United State*
                 Environmental Protection
                 Agency
            Office* Air Quafty
            Pltnnlno and Standante
            Waahlngton, DC 20400
EPA-340/1.82-013
September 12
  oEPA
                 Stationary Source Compliance Series
A Guide to Normal Demolition
Practices Under the Asbestos
NESHAP
C

-------
                                             EPA-340/1-92-013
                          A Guide to Normal
                     Demolition Practices Under
                       the Asbestos NESHAP
                             (TRC Ref. No. 1-4564)19)
                                                    ou
                     U.S. ENVIRONMENTAL PROTECTION AGENCY
                        Office of Air Quality Planing and Standards
                         Stationary Source Compliance Division
                             Washington, DC 20460
                                September 1992
C

-------
                                         DISCLAIMER
              This manual was prepared by TRC Environmental Corporation for the Stationary
              .Source Compliance Division of the U.S* Environmental Protection Agency. It has
              been completed in accordance with EPA Contract No. 68D20059, Work Assignment
              No. IA2-19.  This document is intended for information purposes ONLY, and may not
              in any way be interpreted to alter or replace the coverage or requirements of the
              asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), 40
              CFR Part 61, Subpart M.  Any mention of product names does not constitute
              endorsement by the U.S. Environmental Protection Agency.
C
        A92-1225.UI                               ii
                                                                                   TRC

-------
                                    TABLE OF CONTENTS

          Section                                                              Page

          1    .DEMOLITION PRACTICES AND NONFRIABLE MATERIALS	   1-1
               Introduction	   i-i
               Purpose .."	   M
               Definitions	   1-2

          2     PRE-DEMOLFTION BUILDING STATUS	   2-1
               State and Local Regulations	   2-1
               Unsafe Building Declarations	   2-1
               Abatement Prior to Demolition	   2-1
               Intentional Burning	.	   2-2

          3     DEMOLITION PRACTICES BY TYPE OF ACM	,.   3-1
               Introduction  	.. -.	%	   3-1
               Resilient Floor Covering (TUes)	   3-1
               Asphalt Roofing Products		   3-3
               Asbestos-Cement Products	   3-3

          4     DEMOLITION PRACTICES BY METHOD  	   4-1
               Heavy Machinery Razing Operations	   4-1
               Explosions/Implosions	 .	   4-3
               Hand Methods of Demolition	   4-4

          5     ONSITE WASTE HANDLING PROCEDURES	   5-1
               Introduction	   5-1
               Waste Consolidation	   5-1

          6     OFFSITE WASTE HANDLING PROCEDURES	   6-1

          Appendix I	  I-l
C
         A92-1225.UI                            iii
                                                                             7WC

-------
                                  SECTION!

      DEMOLITION PRACTICES AND NONFRIABLE MATERIALS


INTRODUCTION

EPA revised the asbestos NESHAP regulations on November 20, 1990 (see 40 CFR Part 61
Subpart M).  Although the NESHAP has not been revised to alter its applicability to friable
and nonfriable asbestos-containing materials (ACM), nonfriable asbestos materials are now
classified as either Category I or Category Q material.

Category I material is defined as asbestos-containing resilient floor covering, asphalt roofing
products, packings and gaskets. Asbestos-containing mastic is also considered a Category I
material (EPA determination - April 9, 1991). Category n material is defined as all
remaining types of non-friable ACM not included in Category I that, when dry, cannot be
crumbled, pulverized, or reduced to powder by hand pressure. Nonfriable asbestos-cement
products such as transite are an example of Category Q material

The asbestos NESHAP specifies that Category I materials which are not in poor condition and
not friable prior to demolition do not have to be removed, except where demolition will be by
intentional burning. However, regulated asbestos-containing materials (RACM) and Category
n materials that have a high probability of being crumbled, pulverized, or reduced to powder
as part of demolition must be removed before demolition begins.

PURPOSE

EPA has identified a need to address how specific demolition practices affect Category I and
n nonfriable ACM. The purpose of this manual U to provide asbestos NESHAP inspectors
with such information.

This manual is intended to apply primarily to  demolition and cleanup activities for buildings
that contain Category I nonfriable ACM. Although references will be made to Category n
nonfriable ACM, for the purposes of this document, it and aB other RACM will be assumed
to have been nmoved prior to the start of actual demolition activities. Work practices
associated solely with building renovations  will not be addressed.

This manual is designed to assist the asbestos NESHAP inspector in identifying practices that
normally do or do not make Category I nonfriable ACM become regulated asbestos-
containing material (RACM), Applicability determinations (both formal and informal)
provided  by the Regional NESHAP Coordinators have been incorporated into the appropriate
sections of this document in an effort to promote nationwide consistency in applying the
asbestos NESHAP to these demolition practices.
A92-1225.IXI                              1-1
                                                                           TRC

-------
c
c
Activities associated with site cleanup such as segregation, reduction, and on and offsite
disposal of ACM art discussed because they may take place during or after the major
demolition activities at a site and consequently may influence a demolition contractor's choice
of methods.

DEFINITIONS

The following definitions taken from the November 20, 1990 revision of the asbestos
NESHAP regulation are provided for ease of reference.

Adequately wet means sufficiently mix or penetrate with liquid to prevent the release of
particulates. If visible emissions are observed coming from asbestos-containing material, then
that material has not been adequately wetted.  However, the absence of visible emissions is
not sufficient evidence of being adequately wet

Axbestos-containing waste materials means mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to die provisions of this subpan.
This term includes filters from control devices, friable asbestos waste material,, and bags or
other similar packaging contaminated with commercial asbestos. As applied to demolition-
and renovations operations, this term also includes regulated asbestos-containing material
waste and materials contaminated with asbestos including disposable equipment and clothing.

Category I nonfriabte asbestoS'Containing material (ACM) means asbestos-containing
packings, gaskets, resilient floor covering, and asphalt roofing products containing more man
one percent asbestos as determined using the method specified in appendix A, subpart  F, 40
CFR pan 763, section I, Polarized Light Microscopy.

Category // nonfriable ACM means any material, excluding Category I nonfriable ACM,
containing more man one percent asbestos  as determined using die methods specified in
appendix A, sobpart F, 40 CFR pan 763, section I, Polarized Light Microscopy that, when
dry, cannot be crumbled* pulverized, or reduced to powder by hand pressure.

Catting means to penetrate  with a sharp-edged instrument and includes sawing, but does not
include shearing, slicing, or punching.

Demolition means  the wrecking or taking out of any load-supporting structural member of a
facility together with any related handling operations or the intentional burning of any  facility.

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. For  purposes of this definition, any building, structure, or
installation that contains a loft used  as a dwelling is not considered a residential structure,
installation, or building. Any structure, installation or building that was previously subject to
this subpan is not excluded, regardless of its current use or function.

A9M223.UI                                 J-2

-------
I
Facility component means any part of a facility including equipment.

Friable asbestos material means any material containing more than one percent asbestos as
determined using the method specified in appendix A, subpan F, 40 CFR part 763 section 1,
Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to
powder by hand pressure.  If the asbestos content is less than 10 percent as determined by a
method other than point counting by polarized light microscopy (PLM), verify the asbestos
content by point counting using PLM.

Grinding means to reduce to powder or small fragments and includes mechanical chipping or
drilling.

in poor condition means the binding of the material is losing its integrity as indicated by
peeling, cracking, or crumbling of the material.

Inactive waste disposal site means any disposal site or portion of it where additional asbestos*
containing waste material has not been deposited within the past year.

Installation means any building or structure or any group of buildings or structures at a single
demolition or renovation site that are under the control of the same owner or operator (or
owner or operator under common control).

Nonfriable asbestos~containing material means any material containing more than one
percent asbestos as determined using the method specified In appendix  A, subpart F, 40 CFR
pan 763, section 1, Polarized Light Microscopy, that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.

Owner or operator of a demolition or renovation activity means any person who owns,
leases, operates, controls, or supervises the  facility being demolished or renovated or any
person who owns, teases, operates, controls, or supervises the demolition or renovation
operation, or both.

Planned renovation operations means a renovation operation, or a number of such
operations, in which some RACM will be removed or stripped within a given period of time
and that can be predicted.  Individual nonscheduled operations are included if a Dumber of
such operation* an be predicted to occur during a given period of time based on operating
experience.

Regulated asbestos-containing material (RACM) means (a) Friable asbestos material, (b)
Category I nonfritbk ACM that has become finable, (c) Category I nonfriable ACM that will
be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category n
nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized,
or reduced to powder by the forces expected to act on the material in die course of demolition
or renovation operations regulated by this subpart
              A9M223.IU                                1.3
                                                                                             TRC

-------
c
Remove means to take out RACM or facility components that contain or are covered with
RACM from any facility.

Renovation means altering a facility or one or more facility components in any way,
including the stripping or removal of RACM from a facility component Operations in which
load-supporting structural members are wrecked or taken out are demolitions.

Resilient floor covering means asbestos-containing floor tile, including asphalt and vinyl floor
tile, and sheet vinyl floor covering containing more than one percent asbestos as determined
using polarized light microscopy according to the method specified in appendix A, subpart F,
40 CFR pan 763, Section 1, Polarized Light Microscopy.

Strip means to take off RACM from any part of a facility or facility components,

Visible emissions means any emissions,  which are visually detectable without the  aid of
instruments, coming from RACM or asbestos-containing waste material, or from any asbestos
milling, manufacturing, or fabricating operation. This does not include condensed,
uncombined water vapor.

Waste generator means any owner or operator of a source covered by this subpart whose act
or process produces asbestos-containing  waste material.

Waste shipment record means the shipping document, required to be originated and signed by
the waste generator, used to track and substantiate the disposition of asbestos-containing
waste material.
     A9M225.I*                                1-4
                                                                                    TRC

-------
c
c
                                    SECTION 2

                    PRE-DEMOLITION BUILDING STATUS
,- This section discusses several factors that can affect the approach to demolition taken by a
  demolition contractor. It is being included because events that have taken place prior to the
  start of actual demolition work can influence the methodology(ies) chosen by demolition
  contractors.  These events can be evaluated by an inspector, allowing for prediction of
  "hidden" potential problem areas.  Reinforcement and clarification of applicable components
  of the asbestos NESHAP regulations are also included in this section.

  STATE AND LOCAL REGULATIONS

  State and local asbestos regulations are sometimes more stringent than the asbestos NESHAP
  regulations.  This does not imply, however, that Category I nonfriable ACM is necessarily
  removed from a building prior to demolition.. Contractors surveyed during research conducted
  in the preparation of this manual indicated that they typically treated Category I nonfriable
  ACM as RACM  only when the  owner or operator of the building being demolished was a
  state or local government agency or when project specifications explicitly specified mat one
  or more of the Category I nonfriable ACM materials be removed prior to the start of
  demolition.

  UNSAFE BUILDING DECLARATIONS

  Several contractors surveyed utilized state or local mechanisms to have buildings declared
  unsafe as a means to  avoid NESHAP requirements during and after demolition activities.
  However, a State or local agency should not issue a demolition order unless the facility is
  structurally unsound and in danger of imminent collapse. These conditions  should be
  confirmed independently, and a  demolition order should not be based solely on the
  representation of the contractor or the contractor's agent Although issuance of a demolition
  order may have an effect on notification requirements under the asbestos NESHAP (see
  61.145(aX3)), it has no effect on requirements for disposal procedures for RACM after
  demolition activities.  Also, waste segregation/reduction activities, addressed in Section 5 of
  this manual, are subject to the asbestos NESHAP provisions whether or not a building has
  been declared unsafe.

  ABATEMENT PRIOR TO DEMOLITION

  Demolition contractors typically require that a building owner/operator accept responsibility
  for die removal of all asbestos-containing materials found during the building inspection prior
  to the start of demolition activities. Several contractors indicated that if suspect ACM
  became exposed  during demolition activities, and there was no prior knowledge of its
  existence at the start of demolition activities, that potential asbestos NESHAP requirements
  would be disregarded unless a change order was immediately processed by the owner/operator
          A9M223,Ut                               2-1
                                                                                       TRC

-------
C
requesting the time and materials necessary to achieve compliance with the asbestos
NESHAP. Such practices are in direct violation of the asbestos NESHAP.

INTENTIONAL BURNING

As stated in the November 1990 asbestos NESHAP revision (see  $6U45(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."

Abandoned buildings utilized by fire departments for practice exercises involving partial
burning are subject to this requirement,

For buildings which are still structurally sound but which have previously been subjected to
partial or total, intentional or unintentional burning, an inspection for the condition of all
ACM should be conducted.  Category I ACM should be examined for friability and condition.
Friable materials or Category I materials that are friable and in poor condition must be
removed prior to any further demolition activity.
C
    A92-1223.ut                               2-2
                                                                                 7WC

-------
c
c
                                  SECTION 3

              DEMOLITION PRACTICES BV TYPE OF ACM
INTRODUCTION

For many years now the applicability of the asbestos NHSHAP to demolitions involving
Category I nonfriable ACMs (packings, gaskets, resilient floor coverings and mastic, and
asphaltic roofing materials) has been the topic of much debate. Since significant amounts of
airborne asbestos fibers are not believed to be produced from such materials during normal
demolition activities, however, the asbestos NESHAP, in most cases, does not require their
removal prior to demolition.

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. (Definitions for these
terms and additional information concerning Category I nonfriable ACM can be found in the
preamble to the November 1990 revised asbestos NHSHAP (SUPPLEMENTARY
INFORMATION, Section IV - Significant Comments..., Demolition and Renovation,
Nonfriable ACM and Broken ACM).

The following information details specific pre-demolition and demolition practices and their
impact on Category I nonfriable ACM. The information has been compiled from telephone
surveys of demolition contractors, the viewing of activities at a number  of demolition sites,
and formal and informal EPA applicability determinations.  The effects of various demolition
practices on asbestos-cement products tie also discussed.  Since the applicability of the
asbestos NESHAP to Category Q nonfriable materials is determined on a case-by-case basis,
it U hoped that this additional information will help foster nationwide consistency in the
application of the regulation to these maimiih

As you will see, many of the various demolition techniques described do not, by themselves,
cause Category I nonfriable ACM to become RACM. However, in many cases, post-
demolition waste consolidation, cleanup, and recycling efforts can cause both Category I
nonfriable  ACM and Category n nonfriable ACM to become RACM. If that is likely to
happen, such materials most be considered RACM and be treated as such.  Post-demolition
activities which can affect Category I and 0 mftfr*1* will  be detailed later in this manual

RESILIENT FLOOR COVERING (TILES)

Depending on the types of activities occurring at a demolition site, floor tiles (and mastic)
may or may not become subject to the provisions of the asbestos NESHAP.   *
          A9M225.t                              3-1
                                                                                     7WC

-------

Pre-demoUtfon Floor TOe Removal

Although not usually required by the asbestos NESHAP, removal of asbestos-containing
resilient floor tiles may occur prior to demolition.  Such removal may be required when the
substrate to which the floor covering is attached (particle board, wood, concrete) U to be
recycled or salvaged.

Since the presence of mastic  is not desirable on materials intended for resale or recycling,
contractors use a variety of methods to remove this material as well.

A wide variety of floor tile removal methods exists, some of which cause the floor tiles and
mastic to become RACM and subject to the provisions of the asbestos NESHAP. The
following describes various removal methods and the applicability of the asbestos NESHAP
to them.

Water/Amtndtd Water/Solvents

Water, amended water, or solvents may be spread onto floor tiles in order to loosen them.
After a period of soaking, the tiles may be removed using long-handled scrapers (ice.
chippers), or gas- or electrically-powered mechanical chisels. In cases where tile breakage is
minimal, the floor tiles are not considered RACM.  However, where breakage is extensivev
the tiles are RACM and are subject to the provisions of the asbestos NESHAP.

Dry let

Although rarely used for this purpose nowadays, dry ice (frozen carbon dioxide) can be used
to remove floor tiles. When  dry ice is applied to the tiles, the intense cold causes the tiles to
contract and detach from the  substrate. As long as the tiles are not extensively damaged, they.
are not considered RACM.

Infrared Machines

Infrared machines may be used in the removal of floor tiles. These machines heat the
flooring, thereby softening the tiles and adhesive, and allow for its easy removal. Since most
tiles  detach intact, they are not friable, and therefore are not considered RACM.

Shot-blasters

Shot-blasters are sometimes used in the removal of floor tiles.  These machines direct a
barrage of small pellets (shot) against the tiles and continually vacuum up and separate the   ,
mixture of pulverized tile and pellets. The pellets are reused immediately and the pulverized
materials are segregated for disposal.  EPA allows the use of shot-blasters only on wetted
floor tiles.  Floor tiles and mastic removed by shot-blasters are considered RACM and are
therefore subject to the asbestos NESHAP.
A92-1225.U1                                3-2
                                                                               TRC

-------
C
 Demolition with Floor Tfls In Place

 Since ordinary demolition activities do not include the sanding, grinding, cutting and abrading
 of floor tiles, floor tiles and associated mastic that are not in poor condition and not friable
 an not considered RACM and are allowed to remain in place during demolition.

 ASPHALT ROOFING PRODUCTS

 The pre-demolition terms and conditions (governmental regulations, contract specifications)
 discussed in Section 2 also influence the handling of asbestos-containing roofing materials.

 Pre-demolition Roof Removal

 If preliminary assessment has determined that roofing materials contain asbestos, and
 regulations or contract specifications dictate removal of such material prior to demolition,
 licensed abatement contractors may be requited to do the removal. Alternatively, the
 demolition contractor may undertake  the operation.

 Roofs may be removed in a variety of ways. Demolition personnel may use sledge hammers,
 pry bars, axes, adzes, shovels, ice chippers and roof-cutting saws to remove the roofing
 materials. They also may use tractor-mounted rotating blade cutters, power plows and power
 sheers.  Use of roof-cutting  saws, either hand- or power-driven, or tractor-mounted, are of
 great concern, since they can generate asbestos-containing dust from roofing materials.  The
 sawing of Category I nonfriable ACM roofing material and the debris created by the sawing
 are regulated by the asbestos NESHAP.  Since power plows and power slicers do not sand,
 grind, cut or abrade the roofing materials, their use and resultant debris are not subject to the
 asbestos NESHAP regulation.  Category I nonfriable ACM roofing squares that have been
. decontaminated may be disposed of with other demolition debris or at an asbestos landfill.

 Demolition with Roofing Materials in Plac*

 Since demolition activities do not include sanding, grinding, cutting, or abrading, Category I
 asbestos-containing roofing materials not in poor condition and not friable are not considered
 RACM and are allowed to remain in place during demolition.

 ASBESTOS-CEMENT PRODUCTS

 Asbestos-cement products (such as transite) are commonly  used for duct insulation, pipes, and
 siding.  Being a Category D nonfriable ACM, asbestos-cement products need to be removed
 prior to demolition if they have a high probability of becoming crumbled, pulverized, or
 reduced to powder during demolition activities.  EPA believes that most demolition activities
 will subject such Category n nonfriable ACM to the regulation.

 Whether asbestos-cement products are subject to the asbestos NESHAP should be determined
 by the owner or operator on a case-by-case basis based on  the demolition techniques to be
 used.
           AW.l22S.uu                               3-3
                                                                                        TRC

-------
     In general, if contractors carefully remove asbestos-cement materials using tools that do not
     cause significant damage, the materials are not considered RACM and can be disposed of
     with other construction debris.

     However, if demolition is accomplished through the use of cranes (equipped with wrecking
     balls, clamshells or. buckets), hydraulic excavators, or implosion/explosion techniques,
     asbestos-cement products will be crumbled, pulverized or reduced to powder, and are subject
     to the provisions of the asbestos NESHAP.

     Some demolition contractors do not treat significantly damaged asbestos-cement products as
     RACM; they mix it with other demolition debris and dispose of it in direct violation of the
     waste-disposal provisions of the asbestos NESHAP.
C
     A9M2U.m                                3-4
                                                                                   TRC

-------
                                   SECTION 4

                 DEMOLITION PRACTICES BY METHOD
Methods of destruction employed at demolition sites include the use of heavy machines,
explosions/implosions, and hand methods. All of these methods cause Category 0 nonfriable
ACM to become RACM; however, Category I nonfriable ACM (packings, gaskets, resilient
floor coverings, asphaldc roofing materials, mastic) that is not in poor condition and not
friable prior to the demolition operation may be subjected to most of these techniques without
becoming RACM. The following describes various demolition techniques and their effects on
nonfriable materials.  All Category I nonfriable ACM referenced is  presumed not to be in
poor condition and not friable prior to the demolition operation. .

HEAVY MACHINERY RAZING OPERATIONS

For the purposes of this document heavy  machinery (or equipment) includes large motorized
vehicles such as bulldozers with rakes, top loaders, backhoes, skid loaders/bobcats, hydraulic
excavators, and other similar machinery used .for  transporting, moving, or dislodging of
materials at a demolition site. Cranes equipped with wrecking balls, clamshells, or buckets
are also considered heavy machinery.

Heavy machinery is used at demolition sites for bom razing operations and post-demolition
activities. "Razing*, the process which reduces ft building's structural skeleton to rabble,
typically cxxun after the building's interior has been gutted by hand.

Use of heavy machinery during the razing process causes Category  n nonfriable ACM, bat
not Category I nonfriable ACM to become RACM. Use of such equipment during subsequent
operations, such as waste consolidation, however, is a major concern which will be addressed
in Section 5 of this document

Bulldozers and Similar Machinery

Included in mis grouping of heavy machinery are all types of bulldozers, backhoes, top
loaders and sldd loaders/bobcats commonly used in conjunction with hand methods to raze
buildings.  Bulldozers move on tracks whereas backhoes, top loaders, and skid loaders operate
on rubber tires.

Only if a great deal of working space exists at a site, and a precisely-controlled demolition is
not necessary, can bulldozers such as 977 loaders and D-9s be used to demolish a building.
These bulldozers are typically equipped with giant rakes designed to ram builduig walls and
move debris.

977's or D-9s may be used to undermine a building, but hydraulic excavators (discussed later
in this section) are usually used for mis purpose.
A9M225.UK                               4-1
                                                                             7RC

-------
C
Backhoes and top loaders are mainly used for moving debris and tearing off sections of walls
and other building components.

Skid loaders, machines commonly used to load skids or pallets onto trucks, may be specially
equipped with a type of ram for use during demolitions and are usually of the "bobcat" type.

The razing of a building using the heavy machinery described above causes Category U
nonfriable ACM, but not Category I nonfriable ACM  to become RACM.

Hydraulic Excavators

Hydraulic excavators, such as EL-SOOs, 225s or 215s, resemble a combination
bulldozei/backhoe and operate on tracks. They  are easier to use and provide greater control
during demolition than the bulldozers described above.  However, since they too raze
buildings by ramming and tearing, like bulldozers, their use in congested areas is limited.
Nearby buildings must be protected from the falling debris; plywood may be applied over the
windows and rubber tires may be used to cushion and prevent damage to walls of adjacent
structures.

On rare occasions, hydraulic excavators may be used  to topple one- or two-story buildings by
means of an undermining process. The  strategy is to  undermine the building while
controlling the manner and direction in which it falls. The demolition project manager (who
in many jurisdictions must be licensed by the city or state) must determine where
undermining is necessary so that a building falls in the desired manner and direction. The
walls are typically undermined at a building's base, but this is not always the case as building
designs may dictate otherwise.  Safety and'cleanup considerations are also taken into account
in determining the methods to be used.
                                                       f
Since the toppling of a building  constitutes a safety hazard and generates enormous quantities
of dust, many cities and towns will not approve of this method of demolition.  Where the
practice is allowed, the, contractor may be required to keep the structure wet during
demolition. Hydrant permits may be required and, because of the wetting restrictions, such
demolitions may  be impossible to accomplish during the winter.

Hydraulic excavators are also used to conduct cleanup activities such as excavation, IBl
burial, material reduction, and material load-out

The use of hydraulic  excavators  during the razing process causes Category n nonfriable
ACM, but not Category I nonfriable ACM to become RACM.

Cranes (Wrecking BaD, Clamshell, Bucket)

Although often employed in the  past, particularly during demolitions of high-rise structures,
cranes are now rarely used. They are expensive to operate and usually not necessary, since
renovation has displaced demolition as the method of choice in dealing with many out-of-date
          ':23.ut                               .4-2

-------
structures.  Cranes are currently used only in situations where other equipment cannot be
employed.

Cranes may be equipped with wrecking balls, clamshells or buckets, which are used in a
variety of ways.  All three may be dropped or swung against the structure to demolish it.
When employed in this manner, clamshells provide the greatest force of the three and result
in the fastest, most efficient demolition projects.

Buckets and clamshells allow a greater degree of control than wrecking balls.  Buckets may
be raised to the level where internal demolition of the building is taking place and be used
merely to transport and segregate hand-loaded demolition materials collected from within.
Clamshells can take big bites out of the structure and facilitate the segregation of demolition
debris.

When demolition is accomplished by crane, the process can begin at the roof and progress
continually downward, or alternate up and down.  Materials are segregated to the greatest -
degree possible as the demolition progresses so that the need for post-demolition handling is
minimized.  In the case of high-rise structures, the interiors are usually gutted by hand prior
to razing.

Effect on Category I Materials

The use of cranes during the razing process does not cause Category I nonfiiable ACM to
become RACM; therefore, Category I materials which are not in poor condition and not
finable may remain in die building during such demolition.

Effect on Category 11 Materials

The use of wrecking balls on asbestos-cement (A/C) siding (a Category n nonfiiable ACM)
on buildings is specifically addressed in the November 1.990 asbestos KESHAP revision (see
SUPPLEMENTARY INFORMATION, Section IV - Significant Comments-., Demolition and
Renovation* Nonfiiable ACM):

       "...A* A/C siding on a building that is to be demolished using a wrecking ball is very
     ' ttkefy to be crumbled, or pulverized with increased potential for the release of
       significant levels of asbestos fibers.  Such material in this instance should be removed
       prior to demolition.''

Therefore, A/C siding, although a nonfnable material, is considered RACM when a wrecking
ball is being used to demolish the structure. Whenever buckets and clamshells are to be
swung like wrecking balls, A/C materials should also be considered RACM.

EXPLOSIONS/IMPLOSIONS                                    .

Building implosions utilizing explosive devices constitute a rarely-used demolition technique.
In simplest form, mis method is accomplished through the use of explosive charges placed

A9M225.M                               4-3

-------
     strategically throughout a building so that the building collapses in on itself and debris does
   not radiate outward to any appreciable distance.  Relatively large quantities of dust are
     created, however, and the direction and magnitude of transport are matters of concern.

     Effect on Category I Materials

     The asbestos NESHAP does not require the removal of Category I nonfriable ACM that is not
     in poor condition and not friable prior to building implosions.  Normal implosion techniques
     do not cause nonfriable materials to become RACM,  Hie destruction of buildings during
     military target practice is considered to be another form of explosive  demolition. Category I
     materials may remain in place during target practice.  However, if it can be expected thai the
     building and ACM will burn as a result of explosive demolition, the ACM must be removed
     prior to demolition.

     Recent examination of asbestos-containing floor tiles and roofing materials contained in a
     large building demolished by implosion revealed that the floor tile was in fair to good
     condition and had not become finable. Tiles had been broken up Into small quantities of large
     pieces as the individual floors collapsed upon each other.  The roofing materials were
     similarly affected; they too remained nonfriable following demolition by implosion.

     EPA does not consider Category I material to be RACM as a result of building implosions.
     If, however, Category I materials are  to be subjected to sanding, grinding, cutting, or abrading
     after demolition, they must be treated as RACM and be removed from the building before
     demolition.

     Effect on Category H Materials

     Category D materials, such as transite, found in or on buildings scheduled for
     implosion/explosion destruction must be removed before such demolition. Such materials are
     considered RACM because they have "a high probability of becoming crumbled, pulverized
     or reduced to powder" during such activities.

     HAND METHODS OF DEMOLITION

     This section of die manual addresses hand methods employed during demolition and includes
     segregation activities which take place during demolition (as opposed to cleanup) and their
     effects on Category I materials. "Hand methods", for the purposes of this manual, refer to die
     use of motorized and non-motorized tools that can be operated by hand and are not used for
     transportation.  The methods discussed include not only those used in the gutting of building
     interiors prior to razing, but also those used during razing itself.  Unless otherwise noted,   ,
     "hand methods" refers to those methods that do not significantly damage die ACM and
     therefore do not cause Category I nonfriable ACM to become RACM.

     Most buildings of ten floors or less are currently razed at least partially, if not fully, by hand.
     Hand methods allow much greater control over a building's collapse  than other methods and
     permit easier segregation of demolition materials for resale or recycling dun other demolition
     methods.  In addition, hand methods may be required because of workspace limitations.

     A9M225.au                               4-4

-------
 Depending on the size of the job and demolition schedule, the size of a demolition crew may
 vary from as few as five individuals to 30 or more.  As a general rule, workers use relatively
 inexpensive tools such as pry bars, hand-held saws, power saws, sledge hammers, axes, bolt
 cutters, and acetylene torches during gutting and razing operations.

. As the gutting/salvage activities progress, demolition debris is typically deposited into a trailer
 or dumpster strategically placed outside a window of the building being demolished. The
 window frame is removed and materials are loaded into the storage containers by hand, or,
 where possible, by bobcats operating within the building.  Many jobs require the use of dust-
 tight chutes for the transport of such debris.

 On the rare occasion where onsite burial of demolition debris is allowed, the first activity to
 take place in the building is the removal of the first story's flooring.  This is done so that as
 waste  materials accumulate on upper floors, they can be sent down into the basement through
 the center of the building, typically through elevator shafts, for disposal.  Chutes may be used
 if elevator shafts are not available.  Such onsite disposal typically is allowed only for
 noncombustible materials such as cement and bride Waste consolidation activities which
 occur  in the basement area are of great concern to EPA and are discussed in Section 5 of this
 manual

 Excess demolition wastes are loaded out for transport to a landfill that accepts construction
 debris. If no basement area exists, or if materials cannot be sent into dumpsters or trailers
 immediately as previously described, debris may be stored in piles scattered around the site,
 These materials may subsequently be moved by hand or through the use of light or heavy
 machinery.  Section 5 of this manual details such operations.

 Floor Removal and Disposition

 The techniques used in removing flooring depend upon its ultimate fate.  When it is in poor
 condition and incapable of being reused or recycled, die flooring is typically zipped out using
 pry bars and sledge hammers and sent offsite for disposal.  Sometimes wood flooring and
 other debris is burned to reduce the volume of waste.  In this case, the asbestos must be
 removed prior to burning the wood debris.  Since demolition debris disposal costs are so high
 ($100 -1500 per 60-100 cubic yard load) as much salvage/recycling of materials is done as
 possible.

 Wood or particle board flooring is sometimes segregated and sold to recycling centers where
 it is chipped up and sold as filler or mulch  (composting, gardening, etc.). If resilient
 asbestos-containing floor covering is attached to such flooring it is considered RACM and
 must be removed prior to recycling. Tiles are often chipped or scraped off the substrate using
 the methods described in Section 3.

 Large  planks and joists, and beams (both wooden and steel) may also be  saved if they are in
 good condition.  Wooden planks are usually lifted with pry bars, whereas the  larger joists and
 beams are segregated for reuse  following the razing of the structure.
 A9MJ25.ut                                4-5

-------
Where demolition debris will be recycled, any asbestos remaining on the debris must be
removed prior to any recycling that will sand, grind, cut, or abrade the asbestos or otherwise
cause it to become RACM.

Roof Removal and Disposition

On occasion one may find that the roof of a building being demolished is removed before the
building is razed. Such removal may be required when buildings are very close to one
another, or when the roofing contains asbestos-containing materials.

There axe two major types of roofing:  "built-up roofing" and "sheet goods". Built-up roofing
contains multiple layers -of felt and asphalt  Sheet goods typically consist of a single layer of
material.                            '

Roofs are often taken out by hand, typically by using pry bars, sledge hammers, axes* adzes,
bolt cutters, ice chippers, shovels and roof-cutting saws.  If the roof contains asbestos
materials (felt, cork, etc.), an asbestos removal contractor may be employed to remove it
Some abatement contractors wet die roof with plain or amended water and then use shrouded
power saws whose exhaust is HEPA-filtered to cut the roofing into manageable (often T %
3') pieces.  After the pieces are lifted, the edges may be encapsulated. Other abatement   *
contractors may build a foil containment and establish a reduced pressure environment prior
to removing the roofing materials.

Depending upon the contractors involved and the condition of the asbestos-containing roof
debris, the debris may or may not be segregated from other demolition debris.  Abatement
contractors may store roof debris in lined dumpsters onsite and dispose of it at an asbestos
landfill; if the asbestos-containing roofing material is not in poor condition and is not friable
however, it may be disposed of in a landfill which  accepts ordinary demolition waste.

Asbestos-containing roofing material may not be ground up for recycling into other products.

Work Progression

Demolition crews typically work downward, floor by floor.  Materials such as doors,
windows, electrical and other fixtures which can.be salvaged are removed first  Interior
partitions are  then ripped, cat, or knocked out using various hand-held tools including sledge
hammers, axes, adzes and pry bars. Brick is generally segregated immediately after being
knocked out of walls so it can be examined at the site by potential buyers.  Ceilings are also
ripped out using pry bars, axes and sledge hammers.  Steel and other metal materials are
typically placed in separate debris piles from other materials. Work proceeds in a similar  '
floor/wall, floor/wall pattern until the first floor is once again reached.

Sawing/Cutting Operations

In order to raze a building by hand, load-bearing members must be cut Based upon the
composition,  thickness, and condition of the structural member being cut, saws selected range

A9M223.UI                                4-6

-------
C
             from hand saws to Sawz-alls and gas-driven carbide blade hand saws. Large bolt cutters
             ait also used to cut steel members. Category I materials subjected to sawing or cutting are
             subject to the provisions of the asbestos NESHAP; however, typical demolition sawing/cutting
             operations rarely involve such materials.

             Grinding Operations

             Grinding operations are not common occurrences at most demolition sites.  On occasion,
             however, asbestos-containing mastic and remaining pieces of floor tile may be ground off
             concrete destined for recycling.  Category I material so treated is RACM and is subject to the
             provisions of the asbestos NESHAP.

             Pulverizing Operations

             On occasion, asbestos-containing floor tiles are removed bom their substrate by hand, using
             either hand-held ice choppers or electrically- or gas-powered mechanical chippers.  If use of
             such methods pulverizes, crumbles or reduces the floor tiles to powder, the tiles must be
             considered RACM and must be handled in accordance with the requirements of the asbestos
             NESHAP.

             Summary

             On rare occasions Category 1 nonfriabte ACM may be subjected to hand methods involving
             the uncontrolled drilling, cutting, sawing, grinding or abrading of such materials; under these
             circumstances Category! materials are considered RACM.
             A9M22S.ut                                4-7
                                                                                           TIM

-------
c
                    .3Q.
     A92-122S.ttt
                                 4-8
TRC

-------
c
                   SECTION 5

ONSITE WASTE HANDLING PROCEDURES
          .INTRODUCTION

           At the present time it is not demolition operations and ordinary cleanup activities but the
           post-demolition activities involving waste consolidation and recycling of Category I and n
           materials which are of greater concern. If such activities subject either Category I or n
           nonfriable ACM to sanding, grinding, cutting or abrading* the materials become RACM and
           arc then subject to the provisions of the asbestos NESHAP.

           In general, since cleanup activities such as loading waste debris onto trucks for disposal do
           not subject nonfriable materials to sanding, grinding, cutting or abrading, such materials are
          not considered asbestos-containing waste materials and are not regulated by the asbestos
           NESHAP.

           However, waste consolidation efforts which involve the use of jack hammers or other
           mechanical devices such as grinders to break up asbestos-containing concrete or other
           materials covered or coated with Category I nonfriable ACM, are subject to the regulation.

           In addition, operations such as waste recycling which sand, grind, cut, or abrade Category I or
           n nonfriable ACM are subject to the asbestos NESHAP.  When these types of activities are
           performed. Category I and n nonfriable ACM become RACM.

           The following details the post-demolition activities of waste consolidation (segregation and
           reduction), waste load-out and onsite waste disposal and their effects on nonfriable ACM.

           WASTE CONSOLIDATION

           Waste consolidation operations involve segregation and reduction activities that have as their
           ultimate goal the resale, recycling, and disposal of demolition debris.

           Segregation of DaaoUtfcm Debris

           Demolition contractors segregate demolition debris primarily to maTriimre their profits. As
           much material as possible is collected  for resale and recycling (e.g., wood, brick, steel  and
           concrete); the remaining debris is most often  transported orTsite for disposal.

           Segregation may involve catting and grinding operations, the breaking and tearing apart of
           materials to separate mem by material type, and the transport of materials within die
           demolition site boundaries.
           A92-1225.txt                              5-1
                                                                                       TRC

-------
 Since segregation activities may be accomplished using hand methods and heavy equipment,
 nonfriable ACM may or may not become finable in the process. Hie following text details
'various segregation activities and describes their effects on nonfriable materials.

 Segregation by Hand

 Materials such as wood, brick and steel are generally separated from other demolition debris
 using equipment such as sledgehammers, prybars. adzes and axes.  If any hand equipment is
 used to cut, sand, grind, or abrade Category I or n materials, RACM is thus created and the
 provisions of the asbestos NESHAP apply.

 Material Transport

 Since heavy equipment is often used to move and segregate demolition debris* questions have
 been raised concerning the effect of such transport particularly on Category I nonfriable
 ACM.

 If Category I nonfriable ACM is transported  across a demolition site in the  bucket of a top
 loader, backhoe, hydraulic excavator or other similar vehicle, it is not considered RACM     .
 since it is not subjected to sanding, grinding, cutting or abrading during this activity.

 Use of bulldozers, on the  other hand, is expected to have a greater impact on Category I
 materials. However, EPA has stated that "...if the bulldozer is moving the debris or picking it
, up to be put in a vehicle and inadvertently runs over Category I material, then it is not
 subject to the NESHAP standard" (see Appendix I).  Consequently, the moving of debris by
 bulldozers, whether by carrying it in a bucket or pushing it along the ground does  not in itself
 cause Category I nonfriable ACM to become RACM.

 Category H nonfriable ACM subjected to sanding, grinding, cutting or abrading during
 collection and transport is considered RACM and thus subject to the asbestos NESHAP.

 Vehicular Traffic Impact

 Rubber~tired Vehicles

 If nonfriable ACM is intentionally run over by rubber-tired vehicles as a means  of
 segregation, it does not automatically become RACM but must be examined for damage. If it
 has  become extensively damaged, ie., it was sanded, ground, cot or abraded during
 segregation, it becomes RACM and is subject to the NESHAP regulation.

 Tracked Vehicles

 Although  tractor treads present greater risks of causing extensive damage to nonfriable ACM,
 limiting their use at demolition sites is not considered practical  Intentionally.running over
 nonfriable ACM with tractor treads as a means of segregation is considered grinding; material
 thus treated becomes RACM.

 A9M223.txt                               5-2

                                                                              TWC

-------
Intentional segregation in this manner is addressed in the preamble to die revised asbestos
NESHAP (SUPPLEMENTARY INFORMATION. Section IV, Significant Comments and
Changes to the Proposed Revisions, Demolition and Renovation, Nonfriable ACM):

       "Examples of practices...included tke breaking ofnonfriable insulation from steel
      'beams by repeatedly running over the "beams with a crawler tractor...these and other
      similar practices involving nonfriable asbestos material were  considered to render
      nonfriable ACM into dust capable of becoming airborne."

Reduction of Demolition Debris

Reduction activities are of the greatest concern to EPA, since they are most likely to cause
both Category I and Category 0 nonfriable ACM to become RACM.

Category 1 Reduction

The use of bulldozers to reduce the volume of Category I materials causes them to become
RACM as discussed elsewhere in this manual and in the following EPA correspondence:

       "If, offer a demolition, material left in. the facility.* is intentionally ground up (such as
      repeatedly running over the debris with a bulldozer to compact the material), then?
      6l.l5Q(a)(3) applies.  The material must be  adequately welted and kept adequately wet
      during collection and transport to a site or facility operated in accordance with
      61.154 or 61.155." (See Appendix I).

Reduction by the use of sledgehammers does not normally cause Category I nonfriable ACM
to become RACM.  The use of pneumatic hammers, however, whether hand-operated or
attached to heavy machinery, does cause these materials to become RACM.  The use of
cranes with clamshells or other heavy machinery with rakes or buckets to partially reduce
Category I nonfriable  ACM is permissible if the material is left recognizable in its original
form.  Extensively damaged Category I ACM (that  which has been sanded, ground, cut, or
abraded) becomes RACM. Consolidating  waste materials containing Category I nonfriable.
ACM in die  hole (basement) of a braiding and subsequently grinding or crushing it .via
bulldozer subjects the operation to the asbestos NESHAP.

For wood/tile debris, demolition crews sometimes use tree chippers to grind the material up.
Any Category I nonfriable ACM subjected to mis treatment becomes RACM.

Category II Reduction

Reduction of Category n materials such as asbestos-cement pipe and concrete following
demolition is also a matter of concern.
A9M225.txt                               5-3
                                                                             TRC

-------
Asbestos-Cement Pipe

EPA considers asbestos-cement pipe to be t "facility component" (as defined in 40 CFR
61.141) of the facility which owns or utilizes 'the pipe. In addition, EPA considers asbestos*
cement pipe to be Category n nonfriable asbestos containing material. This material becomes
"regulated asbestos containing material* (RACM). as defined in 40 CFR 61.141, when it
becomes "friable asbestos material" or when it "has a high probability of becoming or has
become crumbled, pulverized or reduced to powder by the forces expected to act on the
material during the course of demolition or renovation operations regulated by [40 CFR Part
61 Subpart M]."  Consequently, the crushing of asbestos-cement pipe with mechanical
equipment will cause this material to become  RACM.  The demolition and renovation
provisions in 40 CFR 61.145 and the waste disposal provisions in 40 CFR 61.150 apply to
asbestos-cement pipe where the pipe is considered RACM, and the amount of pipe being
removed and crushed is at least 260 linear feet for a single renovation project or during a
calendar year for individual nonscheduted operations,

Concrete
                                                          "

At certain demolition sites demolition contractors may rent and operate  large concrete-
pulverizing machines called PC-400s.  Since the asbestos content of concrete is rarely known.
use of such machines is a matter of concern to EPA.  Under no circumstances should
asbestos-containing concrete, or concrete to which asbestos-containing resilient flooring is
attached, be subjected to such treatment

Onstte Waste Disposal

As mentioned in  other sections of mis manual, using heavy machinery to crash demolition
debris containing Category I or 0 nonfriable ACM in place prior to or during burial, can
cause the ACM to become RACM subject to the  provisions of sections  61.150 (waste
disposal) and 61.151 (inactive  waste  disposal sites) or 61.154 (active  waste disposal sites).
If Category I or IT raatenabure iwrfji&deiedTHaMe, mtfy are not inject to the albestos
NBSHAP.        *- T*-'  '"  *;  -             ,           -. .*. -.:-%

EPflb recently responded to a question regarding the onsite d$osal  of crushed asbestos-
cement pipe, t Category n material. The response is applicable as well to the burying of
Category I material which has been sanded, ground, cut or abraded. In its correspondence
EPA stated that the practice of backfilling and burying crushed asbestos-cement pipe in place
causes these locations to become active waste disposal sites subject to the requirements of
61.154. Furthermore, if no additional asbestos-containing waste material is buried at that
location for a year, the site becomes an inactive waste disposal site subject to die
requirements of 6l.l51(e) and  6US4(h).

Consequently, the owner of the  land would be required to comply with  the requirements for
active and inactive waste disposal sites.
A9M225.UI                                5-4
                                                                               TRC

-------
In order to avoid UK creation of a waste disposal site which is subject to the Asbestos
NESHAP, it was suggested that the owners or operators of the pipe consider other options for
dealing with it  If the pipe is left in -place or removed in such a way that it is not crumbled,
pulverized or reduced to power, it would  not be subject to the NESHAP. If the pipe must be
crushed,, the Creadon of an active waste disposal site can be avoided by removing the pipe
from the site and transporting it to a landfill which accepts asbestos waste material.

An alternative method suggested involved the pumping of grout into the buried lines which
are no longer in service.

Waste Load Out

As mentioned previously, waste load out activities generally do not cause Category I
nonfriable ACM to become RACM, Top loaders are typically used to deposit demolition
debris containing Category 1 nonfriable ACM into trucks for hauling to landfills that accept
construction debris.
            
Recent EPA correspondence discusses the hauling and ultimate disposal of both Category I
and Category n ACM as follows:

      It is required under I.150(a)(3) that asbestos-containing waste  material be kept .
      adequately wet.  Asbestos-containing waste material as applied to demolitions and
      renovations includes RACM waste and materials contaminated with asbestos including
      disposable equipment and clothing. Category I or Category If nonfriable ACM mat
      has been contaminated by RACM, and cannot be decontaminated (e.g.. building debris
      in a pile contaminated with RACM) must be  treated as asbestos-containing waste
      material.  Category I or Category IJ ACM that does not meet the  definition of RACM
      after a demolition or renovation, and is not contaminated with RACM, is not asbestos-
      containing waste material and is not subject to the wetting requirement of
       Category lorU nonfriable ACM that is not subject to 61.150(a)(3) would still have
       to be disposed of in a landfill that accepts building debris, in a landfill mat operates
       in accordance with $61.154, or at a facility that operates in accordance with 6]. 155.
      'This watte material would not be allowed to go to any facility mat would sand, grind,
       cut or abrade the non-RACM waste or otherwise tarn it into RACM waste (such as a
       cement recycling facility).  In addition, if Category I or II nonfriable ACM is sanded,
       ground, cut or abraded during disposal at a landfill, before  it is buried* it is subject to
       the NESHAP. (See Appendix I).
A9M225.U1                                5-5
                                                                               TRC

-------
A9M225.au                                    5*6

-------
                                  SECTION 6

               OFFSITE WASTE HANDLING PROCEDURES
The issues discussed in this section include landfills, recycling centers, conversion facilities,
and renovation activities.  Since EPA has taken a "cradle to grave" approach regarding the
disposition of ACM, responsibility for the ultimate fate of Category I ACM rests with all
individuals involved in handling the material.

Landfills

Category I and n ACM that has become RACM roust be disposed of in a landfill that
operates in accordance with 61.150 and 61.154, or in an EPA-approved conversion facility
described in 61.155 of the asbestos NESHAP.

Category I and n nonfriable ACM which has not become RACM during demolition may be
disposed of in a landfill that normally accepts construction debris.  However, if Category,! or
n nonfriable ACM is sanded, ground, cut or abraded before it is buried at the landfill, it is
subject to the asbestos NESHAP.

Recycling Centers

At the present time. EPA does not allow either Category 1 or n nonfriable demolition debris
to go to any facility (e.g., a cement recycling facility) that will sand, grind* cut or abrade it or
otherwise mm it into RACM waste.  Recycling facilities which cause non-RACM waste to
become RACM waste are subject to the provisions of the asbestos NESHAP (See Appendix
Conversion Facilities

Conversion facilities are addressed in Section 61.155 of the November 1990 revised asbestos
NESHAP. Owners/operator* of such facilities must handle ACWM according to the
provisions- of the asbestos NESHAP,
A92-1225.UI                              6-1
                                                                            TRC

-------
                              APPENDIX I


             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON, D.C 30460
                               MAR  ! 8 1992
                                                            omaot
MS. Ann Bieller, Area Manager
Environmental Management
Southwestern Bell Telephone
Procurement Organization
500 North Broadway, Room 1400
St. Louis, Missouri 3102

Dear Ms. Bieller:

     This letter is in response co your January 28, 1992 letter
requesting a clarification of 40 CFR !61.1SO(a)(3)  as it relates
co 561.145(c) (1) U) and (iv), of the Asbestos NESHAP Revision;
Final Rule, dated November 20, 1990.

     In your letter, you present your understanding that there are
no special retirements for adequately wetting Category I or
Category II nonfriable asbestos-containing material (ACM) during
the course of a demolition or renovation it it does not meet the
definition of regulated asbestos-containing material (RACK).  You
also state that this conclusion is further supported by
61.150(a)(5), tinci! S61.150(a)(3) is taken into consideration.
Section 61.1SO(a)(3) requires, 'for facilities demolished where
RAQt is not removed prior to demolition according to
SS61.145(c) UMi),  and (iv).

     Section frl.!50(a)(3) correctly cites
561.145(0 UMi), (ii), (iii) and (iv).  It is required under
S61.150(a) (3) that asbestos-containing wast* material be kept
adequately wet.  Asbestos-containing wast* material as applied to
demolitions and renovations includes RACH wast* and materials
contaminated with asbestos including disposable equipment and
clothing.  Category I or Category II nonfriable ACM that has been '
contaminated by RACK, and cannot be decontaminated (e.g., building
debris in a pile contaminated with RACK) must be treated as
asbestos-containing wast* material.  Category I or Category II ACM
that does not meet the definition of RACM after a demolition or
renovation, and is not contaminated with RACM, is not asbestos-
containing waste material and is not subject to the wetting
requirement of S61.150U) (3).

-------
                                  -2-

       If,  afcer  a .demolition,  material  left in the facility
 'according to 561.145(c)(1)(i) or (iv)  is  intentionally ground-up
  (such as  by repeatedly  running over,  the debris with a bulldozer to
  compact the material),  then 61.150(a)(3)  applies.  The material
  must  be adequately wetted  and kept adequately wet during
  collection and  transport to a site or  facility operated in
  accordance with 561-154 or $61.135.  However, if  the bulldozer is
  moving the debris or picking  it  up to  be  put  in a vehicle and
 inadvertently runs over Category I material,  then it is not
  subject to the  NESHAP standard.

       Category I or II nonfriable ACM that i*  not  subject to
  561.150(a)(3) would still  have to be disposed of in a landfill
  that  accepts building debris, in a landfill that  operates in
  accordance with 561.-154, or at a facility that operates in
  accordance with $61,155,   This waste material would not be allowed
  to go to  any facility that would sand, grind, cut or abrade  the
  hon-RACM  waste  or otherwise turn it  into  RAOf waste  (such as a
  cement recycling facility).   In  addition,  if  Category I or II     -t
  nonfriable ACM  is sanded,  ground, cut  or  abraded  during disposal  '
  at a  landfill,  before it is buried,  it is subject to the NESHAP.  ;

       This response has  been coordinated with  EPA's office of
^Enforcement and with the Emission Standards Division of the  Office
  >f Air Quality  Planning and Standards.. If you have any questions,
  please contact  Tom Ripp of my staff  at (703)3?88-I727.
                                  Lchard Biondi,  Acting Director
                           Stationary Source Compliance Division   ,
                        Office of Air Quality Planning and Standards
                                                                  v
  cc:   Sims Roy,  BSD (MD-13)
       Omayra Salgado,  SSCD (EN-341W)
    .   Scott Throve, SSCD (EN-341W)
       Charlie Garlow,  OE (LE-134A)
       Regional Asbestos NESHAP Coordinators

-------