Idaho Solid Waste Association Idaho Snow: Debris from Collapsed Buildings EPA Asbestos Requirements for Demolishing a Building John Pavitt U.S. Environmental Protection Agency Region 10, Alaska Operations Office
Natural Disasters What happens when buildings come down, not from human-planned demolitions but from natural disasters? What EPA regulations still apply?
Snow-Collapsed Buildings
Asbestos Waste from Building Demolitions Overview: Steps required before, during and after the demolition. Building Surveys Notifications Abatement Disposal Reporting Q: Is this waste suitable for disposal in your local landfill?
EPA s Program - Asbestos NESHAP National Emission Standard for Hazardous Air Pollutants 40 CFR, Part 61, Subpart M (Asbestos)
Asbestos Overview What is asbestos? How does EPA regulate it for Demolitions? Requirements for Building Owners Abatement Contractors Waste Haulers Landfill Operators How to Recognize Red Flags/Bad Jobs
What is Asbestos? A: A naturally occurring mineral. B: Used in 3,000+ building materials. C. Breaks up into very fine fibers. D. A known human carcinogen. E. All of the Above
Asbestos Containing Building Materials (ACBM) About 3,500 known products types Some products may still contain asbestos (historic uses may continue, w/ some exceptions). Common examples: pipe insulation, ceiling texture, roofing asphalt, floor tile, cement pipes...
Asbestos Examples Air Cell Insulation (Paper) Pipe Elbow Insulation
Asbestos Examples Cement Boards (Under Tank) Cement Boards (On Building)
Asbestos Examples Shaped Pipe Insulation Textured Paint
Asbestos Examples Sprayed on Wall Panels Sprayed on Ceilings
Examples: Roofing & Pavement Repair Materials
Examples: Roofing Shingles, Asphalt Paper
Examples: Mortar and Concrete
Examples: Ornate Cement Board
Examples: Cement Patching & Caulk
Examples: Drywall & Joint Compound
Any Questions So Far?
EPA s Asbestos Regulations Clean Air Act Air Toxics Regulations Section 112 of CAA Asbestos NESHAP 40 CFR Part 61, Subpart M
EPA Regulates Facilities undergoing: All Demolitions Renovations that Exceed regulatory thresholds Disturb friable materials
EPA Regulates Facility means any institutional, commercial, public, industrial, or residential structure, installation, or building (including any structure, installation, or building containing condominiums or individual dwelling units operated as a residential cooperative, but excluding residential buildings having four or fewer dwelling units); any ship; and any active or inactive waste disposal site.
EPA s Regulations The Way It Should Work For Renovations and Demolitions: Survey Notification Keeping It Wet Handling It Carefully Storing It Transporting It Disposing It Confirming Disposal
Asbestos Surveys An inspection must be conducted by the building owner or operator before a demolition or renovation begins. Inspector certification required The AHERA Asbestos Building Inspector Certification. 24 Hour Course, Annual Refresher
Q: What Size Jobs Are Regulated? Some Jobs Are Too Small
Regulated Amounts (3 Ways to Measure) 160 Square Feet 10 X 16 260 Linear Feet 35 Cubic Feet
Pipelines Coated with Asbestos - More than 260 Linear Ft
Notifications Advance Notice to EPA is Required
Notices Due 10 Days in Advance (Unless it s an Emergency)
Notification Details Project Location Building Description How Much Asbestos is There? When is the Project Starting/Ending? Contractor Name Waste Hauler Landfill Location
Waste Transporter Waste Disposal Site
Work Practices -- Please Be Careful! -- Remove Asbestos Before Demolition
All Regulated Asbestos Must Be Removed Prior to Demolition
Otherwise Asbestos will Contaminate Demo Debris
Hotel Demolition - Asbestos Not Removed Prior to Demo -- Public Exposure Concern
Flooring Waste in Demo Debris Pile - should have been removed in advance
Remove all Regulated Asbestos Before Starting a Demo that will Disturb it.
Fire Training Burns Demolition by Fire All Asbestos Must Be Removed in Advance
Keeping It Wet The waste must be kept wet at all times.
Apply Water When Handling Contaminated Debris
Abatement workers apply water before, during and after removing asbestos. They must wear personal protective equipment.
Contingency plans You may have to bring your own water.
Visible Emissions (Dust) Prohibited
No Water Sprayed on Asbestos Visible Emissions are Prohibited
Transporting/Disposing Asbestos Wastes No dust allowed. Keep it wet at all times.
Good Practices: Water Sprayed
Not So Good Practices: No Water
Careful Handling Do not let asbestos fall to the ground.
Hotel Boiler Room - Untrained Worker Contaminated Area
Lower waste to the ground - do not drop it.
Barriers and signs prevent public access. Visible Emissions Can t Escape the Area
HEPA Air Filter Inside Building
Negative Air Prevents Visible Emissions to Outside Air Air Monitor Outside of Work Area
Glove bags are Leak Tight Containers for Removing Pipe Insulation
These super sack containers are leak-tight.
Seal waste bags before bringing them outside the work area.
Bulk Wastes should be placed in lined, secure containers.
Bulk Waste Placed In Lined Shipping Containers
Storing Waste Storage containers must be secure. This truck can be locked.
Improper Storage These wastes are open to the weather and could be disturbed.
Waste Disposal Responsibilities Waste Generator/Contractor Waste Hauler Landfill
Transporting Asbestos Waste Bulk waste should be covered. Load Cover?
Waste Disposal Requirements for Owner/Contractor/Hauler Asbestos NESHAP 40 CFR Part 61 61.150 Standard for waste disposal for manufacturing, fabricating, demolition, renovation, and spraying operations.
Waste Disposal Owners/Operators/Haulers Discharge no visible emissions Adequately wet asbestos containing waste material (ACWM) Seal it Label it Transport in bulk if the building was unsound, in danger of collapse.
Waste Disposal Requirements for Owners/Operators/Hauler Deposit ACWM as soon as practical at a waste disposal site operated in accordance with the provisions of 61.154. Mark waste hauling vehicles with asbestos warning signs during loading/unloading. Maintain Waste Shipment Records, and provide copy to landfill manager.
Waste Shipment Records
Waste Shipment Record (Discrepancy) # of Containers? Quantity of Asbestos Waste? Signatures?
Requirements for Landfill Asbestos NESHAP 40 CFR Part 61 61.154 Standard for active waste disposal sites. Have a natural barrier to prevent public access, or post warning signs and install fencing.
Requirements for Landfill Either have no visible emissions, from asbestos cell, or At the end of each day, cover ACWM with 6+ inches of compacted, clean soil, or Cover with resinous material to bind dust and control wind erosion
Requirements for Landfill Maintain Waste Shipment Records (WSR) Examine WSR for each incoming load of ACWM and note discrepancies. Uncovered waste Waste not in leak tight containers Report in writing to EPA for significant discrepancies
Disposal Asbestos must go to a licensed landfill.
Asbestos waste is isolated, warning signs are posted, and waste is covered with soil each day.
Landfill Management - Restricted Access & Signs
ACWM Must Be Covered by End of Day
Waste Not Leak Tight
Demo of Snow-Collapsed Buildings Is this building safe to abate?
EPA Statement on Snow-Collapsed Buildings https://www.epa.gov/id/idaho-snowdebris-collapsed-buildings
Structurally Unsound Buildings - Survey & Abatement Waived
But, if possible, the standing portion must be inspected and abated.
Partial Collapse vs. Total Collapse
Snow-Collapsed Buildings If possible: Survey for asbestos Abate asbestos Keep asbestos wet, put in containers or wrap it in sections, transport to landfill. WSR Clean Material is nonregulated. If completely collapsed or unsound: Assume debris is asbestos-contaminated Keep debris wet Transport in bulk to landfill permitted to accept asbestos waste. WSR
See EPA s National Asbestos Web Site http://www.epa.gov/asbestos
Questions? John Pavitt US EPA Region 10 Alaska Operations Office (907) 271-3688 Pavitt.john@epa.gov www.epa.gov/asbestos