TRB Summer Conference June 15-18, 2008 Baltimore, Maryland DOT Practices for the Identification and Abatement of Asbestos in Bridges - TxDOT

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1 TRB Summer Conference June 15-18, 2008 Baltimore, Maryland DOT Practices for the Identification and Abatement of Asbestos in Bridges - TxDOT Rodney Concienne, P.G. Terry Dempsey, P.G. Pollution Prevention & Abatement Branch Texas Department of Transportation 1

2 DOT Practices for the Identification and Abatement of Asbestos in Bridges TxDOT Overview Problem Discovery Addressing the Issues Programmatic Approaches Process Developed Where Asbestos is Found 2

3 DOT Practices for the Identification and Abatement of Asbestos in Bridges - TxDOT Problem Discovery Fall 2005, DSHS notified TxDOT of noncompliance with NESHAP asbestos requirements for a scheduled bridge demolition project. DSHS -Texas Department of State Health Services (DSHS) administers the Texas Asbestos Health Protection Rules (TAHPR). TAHPR adopts EPA Asbestos NESHAP by reference. 3

4 DOT Practices for the Identification and Abatement of Asbestos in Bridges - TxDOT Addressing the Issues Dec 2005, TxDOT issued an interim asbestos guidance for bridge work. Jan Dec 2006, TxDOT & DSHS negotiations and guidance development. Jan 2007, TxDOT issued final comprehensive asbestos guidance for construction projects. 4

5 DOT Practices for the Identification and Abatement of Asbestos in Bridges TxDOT Programmatic Approaches NESHAP does not offer much flexibility. Approved programmatic approaches Include multiple bridges with no Asbestos Containing Materials (ACM) on one notification. Flexibility with start dates for multiple bridge demolition projects with no ACM. Certain activities were exempt from NESHAP. 5

6 DOT Practices for the Identification and Abatement of Asbestos in Bridges TxDOT Programmatic Approaches Activities Generally Exempted: Work on culverts or pipes constructed entirely of concrete or metal do not require formal inspection or notification. Excluded Some Routine Maintenance Activities: Asphalt overlays or seal coats for pavement on a bridge. Repair/change-out of guardrail, barrier walls, or fencing consisting of uncoated concrete, steel or wood. Addition of conduits/piping and lighting. Sealing of cracks. Small deck repairs affecting only concrete, asphalt, or steel. Modification of drainage openings. Change-outs of reflectors or signs. 6

7 DOT Practices for the Identification and Abatement of Asbestos in Bridges - TxDOT General Process Developed Identify activities that might disturb potential ACM. Inspect and test to determine whether ACM are present. Notify DSHS for projects that include demolition, or that disturb ACM above asbestos thresholds. Abate (remove) confirmed ACM using trained asbestos contractors. 7

8 Asbestos and Bridge Maintenance Identify Activities Activities that might disturb potential ACM: Demolition activities - bridge replacements and other projects that would remove a significant portion of the structure (most common). Renovation activities - work that could disturb potential ACM. 8

9 Asbestos Procedures for Bridges Inspection Have the structure inspected for potential ACM prior to the project. Generally use licensed asbestos inspector to perform the inspection, sample and analyze suspect materials, estimate extent of ACM, and provide report. TxDOT may use in-house personnel for initial inspection if properly trained in identifying ACM. Verify with Point Count Method for samples w/ 5% or less ACM. 9

10 Asbestos Procedures for Bridges Notification DSHS notification is required for all demolition projects and some renovations Must use the official DSHS Demolition/ Renovation Notification Form. Notification must be postmarked at least 10 working days prior to demolition start date (cannot be faxed or ed). Amend the notification when project start/stop dates change. 10

11 Asbestos Procedures for Bridges Notification - Demolition Demolition - submit DSHS Notification Form for all bridge demolitions, even when asbestos is not present. For construction projects requiring demolition of multiple bridges, and asbestos is not present, a single notification may be filed for the entire project. May use project start/stop dates rather than start/stop dates for individual bridges within the project. 11

12 Asbestos Procedures for Bridges Notification Renovation/Abatement Renovation DSHS notification required only when the activity will disturb ACM above NESHAP thresholds. NESHAP Threshold Quantities RACM equals or exceeds: 260 linear feet for pipes, 160 sq feet for other components (such as coatings). 35 cu. feet of removed material which could not be measured previously 12

13 Asbestos and Bridge Maintenance When is abatement required? Abate when ACM might be disturbed by project activities: Abate using a licensed abatement contractor prior to project activities whenever possible. Perform abatement separately from the prime contract when possible, if can t abate prior. For work disturbing ACM, use an asbestos consultant to provide project management and guidance. 13

14 Asbestos Procedures for Bridges DSHS Fee Payments DSHS will invoice TxDOT an asbestos notification fee, based on the amount of asbestos involved. TxDOT finance division sent instructions to district accounting staff explaining payment procedures (designate single point of contact). 14

15 Asbestos Procedures for Bridges TxDOT NESHAP Activity January 2006 April 2008: 86 Projects required DSHS notification. 55 of 86 demolition only. 12 of 86 ACM abatement. 19 of 86 ACM abatement and demolition. 15

16 DOT Practices for the Identification and Abatement of Asbestos in Bridges - TxDOT Where Asbestos is Found ACM on TxDOT Structures Approximately 12% of materials tested had ACM. Occurrences from 451 bridge inspections: Concrete Coatings 47/193 Mastics/Caulks/Adhesives 9/118 Utility Attachments/Pipes 5/8 Roofing Felt 4/86 Paint on Timber 2/5 16

17 Asbestos and Bridge Maintenance Asbestos-Containing Materials Frequency from 451 bridge inspections (continued): Exp Joint Filler / Asphalt Board 2/44 Coatings on Steel Girders 2/58 Pads under Rail Posts 1/5 Coatings on Steel Rail 1/36 Joint Sealant 1/52 Neoprene Bearings 0/36 17

18 Examples: Utility Attachment / Pipes 5/8 ACM 18

19 Asphaltic roofing felt or fiberboard bearing material 4/86 acm 19

20 Roofing felt pile cap on timber bridge 4/86 ACM 20

21 Isolator Pad on Bridge Rail 1/5 ACM 21

22 Coatings on steel rail 1/36 ACM 22

23 Coating on timber bridge 2/5 ACM 23

24 Mastic used to adhere flashing 9/118 ACM 24

25 Coating on Concrete 47/193 ACM 25

26 Abatement for coating on concrete walls / rails 26

27 DOT Practices for the Identification and Abatement of Asbestos in Bridges TxDOT Questions Rodney Concienne, P.G. Manager, Pollution Prevention & Abatement Branch; Texas Department of Transportation Ph: (512) TRB Summer Conference June 15-18, 2008 Baltimore, Maryland 27

SUBPART 56-5 PHASE IA: ASBESTOS SURVEY PLANNING AND DESIGN

SUBPART 56-5 PHASE IA: ASBESTOS SURVEY PLANNING AND DESIGN 56-5.1 Asbestos Survey Requirements for Building/Structure Demolition, Renovation, Remodeling and Repair (a) (b) Asbestos Survey Required. An