incidental plastic or rubber materials which are an integral part of a structure used for fire training, such as plastic plumbing, fixtures, and conduit; electrical wiring insulation, connections, switches, and fixtures; interior trim; glues and resins in manufactured wood products; and vinyl window and door frames do not have to be removed.
5. Unless conducted at a recognized fire training academy, submit the certification required by Rule 1200-03-04-.04(1)(c) to the Division of Air Pollution Control at the appropriate regional TDEC Field Office at least ten (10) working days prior to commencing the burn. Division of Air Pollution Control staff will contact you to schedule a site visit after your certification has been received. The proposed structure will be evaluated for compliance with the requirements of the Rule. The written statement must certify:
   1. The open burning is being conducted solely for fire training purposes.
   2. All vinyl siding, carpet, vinyl flooring, asphalt roofing materials, and any other materials expressly prohibited in Tennessee Air Pollution Control Regulations (TAPCR) 1200-03-04-.03, have been removed. However, the provisions of TAPCR 1200-03-04-.03(4) as it pertains solely to “other rubber products” and “other plastics” are waived for incidental plastic or rubber materials which are an integral part of a structure used for fire training, such as plastic plumbing, fixtures, and conduit; electrical wiring insulation, connections, switches, and fixtures; interior trim; glues and resins in manufactured wood products; and vinyl window and door frames. Sheathing, decking, roofing, exterior siding and trim, and structural load-bearing members whose composition is primarily rubber or plastics are not considered incidental.
   3. All regulated asbestos containing materials have been removed in accordance with TAPCR 1200-03-11-.02.
   4. A traffic hazard will not be caused by the air contaminants generated by the fire training.

For additional resources, go to https://www.tn.gov/environment/program-areas/apc-air-pollution-control-home.html.

The following links provide information that fire control persons may find useful in this process:

TDEC APC Open Burning Regulations – Fire training regulations.

TDEC APC Fire Training Webpage – Overview of acquired structure live fire training requirements.

TDEC APC Asbestos Information – Overview of asbestos and the required forms.