National Asbestos Meeting Denver, CO June 23 & 24, 2011

Transcription

1 National Asbestos Meeting Denver, CO June 23 & 24, 2011 Everett Bishop Office of Enforcement and Compliance Assurance Office of Compliance U.S. EPA 7/19/ U.S. Environmental Protection Agency

2 Asbestos NESHAP Issues Pipe & Pipeline Renovation Operations Recycling Asbestos-Containing Materials Intentional Burning Floor Tile Municipal Demolitions of Homes 2

3 Pipes & Pipelines Are Asbestos-containing (A/C) Pipes and Pipelines Covered with ACM potentially subject to the Asbestos NESHAP? Yes. They are: a facility component as defined in the regulation. a renovation operation. >260 linear feet becomes friable. 3

4 Pipes & Pipelines In 2002 (liquid) and 2005 (natural gas), the Pipeline and Hazardous Materials Safety Administration (PHMSA/DOT) required pipeline owners to conduct detailed assessments of their pipelines. Based on the assessments, many pipelines are identified to be repaired or replaced. Have you seen an increase in Notifications? 4

5 Pipes & Pipelines Many of America s water and wastewater collection systems (pipelines) use A/C pipe. 300K to 600K miles of A/C pipe is estimated to be in use. Some may be nearing the end of its operation lifecycle. Counties and municipalities seek costeffective methods to replace the A/C pipe. 5

6 Pipes & Pipelines There are a variety of replacement methods. Some methods are not consistent with the Asbestos NESHAP requirements. Pipe Bursting is one in-situ replacement method. U.S. Environmental Protection Agency 6

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8 Pipes & Pipelines Based on our understanding of the method as currently practiced, the pulverized A/C pipe is left in the ground. 40 CFR (c)(1) states: Remove all RACM from a facility being demolished or renovated before any activity begins that would break up, dislodge or similarly disturb the material... 8

9 Recycling Asbestos-Containing Materials In the past several years, petroleum-based waste products are increasingly being evaluated for economic viability for recycling. Asbestos-containing asphalt shingles is an example. Asphalt shingles in many cases originate from single-family homes, which are not subject to the asbestos NESHAP regulation. 9

10 Recycling Asbestos-Containing Materials Most removed shingles are taken to a C&D landfill or other appropriate landfill as required under state solid/hazardous waste regulations. Recyclers may look to remove the shingles from the landfill waste stream for recycling. One method of recycling shingles is grinding the shingles into a smaller, uniform size, melt the material and then reuse it, i.e. asphalt surfacing for roads. 10

11 Recycling Asbestos-Containing Materials For shingles that originate from single family homes as part of regular household maintenance, the Asbestos NESHAP does not apply. What can be done so that these shingles do not become friable? Clean Air Act Title V Operating Permits may offer a solution. 11

12 Recycling Asbestos-Containing Materials Some states require the grinding operation to obtain a Title V Operating Permit. One of the conditions is that ACM cannot be placed into the grinder. This requires the operator to test each batch of material for ACM. 12

13 Intentional Burning Single family homes on Tribal land or in rural communities are sometimes demolished by burning. In many instances, these are not Fire Department training exercises. The burning of these single family homes are not subject to the asbestos NESHAP. 13

14 Intentional Burning Is subject to the Asbestos NESHAP: When a structure is intentionally burned for the purpose of live fire training purposes. When multiple (more than one) small residential buildings are on the same site and under control by the same owner or operator. When the residential structures are demolished as part of a commercial or public project. 14

15 Intentional Burning See Asbestos NESHAP Notice of Clarification (Federal Register: July 28, 1995, Volume 60, Number 145). See 40 CFR (c) (10) If a facility is demolished by intentional burning, all RACM including Category I and Category II nonfriable ACM must be removed in accordance with the NESHAP before burning. 15

16 Floor Tile Category I materials are considered RACM only when they "will be or have been subjected to sanding, grinding, cutting, or abrading", they are in "poor condition" and "friable", or the structure in which they are located will be demolished by burning. Floor tile is considered a Category I material. 16

17 Floor Tile Depending upon the condition of the floor tile and the method of demolition or renovation can cause the floor tile to become RACM. 160 square feet of RACM creates a NESHAP regulated operation. 17

18 Floor Tile Some typical removal techniques: Amended water/solvents Dry Ice Infrared Heat Shot blasters Demolition in Place 18

19 Floor Tile See Guide to Normal Demolition Practices under the Asbestos NESHAP, Sept See Applicability Determination Index. 19

20 Questions? 20