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Guidelines for Enhanced Management of
Asbestos in Water at Ordered Demolitions
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EPA-453/B-16-002a
July 2016
Guidelines for Enhanced Management of Asbestos in Water at Ordered Demolitions
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division
Research Triangle Park, NC
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US EPA
Office of Air Quality Planning and
Standards
Sector Policies and Programs Division
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Acknowledgments
Susan Fairchild, Office of Air and Radiation / Office of Air Quality Planning and Standards
John Pavitt, USEPA Region 10
Ann Strickland, Office of Enforcement and Compliance Assurance / Office of Criminal
Enforcement, Forensics, & Training
Everett Bishop, Office of Enforcement and Compliance Assurance/ Office of Compliance
Pamela Mcllvaine, USEPA Region 4
Steve Anderson, Office of General Counsel / Air and Radiation Law Office
Andrea Kirk, Office of Land and Emergency Management/ Office of Superfund Remediation &
Technology Innovation
Brian Schlieger, Office of Land and Emergency Management / Office of Emergency
Management
Terry Smith, Office of Land and Emergency Management / Office of Emergency Management
Gilberto Irizarry, Office of Land and Emergency Management / Office of Emergency
Management
Cover Photo: Water is used to control asbestos at ordered demolitions where asbestos remains
in place during demolition activity. Water can act as a slurry, carrying asbestos-bearing
sediments and other pollutants offsite to be deposited elsewhere if not contained and
managed onsite. In this photo, the sidewalk acts as a berm to contain demolition water and
prevent contamination of other areas. Photo courtesy of John Pavitt, USEPA Region 10.
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Contents
Figures iii
1 Executive Summary 1
2 How to Use this Document 3
3 Overview of Identified Enhanced Management Practices 6
4 Preparatory EMPs 6
4.1 Personnel Assignments 7
4.2 Training 7
4.3 Inspections 7
4.4 Reporting and Recordkeeping 8
4.5 Work Plan Development 9
4.6 Estimate Resources Needed for Project Completion 11
4.6.1 Evaluate Each Site's Characteristics on a Case-by-Case Basis 11
4.6.2 Plan for precipitation events 11
4.6.3 Site Assessment 11
4.6.4 Contingency Plans 17
4.6.5 Example Calculation 18
4.7 Use the Variance and Demolition Permit Processes to Evaluate and Enforce Requirements of
the Work Plan 18
5 Field EMPs 19
5.1 EMPs to Contain and Manage Demolition Water 20
5.1.1 Primary EMPs 20
5.1.2 Secondary EMPs 26
5.2 Tanks 27
5.3 Field Examples 27
5.3.1 EMP: Berms and Absorbents on a Sloped Site 27
5.4 EMP: Diversion Slurry Pumping System and Slurry Capture Mats 27
5.5 EMP: Vacuum Trucks 28
5.5.1 EMP: Low-volume misting nozzle to adequately wet ACM 28
5.6 EMP: Use a Wetting Agent for most effective Fiber Adhesion and Control: 30
5.7 Dedicated Wetting for Pipe Wrap 31
5.8 Decontamination of Waste-Hauling Vehicles 31
6 Post-Demolition Clean Up and Site Preparation 31
6.1 EMP: Segregate Asbestos-Containing Waste Materials 31
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6.2 Post-Demolition Clean Up Activities 32
6.2.1 EMP: Filter Post-Demolition Wastewater 32
6.2.2 EMP: Post-demolition Wastewater Testing 32
6.3 EMP: Remediate Soils at the Demolition Site and Surrounding Areas 33
6.4 Cross Reference to Selected Relevant Federal Regulations 35
7 Appendices 1
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Figures
Figure 1. Thefibrous mineral anthophyllite asbestos as seen usingTEM 1
Figure 2. This photo illustrates the practical need for adequate wetting of asbestos contaminated
materials. Dust containing asbestos is released when ACM are not removed prior to demolition. (EPA
Photo courtesy of John Pavitt, Region 10) 4
Figure 3. Training is needed to safely inspect buildings and to identify asbestos containing materials. US
EPA photo 8
Figure 4. Ordered demolition of a structure on sandy soil in a coastal area. Water drains readily through
this soil, and asbestos carried by the demolition water becomes embedded in the sandy soil. Photo
courtesy of Pam Mcllvaine, US EPA and Robin Mack, SCDEQ 13
Figure 5. The surrounding sidewalk functions as a berm at this demolition, (EPA photo courtesy of John
Pavitt, Region 10) 21
Figure 6. A filter array that is designed to hold filters of sequentially decreasing pore size 22
Figure 7. Examples of filters used for asbestos removal in the array in Figure 6. Photo courtesy of John
Pavitt, USEPA Region 10. No endorsement implied. Information included for instructional purposes only.
22
Figure 8. Water from a building demolition drained into the basement and was pumped to this tank
(circled in picture) for settling before filtration to remove asbestos and other pollutants. Photo courtesy
of John Pavitt, US EPA Region 10 23
Figure 9. A carbon-filter within this 60-gallon drum is used to remove hydrocarbons and asbestos from
water collected in settling tank. Photo courtesy of John Pavitt, US EPA Region 10. No endorsement is
implied. Information is included for instructional purposes only 23
Figure 10. After filtration and testing of demolition water showed the water met effluent standards, it
was released into the stormwater drain adjacent to the demolition project. Photo courtesy of John
Pavitt, USEPA Region 10 24
Figure 11. Sawdust-stuffed burlap tubes are weighed down with sandbags in 'U' and 'J' shapes (EPA
photo courtesy John Pavitt, Region 10) 26
Figure 12. This is an example of one type of low pressure misting nozzle, which is used to suppress and
control dust. No endorsement is implied. Information provided for instructional purposes only 28
Figure 13. A machine delivering an atomized mist keeps materials adequately wet. This work is being
conducted at a lead-remediation site with compliance requirements similar to the Asbestos NESHAP.
(Photo used with permission from DustBoss, 2015). No endorsement is implied. Illustration provided for
informational purposes only 30
Figure 14. Pipe wrap is frequently hidden and may be difficult to find. Special wetting agents may be
needed for pipe wrap 31
Figure 15. Micro-vac sampling is one method that may be used to indicate that non-porous surfaces,
such as this asphalt parking lot, have not been contaminated by asbestos after the ordered demolition
of the hotel featured in Figure 4. Photo courtesy of Pamela Mcllvaine, US EPA Region 4. Error! Bookmark
not defined.
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1 Executive Summary
Asbestos is a type of mineral that has been mined and used in commercial products for many
years. While there are currently no operating mines or milling operations in the US, asbestos is
still used in commercial products both manufactured in, and imported into the US. Asbestos
may be found in building materials such as pipe wrap, wall board, flooring materials, ceiling tile,
insulation, siding, and roofing materials. Asbestos has not been banned in the US, so many
buildings, even recently constructed structures, may have asbestos-containing materials in
them.
The primary route of exposure to asbestos is through inhalation of the mineral fibers (see
Figure 1). Several pulmonary disorders may be caused by exposure to asbestos, including lung
cancer; mesothelioma, a rare form of cancer that is found in the thin lining of the lung, chest
and the abdomen and heart; and asbestosis, a serious progressive, long-term, non-cancer
disease of the lungs. There is no known safe level of exposure to asbestos.
The EPA has identified enhanced
management practices (EMPs) from existing
regulations, guidance, and State and local
government rules and policies and has
collected them here to provide guidelines to
owners/operators, demolition contractors,
and State and local agencies to use to
prevent the release of asbestos to the
environment when asbestos-containing
materials remain inside the building during
demolition. EPA identified and requested
participation from experienced subject
matter experts throughout the Agency to
contribute information on examples of the
most enhanced management practices used
for asbestos control and abatement. The EPA
also consolidated relevant excerpts and
portions of existing regulations, guidance
documents, and other relevant materials
into this document. We consulted with asbestos program professionals as well as EPA's
National Pollutant Discharge Elimination System (NPDES) Construction Stormwater program to
learn about program practices that prevent the migration of contaminated water from the
Figure 1. The fibrous mineral anthophyllite asbestos as seen using
TEM.
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These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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demolition site and reduce the potential for asbestos exposure due to evaporation and
redistribution of asbestos fibers.
This document may be distributed by various means, including to EPA Asbestos Coordinators
and state asbestos programs, at technical conferences and symposia, and through EPA's
Asbestos website.
These voluntary guidelines do not change or substitute for any statutory or regulatory
provisions. The statutory provisions and EPA regulations contain legally binding requirements,
and to the extent any statute or regulatory provision is cited in this document, it is that
provision, not this document, which is legally binding and enforceable. Thus, these guidelines
do not impose legally binding requirements, do not confer legal rights or impose legal
obligations on anyone, or implement any statutory or regulatory provisions.
This document presents current technical information and recommendations of the Office of
Air and Radiation (OAR)'s Office of Air Quality Planning and Standards (OAQPS), based on
OAQPS's current understanding of a range of issues and circumstances involved in asbestos
handling during demolition operations. The document contains information and
recommendations designed to be useful and helpful to the regulated community, states, tribes,
local governments, and the public. The word "should" as used in this document is intended
solely to recommend or suggest and does not connote a requirement. Similarly, examples are
presented as recommendations or demonstrations, not as requirements. To the extent any
product, trade name or company appears in the document, their mention does not constitute
or imply endorsement or recommendation for use by either the United States government or
EPA. Interested parties are free to raise questions and objections about the appropriateness of
the application of the examples presented in this document to a particular situation. In short,
use of the guidelines provided in this document is voluntary.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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2 How to Use this Document
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The purpose of this document
is to disseminate information
on enhanced management „ .... 4.4.1
Demolition water can act as a slurry, carrying
practices (EMPs) for planning , . r., ff .. , .. ,
asbestos fibers off site where evaporation leaves a
demolition work and for .. .. rr., u- u 4-u u
collection of fibers which then may become re-
controlling, containing and . . , . . ., ,. . .
*" entrained into the ambient air.
managing asbestos-
contaminated demolition
water. The EPA identified
EMPs in two key areas: 1) preparatory: advanced planning and allocation of resources, and 2)
field: on site operational procedures, demolition activities, and site remediation. These
management practices are useful when addressing potential releases of asbestos to the
environment that may occur when demolitions of buildings that are structurally unsound and in
danger of imminent collapse are conducted in compliance with the requirements of the
Asbestos NESHAP (see Figure 2). The EMPs described in this document may be used to mitigate
the potential risk associated with asbestos exposure from such building demolitions.
The intent of these EMPs as applied to structurally unsound building demolitions is to prevent
demolition wastewater from carrying asbestos off-site. However, EPA recommends that EMPs
be a primary consideration in all building demolition projects having the potential for asbestos
exposure, especially those buildings that are declared structurally unsound and in danger of
imminent collapse. These EMPs are ways to manage water and water-borne pollutants on-site
that prevent their migration off-site. We therefore recommend that EMPs be a primary
consideration in all building demolition projects having the potential for asbestos exposure. For
these guidelines, EMPs are classified as either preparatory (advance planning) or field
(demolition and clean-up) EMPs.
These guidelines can be used to inform demolition contractors, local and State environmental
offices, and EPA Regional offices of effective methods to minimize release of asbestos fibers,
and to reduce the movement of asbestos fibers in water from wetting debris at an ordered
demolition site.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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We recommend State and local agencies, demolition contractors, and city planners use this
document when building demolitions are being planned, scheduled and started with asbestos-
containing building materials to remain in place during demolition. This can occur under
NESHAP-compliant demolitions in three ways: 1) when asbestos containing materials (ACM) are
below regulatory
thresholds;1 2) the ACM is
not expected to become
friable;2 and 3) when an
ordered demolition under
the Asbestos NESHAP's
imminent danger of
collapse requirement
occurs with ACM remaining
in place3.
Accessible asbestos should
be removed prior to
demolition, even for
structurally unsound
buildings. For example,
consider a scenario in
which one wall of a building
is leaning over and ready to
collapse. The leaning portion is declared by the Order to be in danger of imminent collapse.
That wall would be pushed over, and abatement should be performed in other parts of the
otherwise structurally sound building. So, as described in this scenario, during a NESHAP-
compliant demolition, under existing guidelines, some asbestos (i.e., that on the leaning wall)
would not be removed and some (i.e., that on the structurally sound parts of the building)
would be removed.
Figure 2. This photo illustrates the practical need for adequate wetting of asbestos
contaminated materials. Dust containing asbestos is released when ACM are not
removed prior to demolition. (EPA Photo courtesy of John Pavitt, Region 10).
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When ACM is not removed prior to demolition, it can be made friable during the demolition
process. As the structure is demolished, dust, including asbestos, is typically controlled by a
water spray. This dust may be comprised of pulverized construction materials including cement
dust, gypsum, wood fibers, plastic, and asbestos fibers. Without careful planning and good
140CFR§61.145(a)(2).
2 40 CFR § 61.145(c)(l) (specifying the circumstances).
3 The appropriate state or local government authority can, through an "Order", declare a building/facility to be
structurally unsound and in danger of imminent collapse. If such an Order is given, the Asbestos NESHAP specifies
a subset of requirements than would otherwise apply. See 40 CFR § 61.145(a)(3).
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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controls, the demolition water can seep into soils or act as a slurry, carrying asbestos fibers off
site where they may contaminate the surrounding environment. These re-entrained fibers,
when dried, are likely to be released into the ambient air. Reference to regulations for asbestos
management, control and reporting are included in the appendices to these guidelines. A
checklist (see Table 1) is included to assist project managers, planners and staff with the various
considerations that are likely to affect successful demolition projects.
Table 1. Checklist for water management at ordered demolitions.
Has a certified asbestos inspector provided an inspection report of
the building(s) to be demolished?
Has a Work Plan been developed for demolition of building(s)?
Does the Work Plan comply with all applicable local ordinances, and
State and Federal rules?
Does the Work Plan include planning for contingencies, such as
weather events, interruption in electric service, water, or other
utilities?
Does the Work Plan incorporate EMPs for the surface and soil types
present at the demolition?
Do all personnel assignments reflect the appropriate level of
expertise for the work expected to be performed, per the work plan?
Are the training requirements for all personnel up to date?
Have regular meetings been scheduled for effective communication?
Have weather forecasts been checked for possible weather events?
Have satellite imagery, geospatial maps and the site terrain been
reviewed by the project manager to check the expected direction of
water flow against the locations of placed berms and barriers?
Have the surfaces and surface soils been evaluated at the work
site?
Have sufficient resources been allocated for the demolition, cleanup,
and remediation work?
Have all water management tools and equipment been ordered and
are these expected to be delivered to the work site in time to prepare
the site for the planned demolition work?
OTHER TO Dos:
YES/NO
DATE
If no, explain:
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These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Each site should be evaluated on a
case-by-case basis, to include in the
work plan useful practices for the
management and control of ACM.
3 An Overview of Identified
Enhanced Management
Practices
Several State and local agencies have
developed specific guidance and/or
requirements that address the management,
control and abatement of asbestos contamination in water (both water to provide adequate
wetting of the ACM and worker shower water) used at asbestos demolition sites. For example,
the Spokane (WA) Clean Air regulations require that building owners or operators submit an
Alternative Work Plan if they believe they need to leave asbestos in place during a demolition.
The city's work plan may be required to include a number of administrative and planning
requirements.
In the state of Washington, discharges under the state's Construction Stormwater General
Permit must not cause or contribute to a violation of surface water quality standards (Chapter
173-201A WAC), groundwater quality standards (Chapter 173-200 WAC), sediment
management standards (Chapter 173-204 WAC), and human health-based criteria in the
National Toxics Rule (40 CFR Part 131.36). Discharges not in compliance with these standards
are not authorized under the Washington State Construction Stormwater General Permit.
Preparatory EMPS are pre-demolition institutional designs, planning strategies, resource
allocation, and documentation of plans to prevent or reduce the release of pollutants into the
environment as a result of a demolition operation. Examples include development of a work
plan, formation of a pollution prevention plan, contingency planning, correct application of
relevant regulations, worksite design optimization, appropriate employee training, scheduling
sufficient inspections of worksite before and during demolition, use of aerial and geological
mapping resources, reporting, and record keeping.
Field EMPs are practices, operations, and strategic use of engineered supplies and equipment
to prevent and reduce pollutants from entering the environment during and after the
demolition operation. Examples include: good housekeeping practices; preventive
maintenance procedures; the use of barriers, berms, absorbent media, covers, and vacuum
trucks; collection, treatment and disposal of excess water; spill prevention; and site
remediation.
4 Preparatory EMPs
Preparatory source control EMPs in conjunction with field EMPs could be a very cost-effective
practice to minimize fiber release during an ordered demolition. For the preparatory EMPs, the
coordinated development and implementation of a work plan is an approach to proper
management and control of asbestos fiber release during the demolition operation. The work
plan should consider site terrain, soil type and permeability, topography, available utilities, and
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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potential contingency plans. Citations to all Federal rules that may apply (i.e., the Asbestos
NESHAP, TSCA, CERCLA, NPDES construction storm water regulations), as well as to the
applicable Federal, State and local rules and requirements, help to ensure that personnel are
knowledgeable in regard to rules governing the work, and that all work complies with the
applicable regulations. A well-defined distinction between regulatory requirements and
recommended work practices provides clarity when adaptations to a plan are needed or
flexibility is appropriate.
4.1 Personnel Assignments
• Consider assigning one or more individuals to be responsible for demolition water pollution
control.
• Establishing clear lines of responsibility for inspections, operation, maintenance, and
emergencies is effective for organizing field responsibilities and preventing overlap or
omissions of field activity protocols.
4.2 Training
Certain training requirements are already in place under regulations governing the removal
work for asbestos-containing materials under OSHA and EPA. Beyond these requirements, we
recommend additional training for management of asbestos-contaminated demolition water.
These include training in:
• Effective control measures for asbestos-contaminated waste water
• Response to releases of asbestos-contaminated waste water
• Environmentally acceptable handling practices for asbestos-contaminated waste water
4.3 Inspections
Certain inspection requirements apply under the Asbestos NESHAP (see appendices). Beyond
these requirements, we recommend additional inspection measures. We recommend
establishing and maintaining an on-site record of each inspection that:
• Identifies the ACM as provided by the inspector4
• Verifies that the field EMPs are functioning as intended
• Describes the current site conditions, meteorology, geography, etc.
• Includes written observations of the presence of suspect ACM in debris that is being
wetted
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op 4 This can be very limited as the inspector may not be able to collect samples due to the building being structurally
unsound and in danger of imminent collapse.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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We recommend that the building
construction date and any renovation dates
be noted in the inspection report and the
permit. These dates cannot be used to rule
out the presence of asbestos because
asbestos-containing building materials are
Figures. Training is needed to safely inspect buildings and to stj|| founc| jn commercial products.
identify asbestos containing materials. US EPA photo. ,, , . .
However, construction dates and
renovation dates can be used to indicate
the likelihood of the presence of asbestos. For instance, a building constructed in 1990 may
have asbestos-containing materials such as vinyl asbestos floor tile, roofing materials,
vermiculite insulation, and other such asbestos-containing materials. A building constructed
prior to 19785 very likely has such materials, to the extent that many types of building materials
from that era (paint, sheetrock, carpet, mastic, floor tiles, pipe wrap, ceiling texture, spray-on
fireproofing, etc.) widely contained asbestos.
The information available in the inspection report should be used to develop the work plan.
The inspection report identifies asbestos-containing materials in those parts of the building
which are accessible for sampling. It identifies the types of building materials which can be
segregated and where in the debris demolition water should be collected and sampled for
movement of asbestos fibers.
4.4 Reporting and Recordkeeping
We recommend a minimum 3-year retention period for inspection reports, reportable quantity
reports, and other records. The inspection reports should include:
• Time and date of the inspection
• Locations inspected
• Statement on status of compliance with regulations and the permit
• Summary report of any remediation activities required; and the
• Name, title, and signature and training of the person conducting the inspection
We recommend that both the owner and operator maintain records of all related pollutant
control and pollutant generating activities such as training, materials purchased, material use
and disposal, water analysis, water collection and disposal, maintenance performed, etc. All
inspections and maintenance conducted during demolition, removal and support activities
should be recorded in writing and retained with the work plan.
5 The Asbestos NESHAP was first promulgated on April 6,1973, and included regulations for manufacturing,
fabricating new products, demolition work practices, and limited spray-on insulation to 1% asbestos content. EPA
successfully banned all sprayed-on application of asbestos, such as fireproofing, in 1978. However, EPA did not
propose a ban on asbestos in manufactured products until 1989, and, on October 18,1991, the U.S. Court of
Appeals for the Fifth Circuit vacated and remanded most of that rule. Consequently, numerous building materials
00 are still manufactured or imported using asbestos, including asbestos cement (AC) corrugated sheet, AC flat sheet,
DO asbestos clothing, pipeline wrap, roofing felts, vinyl asbestos floor tile, AC shingles, millboard, AC pipe, roof
Q- coatings, and automotive parts and products.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Documentation may include aerial or CIS photographs with markings indicating the site
boundary, work area, points of entry, clean water tanks, wastewater tanks, waste piles, fences,
ditches, berms, absorbents, conduits and other similar marking overlaid onto photos of the
work site. Planning the locations of these added elements on a work site can help to prevent
incorrect assumptions of best locations, inadvertently locating too many elements in one place,
or locating them in such a way that access to critical areas is impeded or blocked. Planning the
locations of these elements on top of the topographical maps also allows planners to check that
berms and absorbents are located on the correct downward facing slopes, conduits are located
below to receive runoff, wastewater tanks are located further below to contain all runoff, and
ditches are dug in the areas that allow best drainage of off-site storm water. All photographs of
work, test results, project plan, inspector's checklists and reports, etc. may be retained and
made available if the property is under contract for resale. Retention of these materials
indicates how the demolition work was conducted and whether problems arose during
demolition or asbestos waste handling. Complete documentation of a well-managed demolition
operation promotes prompt resolution of site status and may also be needed for later real
estate transactions.
4.5 Work Plan Development
The objective of the work plan is to lay out the procedures for ensuring the control of asbestos-
contaminated water and to prevent asbestos and other pollutants from leaving the site during
the demolition operation. A site-specific work plan can be developed and implemented for each
demolition that is to be conducted with asbestos-containing materials left inside the building.
You may also consider incorporating the work plan into the stormwater plan that is submitted
to the State, if one is required at the site.
For these guidelines, we reviewed several work plans provided by demolition contractors to
State and Federal authorities engaged in demolition activities. Many of these work plans are
publicly available. Appendix 3 provides example work plans that identify EMPs, many of which
appear in these guidelines. For additional EMPs that may be useful in controlling water runoff,
please see http://water.epa.gov/polwaste/npdes/stormwater/Stormwater-Discharges-From-
Construction-Activities.cfm
The following list identifies options for EMPs that may be considered for inclusion in a work
plan.
1. The work plan should account for removal and/or management of all suspect ACM
identified in the inspection report.
2. Experienced licensed and accredited asbestos abatement professionals should review
and approve the work plan prior to beginning the demolition operation.
3. The work plan should include a schedule of inspections. Unsound portions of a building
should be inspected to the extent possible to identify ACM.
a. The work plan should include the submitted 10-day Notification Form. If a
building cannot be entered because it has been declared structurally unsound
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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and in danger of imminent collapse, the work plan should identify all suspect
ACM/RACM. In lieu of this, all materials in the demolition debris pile should be
suspected to contain or be contaminated by asbestos. A copy of the Demolition
Order should be included in the work plan.
4. The inspection reports should be attached to the work plan along with the results of any
sampling/analysis conducted on the post-filtration wastewater before disposal.
a. Schedule with asbestos inspectors to attend the demolition and to conduct
regular site visits.
b. Routinely inspect the demolition site during the active demolition, removal and
support activities and within 24 hours after any significant weather event, such
as additional water burden due to a rainfall event, high winds, hail, or other
severe weather events. These events can impact the demolition site by
overburdening runoff diversion systems, moving or dislodging berms, conduits
and barriers, and shorting out electrical services.
c. Critical operations in locations that that have the potential to generate a
significant amount of sediment or fugitive dust should be inspected at the end of
the work day to ensure the integrity and effectiveness of structural EMPs at the
worksite.
d. The work plan may require inspector reports, but a standard reporting form can
be used to streamline the reporting process
5. The work plan should identify all the EMPs that are to be used for the management of
abatement and shower water, contingency plans, stop work provisions for any
departure from the work plan, and site remediation. The work plan should specify the
type of demolition equipment to be used, including but not limited to misting nozzles,
water amending chemicals (i.e., detergent), demolition vehicles, and personal protective
equipment (PPE).
6. Inspections that incorporated the placement of signage can help prevent releases to soil
and stormwater inlets. For instance, the posting of signs on wastewater tanks
("Asbestos-contaminated water, Do not release") and on worksite perimeter washing
stations ("Wash all equipment prior to exit"). Additionally, signs should be considered
for the worksite perimeter. Signage on the exterior of the perimeter can warn
trespassers from entering the site at any point and seek the proper entrance; and
signage can remind workers to doff their PPE and use the sanitation station before
exiting.
7. Include in the work plan specific areas to note fulfillment of the work plan provisions
(like checked boxes), replacements to planned EMP, other departures from the plan,
and all instances in which stop-work orders were given. The prevailing wind direction
and rainfall during the days of demolition should also be noted. By including these items
in the work plan, it can be used as a record of adherence to EMPs.
8. Scheduling and conducting regular meetings to review the overall operation of the EMPs
O can nelp identify weaknesses and problems in advance of field demolitions.
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These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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4.6 Estimate Resources Needed for Project Completion
Aspects of careful demolition project planning include
the assessment of available resources and an estimate
of the resources needed for completion of the project.
Each project presents site-specific challenges, and
should be reviewed on a case-by-case basis. The
following sub-sections present some aspects of project
planning that can be used in evaluating the site and
allocating appropriate resources to a demolition
project.
...it is easier and less costly to
prevent contamination of a site
than to abate it through the
remediation process...
4.6.1 Evaluate Each Site's Characteristics on a Case-by-Case Basis
Suspect ACM that might be visible to a trained inspector include materials such as vinyl
asbestos floor tile, carpeting, mastic, and 'popcorn' ceiling spray texture. Other sources might
not be visible if the building cannot be inspected. These include materials behind walls (e.g.,,
electrical insulators, thermal insulation spray or batts), beneath floors (e.g., pipe wrap, vinyl
asbestos floor tiles, mastic, carpet backing, impact deadening compound) and above ceilings
and in stairwells (e.g., vermiculite attic insulation, asbestos insulation, spray-on fire proofing,
pipe wrap, roofing sealants). These are examples of common sources of asbestos materials that
can contaminate demolition water. The EPA published in the Federal Register the responses to
the Asbestos Information Act, a one-time listing of products known to contain asbestos based
on industry responses, which can be found in Appendix 2 to this document. For more
information on asbestos containing materials, you may also refer to EPA's website at:
http://www2.epa.gov/asbestos/learn-about-asbestostffind
4.6.2 Plan for precipitation events
Rainfall can adversely affect containment at an asbestos demolition worksite, especially if high
amounts of precipitation fall in a short period of time. We recommend during resource
planning, the purchase of water diversion structures such as berms, straw, hydromulch, and
slash mulch. We advise reserving a slurry pumping system, tanks, and/or slurry capture mats to
absorb excess storm and demolition waters.
4.6.3 Site Assessment
The steepness of the terrain, the permeability of the soil, the direction of slope, potentially
impacted areas (that could receive wastewater in the event of an unexpected release),
presence and locations of ditches and catch basins, stormwater and sanitary sewer locations,
and proximity to locations of concern (such as daycare centers, schools, playgrounds, parks, and
high density population centers) are some of the factors to consider when assessing the EMPs
needed fora site.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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4.6.3.1 Utilize Available Aerial Photography, Geospatial Maps, and Other Tools
As illustrated by several available work plans, it may be useful to include aerial photography or
satellite imagery in the work plan. Site boundaries; locations of rivers, streams, and other
bodies of water; storm water access points; residential areas; and EMPs protecting these areas
may be indicated in the aerial photographs for reference and planning. Aerial images may be
superimposed over topographical (geospatial) maps to check water flow paths.
4.6.3.2 Evaluate the Terrain
The terrain at the demolition site and surrounding area can influence the types of supplies that
are planned to be used at the site for control and management of demolition water. Multiple
methods of control and direction may be warranted depending on the terrain. For instance, a
primary control and a secondary backup control may be useful to control runoff on steep
inclines with low permeability such as paved surfaces.
Absorbents are "first line" containment and should be followed by berms/directional apparatus
or other secondary controls. An EMP for directional flow construction is the use of plastic-
coated, non-porous barriers or berms. These are used to divert runoff to waiting drainage
tank(s) and may be cleaned and re-used afterward. Earthen berm barriers can be constructed
surrounding the demolition sites, but cannot be cleaned and must be disposed of with the
other waste materials that contain or have been contaminated with asbestos, in compliance
with the waste disposal requirements of the Asbestos NESHAP.6
When the primary control is undergoing replacement, repair, maintenance, or cleaning, a
backup control can be in place to direct any demolition water into waiting conduits to a
collection tank. Consider a tertiary control for the unexpected situation where a backup control
fails.
All materials contaminated with asbestos resulting from the demolition, including segregated
RACM, absorbents, earthen berms, contaminated soils, and filter cakes, must be disposed of as
asbestos-containing waste material.
4.6.3.3 Evaluate the Soil and Surfaces
Water always runs downhill seeking the lowest place. Water will drain directly through soils
that are highly permeable, such as gravelly, sandy or loamy soils (Figure 4). When the
surrounding surface is non-permeable, such as with asphalt, concrete, or similarly impenetrable
materials, demolition water can be expected to run downhill if the site is not level, and to pool
in low spots. Consider protecting surrounding soils using plastic sheeting embedded below the
runoff level. Consider studying the area on topographic maps (available from the State
Geological Survey office) to anticipate the likeliest direction, depth, and path of water flow.
Place drainage conduits and other collection apparatus to direct wastewater to leak-proof tanks
for containment and later filtration.
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6 see 40 C.F.R. section 61.150.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Figure 4. Ordered demolition of a structure on sandy soil in a coastal area. Water drains readily through this soil, and asbestos
carried by the demolition water becomes embedded in the sandy soil. Photo courtesy of Pam Mcllvaine, US EPA and Robin Mack,
SCDEQ.
4.6.3.4 Include Factors Related to Soil Permeability in the Work Plan
Soil permeability is defined as the capacity of the soil or rock to allow fluids to pass through it.
This is important because the permeability of the soil determines the extent to which asbestos
in water runs off soils at the surface, or penetrates through soils at the surface. Asbestos-laden
water that is released into highly permeable soils, such as sandy loose soil, can deposit asbestos
at depths of a foot or more of soil7. Soils that are impermeable, such as highly plastic clays, are
more likely to be contaminated by asbestos nearer to the surface, but problems associated with
runoff, capture and containment should be anticipated when permeability is extremely low.
When the permeability of the soil is evaluated, the appropriate EMPs can be planned, and
measures can be taken to prevent absorption of demolition water and/or water runoff that
may impact neighboring areas or streams. Table 1 shows the permeability of common soils, as
evaluated by Geotech in 2013.
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7 Improper demolition methods at Bainbridge Naval Training Center in 1996 resulted in contamination of the soils
at the site at depths of about 8 inches. In that cleanup, the asbestos-contaminated soil at the site was removed
until sampling and analysis showed the remaining soil was below background levels of asbestos.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Permeability may be represented by the permeability coefficient (k) through Darcy's equation8:
V=ki
Where:
V is the apparent fluid velocity through the medium
i is the hydraulic gradient, and
k is the coefficient of permeability (hydraulic conductivity) often expressed in m/s
The permeability coefficient (K) depends on the relative permeability of the medium for fluid
constituent (often water) and the dynamic viscosity of the fluid as follows:
K=(rw)*K/(|i]
Where:
rw is the unit weight of water
u. is the dynamic viscosity of water, and
K is an absolute coefficient depending on the characteristics of the soil.
Hazen's equation9 may be used to estimate the coefficient of permeability for sands:
where £>10 is the effective grain size, in millimeters.
4.6.3.5 Evaluate and Estimate Building Size and Materials
The debris pile will not have a greater volume than the intact building, so an estimate of the
maximum volume of the debris pile is length X width X height of the building. Alternatively, the
architectural plans of the building may be available from the building department of the
municipality. Unless the building can be safely entered to determine the volume of its contents,
8 The law of flow of water through soil was first studied by Darcy (1856), who demonstrated experimentally that
j- for laminer flow conditions in a saturated soil, the rate of flow or the discharge per unit time is proportional to the
—I hydraulic gradient.
DO 9 Hazen's equation is the most accepted method to predict the saturated hydraulic conductivity, k, of clean sand
Q- and gravel.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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it is safest to estimate the maximum debris pile size and be able to scale down from there to
the size of the actual debris pile.
It may be possible to remove and recycle some building materials prior to demolition. However,
once the building is down, if the ACM have not been removed first, asbestos contaminates the
entire waste pile and it is considered asbestos containing waste material. The entire waste pile
must be disposed of properly.
Pipe wrap: estimate the length and diameter of pipe wrap, and apply the EMPs for pipe wrap.
Assume the pipe wrap is amosite asbestos if sampling and analysis cannot be conducted due to
the structural integrity of the building. Amosite repels water, even when it is amended with
surfactants that are effective on other types of asbestos. Special considerations are appropriate
for situations in which pipe wrap is present10.
Vermiculite: when vermiculite is present (typically as attic insulation and in the interstitial
spaces of cinder block buildings), special care is recommended for demolition. The EPA, the
Agency for Toxics Substances and Disease Registry (ATSDR), and the Center for Disease Control
(CDC) released a joint guidance document on vermiculite, which can be accessed through the
EPA's website at: https://www.epa.gov/asbestos/protect-vour-familv-asbestos-contaminated-
vermiculite-insulation
10 See section 5.7 of this document, "Dedicated Wetting for Pipe Wrap"
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Table 2. Permeability of Common Soils11
LEAST PERMEABLE
««« MOST
Inorganic silts of high plasticity
Inorganic clays of high plasticity
Inorganic clays, silty clays, sandy clays of low plasticity
Organic clays of high plasticity
Organic silts and organic silty clays of low plasticity
Inorganic silts, silty or clayey fine sands, with slight
Clayey gravels, clayey sandy gravels
Well graded sands, gravelly sands, with little or no fines
Silty sands
Silty gravels, silty sandy gravels
Clean sands (good aquifers)
Poorly graded sands, gravelly sands, with little or no
Well graded sand and gravel without fines
Very fine sand, very well sorted
Alluvial sand and gravel
Well graded gravel, sandy gravel, with little or no fines
Poorly graded gravel, sandy gravel, with little or no
Uniform sand and gravel
Peat and other highly organic soils
Medium sand, very well sorted
Coarse sand, very well sorted
min (m/s)
l.OOE-10
l.OOE-10
5.00E-10
5.00E-10
7.00E-10
5.00E-09
5.00E-09
5.00E-09
5.50E-09
l.OOE-08
l.OOE-08
5.00E-08
l.OOE-05
2.55E-05
4.00E-05
8.40E-05
4.00E-04
5.00E-04
5.00E-04
4.00E-03
2.23E-03
3.69E-01
max (m/s)
5.00E-08
l.OOE-09
l.OOE-07
5.00E-08
l.OOE-07
7.00E-08
l.OOE-07
l.OOE-06
5.00E-06
5.50E-06
l.OOE-06
5.35E-04
4.00E-03
5.00E-02
5.00E-02
4.00E-01
1. Swiss Standard SN 670 OlOb, Characteristic Coefficients of soils, Association of Swiss Road and
Traffic Engineers
2. Carter, M. and Bentley, S. (1991). Correlations of soil properties. Penetech Press Publishers, London.
3. Leonards G. A. Ed. 1962, Foundation Engineering. McGraw Hill Book Company
4. Dysli M. and Steiner W., 2011, Correlations in soil mechanics, PPUR
5. West, T.R., 1995. Geology applied to engineering. Prentice Hall, 560 pp.
4.6.3.6 Estimate the amount of water needed to maintain adequate wetting
You can use the site assessment, workplan, number of days needed for demolition, number of
hoses, water nozzle rating (volume of water sprayed per minute) to estimate the amount of
water needed for the demolition and worker hygiene stations (showers). We recommend
adding a 10-20% variance for unforeseen circumstances. Consider bringing spare water tanks
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11 Source: Geotechdata.info. Soil void ratio, http://www.geotechdata.info/parameter/permeabilitv.htm
l(http://www.geotechdata.info/parameter/permeabilitv.html (as of October 7,2013).
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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onsite as a backup in case of municipal water utility disruption in order to maintain adequate
wetting.
Wg = [1.7 xR xDn]
Where
Wg is the total amount of water needed for a demolition, in thousand gallons
R is the volume rating for water nozzles, in gallons per minute
Dn is the duration of the demolition, in days (refer to the workplan).
The nozzle rating (R) is determined by summing the volume rating, expressed in gallons per
minute, for each nozzle to be used:
R = Rl + R2 + R3 ... Rn
Convert to thousands of gallons per day to be used. Here, a 15% variance is included for
unforeseen circumstances:
/ m h\
60 —x 24- -1000 = 1.44x1.15 = 1.7
\ h d/
If you choose to estimate water usage in this way, adjust from a 24-hour day to the actual
period of time that the misting should continue. Many demolitions are completed over an 8-
hour work day. In such cases, estimate water needed for an 8-hour day instead of a 24- hour
day. Other larger scale demolitions may occur over several days. Since the regulated asbestos-
containing materials must remain adequately wet until collected and contained or treated in
preparation for disposal in accordance with the regulations, we recommend evaluating the
total period that the demolition is expected to be conducted to estimate water resources
needed for the demolition activity.
To prevent contamination of bodies of water by asbestos, contain and treat demolition water
prior to release to a stormwater sewer, sanitary sewer, or body of water. Consider bringing
spare wastewater tanks to the demolition site.
4.6.4 Contingency Plans
In general, contingency plans serve to compensate for equipment failures, unforeseen weather
events, and other unanticipated challenges at the work site. Spare nozzles, water amending
chemicals, extra PPE, spare duct tape and 4 mil plastic sheeting, fresh water trucks, spare
wastewater tanks, and electricity generators are examples of field EMPs to include in the
contingency plans. Consider trucking in water to use for demolition activity in the event that
the planned water source is unavailable or is interrupted. Consider including extra leakproof
wastewater tanks in the event a tank is compromised.
Real-time weather forecasts should be updated during the work day so that the on-scene
' - coordinator can remain apprised of weather conditions and can make decisions for the work
gj, site, as needed. Excessive rain can impact the work site if flooding results, potentially
i£. contaminating nearby rivers, streams and lakes, and contributing to a potential violation of the
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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NPDES permit. You may want to consider the total amount of rainfall that is expected during
the demolition and site remediation period, and be prepared to handle stormwater runoff from
the demolition site.
4.6.5 Example Calculation
Example Scenario:
The work plan calls for demolition of a burned out office building (circa 1952) that is structurally
unsound and in danger of imminent collapse and is situated on a third-acre site. In the
emergency response, a debris pile was created which tested positive for asbestos. High
asbestos content of demolition water is expected. The building is situated upon highly plastic
clays having a very low permeability rating. High runoff potential is therefore expected. After
evaluating the site and planning the location of berms, absorbents, a vacuum truck at the
lowest point of the site and water filtration, a resource allocation is made for three low-volume
misting nozzles to be used to maintain an adequately wet site. One nozzle, which has a broad
sweep and rating of 0.6 g/m, is to be used on the debris pile. Two nozzles, each with a wide
diameter spray, and a rating of 0.8 g/m, are to be used on the building (one at the contact
between demolition equipment and the building and the other on interior spaces). The
demolition is scheduled to occur over a 3-day period. Precipitation in the form of rain is a
possibility during the afternoon of one day of the demolition period, and the expected rainfall is
estimated to be no more than 0.25 inches.
Determine How much water will be needed to demolish the building properly.
Using the above equation to estimate the combined nozzle rating:
R = Rl + R2 + R3...Rn
R = 0.6 + 2(0.8) = 2.2g/m
Wg = [1.7 xR xDn]
Wg = 1.7 x 2.2 x 3 = 11.22
Rounding up, we can estimate about 12,000 gallons of water will be needed for the demolition
alone.
Cross-contamination of homes and businesses has occurred in the past from poorly managed
asbestos work sites. Because asbestos should remain in the waste at the worksite to be
properly managed and not taken home with workers, worker hygiene showers should be
planned for the end of each workers shift.
4.7 Use the Variance and Demolition Permit Processes to Evaluate
oo and Enforce Requirements of the Work Plan
CD When an Order is issued for the demolition of a structurally unsound and in danger of imminent
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£ collapse facility, states and/or local environmental agencies may require owners/operators to
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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file a permit request for exemption from the inspection and asbestos removal requirements of
40 C.F.R. Section 61.145. This is also referred to as a 'variance request'. In those situations, the
agency would review the variance request to determine if EMPs are included in the demolition
planning. The variance requests can be used as the vehicle to review work plans, inspector
accreditation records, testing results, and other information indicating what measures will be
taken to contain asbestos under the ordered demolition.
Each site should be evaluated on a case-by-case basis to include in the work plan those
practices that are useful and will be enforced in a variance request or similar enforcement
vehicle.
Under the Clean Water Act (CWA), point sources require CWA permits, but stormwater point
sources are only required to obtain permits if they have been designated to do so. For instance,
if an active construction stormwater point source is below the size threshold designated for
regulation in the NPDES program, a permit is not required under Federal law, but may still be
required by State law.
5 Field EMPs
The preparatory EMPs developed at the desk become field EMPs as they are transferred to the
field at the demolition site. Field EMPs are physical, structural, or mechanical devices or
facilities intended to prevent pollutants from entering stormwater, penetrating soils, and
impacting neighboring sites.
Measurements and locations of all materials should be verified and noted in the work plan.
When workers are setting up equipment such as tanks, berms, conduits, absorbents, etc. at the
worksite, care should be taken to place them in their appropriate locations as shown in the
work plan, and any departure from the work plan should be noted and explained. For instance,
the work plan may account for berms of different lengths or sizes, a certain number of feet
from the structure, to allow for movement of equipment and personnel onsite. A long 20-foot
berm may be planned 40 feet downhill from the demolition. Similarly, the wastewater tanks are
usually located at one of the lowest points for proper drainage, and the supervisor should check
to ensure it was placed properly so that when demolition work begins, and demolition water is
generated onsite, it drains through the conduits and into the wastewater tanks. In general, the
site supervisor should ensure that the correct sizes of equipment are placed in the correct
locations and in such a way that they are able to function properly.
The function and performance of all equipment should be verified by inspection daily, and any
deficiencies should be corrected by repair or replacement. A working copy of the work plan
should be kept onsite for verification and guidance. Any departure from the EMPs in the work
plan should be noted, along with the prevailing wind direction, any stop work orders,
unexpected rainfall, contingency plan execution, or accidental releases.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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5.1 EMPs to Contain and Manage Demolition Water
The purpose of these EMPs is to prevent the discharge of unpermitted demolition wastewater
to ground or surface water, or to storm drains that discharge to surface water, or to the
ground. When asbestos-containing materials remain in the building, water used for demolition
activities and showers should be contained and managed to prevent contamination of the
demolition site and nearby areas.
EMPs to contain and manage demolition water include segregation, enclosures, structural
source controls, absorbent devices, and vacuum trucks. We categorize containment and
management EMPs into two groups: primary and secondary. Primary EMPs are those that first
address the management of demolition water; secondary EMPs are those that follow the
primary EMPs.
5.1.1 Primary EMPs
Primary EMPs are the first and most basic practices that can be used to reduce exposure to
asbestos by controlling or eliminating the impact of outside elements from access to the
demolition site. These measures can be written into the work plan so that they are not
overlooked in the demolition process.
5.1.1.1 Control Access:
Curious spectators, collectors of memorabilia, salvagers, and trespassers can compromise the
integrity of asbestos controls at the worksite. We suggest training workers to notice non-
authorized personnel onsite, instituting display of identification at all times, and prompt
corrections to maintain controlled access.
5.1.1.2 Communication:
Certain requirements for signage and labelling are included in the Asbestos NESHAP. We also
recommend that workers be reminded of key housekeeping measures and work principles.
Examples include:
• Stencil warning signs at stormwater catch basins and drains, e.g., "Dump No Waste -
Drains to Waterbody."
• Label wastewater tanks: e.g., "Asbestos Hazard. Non-Potable Water. Do not dump to
sewer, land or waterbody."
• Identify the location of absorbents for accidental spills and overruns.
• Post inspection schedule and reminders such as "Fill tanks to 80% only; Do not Overfill"
• Label holding areas for asbestos-containing waste: e.g., "Place Asbestos-Containing
Waste Materials Here"
5.1.1.3 Segregation and Isolation:
When possible, we recommend physically segregating the asbestos-containing materials to
O confine the sources of asbestos that can impact demolition water to as small an area as
^j possible. This can help to reduce the total amount of debris that would be contaminated by
£ asbestos, and would have to be disposed of in a landfill permitted to receive asbestos wastes.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Figure 5. The surrounding sidewalk functions as a berm at this demolition, (EPA photo courtesy of John Pavitt, Region 10).
We recommend enclosing and/or covering the asbestos-containing materials (e.g., within a
building or other enclosure, a roof over storage and working areas, temporary tarp) to prevent
cross-contamination of ACM with materials that are non-ACM, and to prevent the movement of
asbestos fibers offsite. Rainfall can add to the water that may need to be managed at a
demolition site, and failure to properly manage this additional water burden can lead to
unintentional stormwater and wastewater impacts as well as a potentially expanded site
remediation area. Consider using available impervious areas that are compatible with the
materials handled, such as cement or asphalt paved surfaces. Alternatively, consider temporary
construction of a cement or asphalt pad for storage and management of ACM.
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These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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5.1.1.4 Water Management
Water management during and after the demolition operation is important for several reasons.
First, water is a valuable natural resource and protecting it is vital to the environmental success
of the project, and to the natural resource itself. Water can impact the demolition site in at
least two ways: first, water used
for the demolition work must be
managed. This includes water used
at the hygiene stations, spraying
operations within the structure,
and spraying of asbestos-
containing debris that accumulates
on-site in segregated piles during
the demolition process. Second,
precipitation events can
potentially impact a demolition
site when storm water, or melting
ice and snow form a slurry with
Figure 6. A filter array that is designed to hold filters of sequentially demolition debris, and flow offsite,
decreasing pore size. . ..'.,..
carrying asbestos with it.
5.1.1.4.1 Management of Demolition Water
Two examples follow for water management that can be used at demolition operations. One
EMP focuses on filtration and re-use of this non-potable water during the demolition process to
greatly reduce the total amount of water consumed by the demolition project. The second EMP
focuses on filtration of the demolition water
for testing and return to the municipal water
system through the stormwater sewer
system.
5.1.1.4.1.1 Filtration of Demolition Water:
Focus on Water Conservation
To minimize total water use, we recommend
filtering and reusing demolition water for the
duration of the demolition work. In the
example shown by Figures 6 and 7, filters,
starting with a sand filter (similar to those
used for pools), followed by micropore filters
in series, sequentially decreasing in size from
12 to 1 micron may be used to filter out
asbestos with other suspended solid
pollutants as sediment entrained in the
water. This may be especially useful with
Figure 7. Examples of filters used for asbestos removal
in the array in Figure 6. Photo courtesy of John Pavitt,
USEPA Region 10. No endorsement implied. Information
included for instructional purposes only.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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large industrial or commercial demolition projects and in areas that may undergo a curtailment
of water resources. All filters must be disposed of properly as asbestos waste.
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5.1.1.4.1.2 Filtration of Demolition Water: Focus on Return to Treatment System
For this second EMP, we use as an
example, the Excavation
Dewatering Permit through the
Alaska Department of
Environmental Conservation
(ADEC)12 in 2015. The water used
to maintain adequate wetting
during the demolition was
drained into the basement of the
building where it was collected.
This collected water was then
pumped from the basement into
a large (8'x8'x20') baffled tank, as
shown in the photo in Figure 8,
where grit and fine particulate
Figures. Water from a building demolition drained into the basement and debris settled out and
was pumped to this tank (circled in picture) for settling before filtration to
remove asbestos and other pollutants. Photo courtesy of John Pavitt, US EPA hyd roca rbons floated to the
Region 10. surface. The presence of
hydrocarbons was indicated by a
slight sheen on the water's surface. Sorbent pads were then
used to remove the small amount of hydrocarbons.
After settling and sorbent pad application, the water was run
through a 55-gallon drum holding a granulated activated
carbon filter, as shown in the photo in Figure 9, where it
polished off any remaining hydrocarbons. The output water
was sampled from the filter, and the results indicated that it
met surface water discharge standards. The initial round of
testing followed this procedure but discharged the filtered
demolition water back into the basement until sample results
confirmed that the effluent met storm water quality
standards. In this case, a storm drain catch basin right at the
curb by the building, shown in the photo in Figure 10 was an
added convenience.
Figure 9. A carbon-filter within this 60-
gallon drum is used to remove
hydrocarbons and asbestos from water
collected in settling tank. Photo courtesy
of John Pavitt, US EPA Region 10. No
endorsement is implied. Information is
included for instructional purposes only.
12 Demolition of the Gastineau Apartments in Juneau, AK, 2015.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Directional devices, such as berms and
conduits, are useful to divert water into
collection and containment. We
recommend their use in areas expected to
receive most of the asbestos-
contaminated demolition water. For
example, these devices should be utilized
along slopes and impermeable surfaces to
aid in the containment strategy of the
excess demolition water. Devices should
direct contaminated water to appropriate
treatment EMPs (to prevent discharge to a
sanitary sewer).
Figure 10. After filtration and testing of demolition water showed the
water met effluent standards, it was released into the stormwater
drain adjacent to the demolition project. Photo courtesy of John
Pavitt, USEPA Region 10.
5.1.1.4.1.3 Management of On-Site Storm
Water
We recommend that sediment generated
by the demolition process be retained onsite. Storm sewer inlets can be protected with
sandbags or rocks as make-shift filters, and sediment controls may be established at the
perimeter of the site.
The Clean Water Act (CWA) establishes the basic structure for regulating discharges of
pollutants into the waters of the United States and protecting water. When demolitions are
conducted close to a body of water that could potentially be negatively impacted by the
demolition, we recommend the collection and filtration for asbestos of all water generated
onsite. Additional requirements may apply in a particular Clean Water Act permit.
5.1.1.4.1.4 Management of Off-Site Storm Water
We recommend segregating storm water off site from all waters onsite to avoid over burdening
the tanks and absorbents with water that does not need treatment prior to release. Diverting
the worksite runoff to containment in a tank or other impermeable structure and diverting off-
site storm water around the worksite area are recommended EMPs.
When storm water can potentially impact a demolition site, we recommend ditches and
trenches as useful EMPs to divert off-site storm water to retention ponds or other sediment-
filtering areas to prevent it from creating an overburden for the EMP devices. Storm water can
create this situation when the demolition occurs on a hillside with an impervious surface.
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Once directional devices have been placed to effectively divert offsite storm water to storm
sewers or ditches, and on-site storm water and demolition water into tanks, the onsite
asbestos-laden demolition water can be managed to remove asbestos. We do not recommend
sending untreated demolition water to a storm water or sanitary sewer, even if the municipality
allows it.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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It is important to note that we do not think these controls are EMPs for asbestos control, and
we have no information indicating that asbestos is removed from water using silt fences and
rock barriers. However, these may be useful for removing excess sediment from the total
amount of water to be collected and subsequently filtered for asbestos removal, and
potentially extending the life of the asbestos filters. Additionally, we don't recommend using
retention ponds or other sediment-filtering areas for on-site diversion of asbestos-
contaminated waste water because this could potentially expand the site contamination rather
than limit it.
Installation of a silt fence as a perimeter control and onsite sediment filters at the lowest site
elevation are effective controls to remove sediment from water. Additionally, if demolition or
storm water has impacted the demolition site and flowed into the silt fence, the silt fence and
all trapped sediments in this case would also be contaminated with asbestos and must be
disposed of properly as an asbestos-containing waste material or converted into non-asbestos
material.
Water spray: It is necessary to meet the Asbestos NESHAP requirement for keeping the
regulated asbestos-containing material adequately wet at a demolition regulated by the
Asbestos NESHAP, according to the Asbestos NESHAP.13 Additionally, State or local dust control
air quality ordinances may apply at the demolition site. We recommend the use of a low-
volume misting nozzle to maintain dampness without excess water volume. Note: Do not hose
down pollutants from any area to the ground, storm drains, conveyance ditches, or receiving
water. This process increases the chances that you may release asbestos and other
environmental hazards into the environment which may trigger a release of reportable
quantities under CERCLA. For additional information on this EMP, see the field example in
section 5.6 of this document.
Drains: We recommend that floor drains in potential pollutant source areas should not be
connected to storm drains, surface water, or to the ground. EMPs are to block all drains within
the work area using materials that are both impervious and not easily dislodged.
Correct equipment: We recommend the use of containers, piping, tubing, pumps, fittings,
and valves that are appropriate for their intended use and for the contained demolition water.
Housekeeping Measures: We recommend that demolition water in impervious uncovered
containment be cleaned up (vacuumed, absorbed, drained and filtered, etc.). Cleaning, steam
cleaning, or pressure washing of equipment or containers inside a building or on an impervious
contained area, such as a concrete pad, can help to prevent the accidental release of asbestos-
laden water. Additionally, walled liners (i.e., 'drip pans') may be installed beneath equipment
I_O handling and storing demolition water (e.g., filter assembly racks, tanks, etc.) to catch spills and
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13 See 40 CFR 61. 145 (c) (6)
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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drips. We recommend drip pans be emptied immediately after a spill or leak is collected,
especially if it is in an uncovered area that may be exposed to rainfall or stormwater.
Maintenance: Prompt repair or replacement of any leaking connections, pipes, hoses, valves,
etc., can help to prevent contaminating areas of stormwater runoff. We recommend repair,
replacement, and resealing any damaged paved areas, especially those at industrial facilities,
such as damaged paved secondary containment, high-intensity parking, and any other drainage
areas subjected to pollutant material leaks or spills.
5.1.2 Secondary EMPs
Contaminated water removal: We recommend the use of vacuum trucks for the removal
of water that threatens to run offsite or to exceed the structural barriers in place at the
demolition site. Vacuuming up water at and beyond the berms and barriers can be helpful to
contain and manage the demolition water in one step. We recommend vacuuming all
appropriate surfaces with wet vacuum trucks
daily or more frequently as needed for the
collection and disposal of asbestos-
contaminated demolition water that could
contaminate surrounding soils.
Absorption: Absorbent devices such as
sawdust-filled tubes (a.k.a., "sausages"), sand
bags, and peat berms may be used to absorb
demolition water. In order to protect
neighboring property, we recommend their use
in areas that are not expected to receive a high
water loss and on the perimeter of areas that
are level. They are also useful at the far end
beyond the berms and barriers and the vacuum
truck, as a secondary or tertiary contingency
plan and precautionary measure in case of an
accidental overflow or miscalculated water path. Since absorbent devices have a maximum
effectiveness level, at which point they are saturated and can no longer absorb water or
function effectively, they are not primary containment EMPs. In Figure 11, the view is looking
downhill after a rainstorm the previous evening. The demolition itself is controlled and these
absorbent devices have been installed as a secondary backup. Any water from the demolition
that makes its way off site would run alongside the curbs and be absorbed into the 'sausages'
instead of running into the storm sewers located along the sides of the street, or into the river
at the bottom of the hill.
Figure 11. Sawdust-stuffed burlap tubes are weighed down
with sandbags in V and 'J' shapes (EPA photo courtesy John
Pavitt, Region 10).
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Determine if a Release Has Occurred: We recommend testing water collected in ditches and
runoff basins at the site for the presence of asbestos to determine whether or not a release has
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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occurred. Notification to the National Response Center, as well as remediation of the impacted
and surrounding soils and catch-basins, may be required.
5.2 Tanks
We recommend collecting and containing the water that may be contaminated by asbestos
from demolition, worker showers, or stormwater because the asbestos NESHAP requires
containment of all regulated asbestos-containing material and proper disposal of all asbestos-
containing waste material. The collected asbestos-laden water may be diverted to on-site
properly labeled tanks for subsequent filtration and disposal.
We recommend the wastewater tank not be filled to capacity because the potential for spills
and leaks increases as the maximum capacity is reached. Spare wastewater tanks may be
brought onsite, and the tanks can be changed out when no more than 80% full.
When possible, consider sizing the tanks larger than the estimated amount of water needed,
and include extra double-wall tanks as a precautionary measure. Tanks may be cleaned and re-
used for similar (non-potable water) projects. Consider dedicating wastewater tanks for
demolition water under the program. See also the following website for additional information:
http://www.ertvideo.org/content/asbestos-managing-problems-addressing-concerns
5.3 Field Examples
5.3.1 EMP: Berms and Absorbents on a Sloped Site
For example, consider a demolition of a building on a hillside. The primary controls used in one
such case were sandbags at the base of the demolition site. Secondary barriers of sawdust-
stuffed burlap tubes ("sausages") were placed in 'J' and 'U' shapes lining the street inside the
perimeter of the demolition area to prevent runoff from entering the river or the stormwater
sewer at the base of the hill, as depicted in the photo in Figure 12.
Downhill from the sausages, concrete or earthen berms may be constructed which direct any
water into waiting enclosed pipes and conduits where the water is diverted to flow into waiting
tanks or absorbents. In order to prevent leaking and dribbling, the "sausages" should be
replaced before they become saturated (to avoid leaking and dribbling). New sausages replace
the soaked sausages which are double bagged for disposal.
In the replacement process, any demolition water that may pass over the area is directed by
berms into the conduits, pipes and collection tank. Pre-existing structures may be present that
can function as berms at a site. For instance, curbs and sidewalks in an urban or suburban
setting may function to prevent wastewater from leaving the site.
5.4 EMP: Diversion Slurrv Purrming System and Slurry Capture Mats
3m to a tank vacuum truck and/or slurry capture
mats especially Tor large demolitions on sloped surfaces, disturbed soils, and/or in proximity to
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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bodies of water that could become contaminated by runoff. This is typical of demolitions near
rivers or on riverbanks or lake edges.
5.5 BMP: Vacuum Trucks
Vacuum trucks are useful in addition to 'sausages' to prevent contaminated runoff from the
site. Consider using vacuum trucks to remove a wet slurry of asbestos debris as a clean-up
method and / or a backup control, especially when steep slopes or impervious materials may
indicate a higher runoff potential. We recommend double-checking for leaks on vacuum trucks
since these vehicles may be fitted with small ducts which should be sealed after emptying to
function properly, and these are easily overlooked. As water is flushed onto a demolition, the
water and slurry can be vacuumed up and hauled away for disposal or further filtering. The
total size of the structure, daily maximum amount of water use, washing of personnel and
equipment, and heavy rainfall (especially when unexpected as this may not have been taken
into account in the work plan) can significantly impact the total amount of contaminated water
that must be managed from the demolition site.
5.5.1 EMP: Low-volume misting nozzle to adequately wet ACM
Buildings scheduled for demolition typically have asbestos-containing materials, many of which
are regulated asbestos-containing materials (RACM). RACM includes materials that are in
damaged or friable condition
or that will be rendered
friable during the
demolition. When these
asbestos-containing
materials are not removed
prior to demolition, the
resulting dust also contains
asbestos. Materials such as
pipe wrap14, transite siding,
textured ("popcorn") ceiling
coatings, sprayed-on
fireproofing, vermiculite attic
I
Figure 12. This is an example of one type of low pressure misting nozzle, which is used
to suppress and control dust. No endorsement is implied. Information provided for
instructional purposes only.
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14 Most pipe wrap was manufactured from amosite (or 'brown') asbestos, and is considered to be among the most
toxic forms of asbestos. Additionally, many surfactants do not successfully penetrate amosite. When pipe wrap is
encountered, special care to identify effective water amendments and then to adequately wet, abate and remove
it should betaken.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Water amendments
(surfactants) reduce the
surface tension of the
water droplets ... and
improve the water's
effectiveness by increasing
its affinity for adhesion to
asbestos fibers...
insulation, roofing materials, and many other building
materials can be found in poor or friable condition.
Using a low-volume nozzle prevents excessive water
use and avoids damage to RACM which is typically in
a friable state. Low-volume misting nozzles (Figures
12 and 13) can be particularly effective at adequately
wetting all ACM before, during and after demolition
without causing further damage to these materials.
According to professionals in the field, the size range
of the water droplets is critical to avoid the
'slipstream' effect that large droplets from sprinklers
have on airborne dust particles. In most applications,
fugitive particles are generally around 50 to 100
microns in size, but water droplets from a sprinkler are much larger, often 2000 to 6000
microns. The velocity of the large sprinkler droplet affects the airflow. When an airborne
particle approaches it, the flow often deflects the particle without a collision between dust and
droplet. In contrast, the atomized mist system creates droplets that are much closer in size to
the dust particles which facilitates the necessary contact to bring dust particles to the ground.
The sheer number of these miniscule droplets also increases the surface area available to
contact airborne particles without over-saturating the debris.15
Prevention of pooling and runoff of toxics-contaminated demolition water was a primary
objective in the remediation of a former lead-acid battery recycling facility in Throop, PA
located adjacent to the Lacawanna River (Figure 13). For the project, engineers were required
to meet a "no visible emissions" standard, find a way to control large volumes of lead-laden
dust, confine surface dust to the immediate area, and prevent airborne particles from migrating
to nearby residential communities. Although this particular project work plan was designed for
compliance with the lead abatement program, not asbestos abatement, we believe these are
EMPs that translate well into the asbestos abatement arena because they address rigorous
requirements similar to those that must be met during demolitions under the asbestos NESHAP
(work practice standards, having no visible emissions, compliance monitoring, removal and
disposal of all contaminated materials, worker training and protection, inspections) and under
overlapping State and Federal rules and local ordinances.
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15 Laura Stiverson, President, Dust Control Technology. Professional Demolition Americas, Issue 1, page
36. 2015. www.pdamericas.com
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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5.6 EMP: Use a Wetting Agent for most effective Fiber Adhesion and
Control:
Figure 13. A machine delivering an atomized mist keeps materials adequately wet. This work is being conducted at a lead-
remediation site with compliance requirements similar to the Asbestos NESHAP. (Photo used with permission from DustBoss,
2015). No endorsement is implied. Illustration provided for informational purposes only.
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A very effective management practice is to add a wetting agent to amend the water used to
wet the asbestos-containing materials in the building to be demolished. This "amended water"
is used to maximize the adherence of asbestos to the water by lowering the surface tension of
water. Water amendments (also called surfactants) also increase the misting capability and
improve the water's effectiveness as it increases its affinity for adhesion to asbestos fibers,
increases its penetration and increases its surface coverage. Wetting agents include soaps,
alcohols and some fatty acids. The EPA's "Purple Book", or as it is formally known, Guidance
for Controlling Asbestos-Containing Materials in Buildings, EPA-560/5-85-024 , recommended
the use of a wetting agent that is a 50:50 mixture of polyoxyethylene ester and polyoxyethylene
ether, or the equivalent, in a 0.16 percent solution (1 ounce to 5 gallons) of water.
Surfactants can be added to onsite tanks or through a port at the hose. Water hoses are usually
attached to a faucet tap, fire hydrant or water tank. Generally, the hose has a nozzle attached
which spreads the water stream so that a fine mist is created.
An engineering control often used is a misting unit which can be used to create a high level of
humidity within a removal area. It is believed that fibers emitted into a saturated environment
will absorb the wetting agent and fall out of the air faster thus reducing airborne fiber levels.
The wetting agents used for the demolition may not be safe to use for the showers. We
recommend using specific wetting agents according to their intended use and consulting the
product safety data sheets (SDSs) before handling or using any wetting agent to amend the
shower water. All the SDSs should be kept onsite in a centrally accessible location.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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5.7 Dedicated Wetting for Pipe Wrap
Dedicated wetting nozzles for use when pipe wrap is
encountered are recommended (see Figure 14). Note
that amosite asbestos was used commercially for pipe
wrap. Asbestos removal professionals take special
measures whenever pipe wrap is involved because
amosite asbestos repels water as well as most
surfactant-treated or amended water. Special
proprietary amending chemicals have been
developed for use on pipe wrap that adhere to and
are not repelled by the amosite asbestos. We
recommend using these chemicals whenever pipe
wrap is encountered.
Figure 14. Pipe wrap is frequently hidden and
may be difficult to find. Special wetting agents
may be needed for pipe wrap.
5.8 Decontamination of Waste-Hauling
Vehicles
When the vehicles used to transport demolition waste may become contaminated by asbestos
from the site, we recommend they be cleaned of contamination before leaving the site in order
to prevent contamination of a wider area. Vehicles, including the tires and undercarriage, can
be visually inspected for debris removal and rinsed using amended water while the vehicles are
on an impervious surface (asphalt or concrete pad). The vehicle rinse pad may be designed as a
slightly inclined surface draining into a collection system and tank. We recommend the
collection and management of all rinse water along with the shower and demolition water.
6 Post-Demolition Clean Up and Site Preparation
6.1 EMP: Segregate Asbestos-Containing Waste Materials
• Where feasible, store containers of asbestos-contaminated debris inside a building or
under a cover and/or containment.
• Stop, contain, and clean up all spills immediately upon discovery.
• If asbestos-containing wastes are stored on-site, have spill containment and cleanup kits
readily accessible. These kits should be appropriate for the materials and the size of a
potential spill. Locate spill kits at all transfer areas including berms, conduits, vacuum
trucks, containment tanks, backup tanks, and water filter assemblies.
• If the spill has reached or may reach a sanitary or a storm sewer, ground water, or
surface water, notify the local jurisdiction and the local sewer authority immediately.
Notification must comply with federal spill reporting requirements. (See also record
keeping at the end of this section).
• Do not flush or otherwise direct absorbent materials or other spill cleanup materials to a
storm drain.
• Collect the contaminated absorbent material as a solid and place in appropriate disposal
containers.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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• The kit(s) should include but are not limited to: salvage drums or containers, such as
high density polyethylene, polypropylene or polyethylene sheet-lined steel;
polyethylene or equivalent disposal bags; an emergency response guidebook; safety
gloves/clothes/equipment; shovels or other soil removal equipment; and water
absorbent barriers, booms and absorbent pads. All should be stored in an impervious
container.
6.2 Post-Demolition Clean Up Activities
Under the Asbestos NESHAP, all asbestos-containing waste materials must be contained,
labeled, kept adequately wet, and be properly disposed of as soon as practical16. These
materials are likely to include berms, absorbents, contaminated soils, silt fence(s), filters, filter
cakes and demolition debris that could not be successfully segregated before beginning the
demolition process. Some barriers that are not permeable by water, such as plastic-coated
berms, may be able to be cleaned and reused at other demolition sites.
The following sections provide EMPs for containing asbestos in the demolition wastewater.
6.2.1 EMP: Filter Post-Demolition Wastewater
It is easier and less costly to protect soil than it is to abate it through the remediation process.
The management of waste water is key to the demolition process. Wastewater should be
filtered to remove asbestos fibers before disposal. We recommend the collection, filtration and
testing of all water used to maintain adequately wet requirements.
Filtration equipment can be set up according to the sediment profile that needs to be removed
from the demolition water. For instance, when coarse, medium and fine sediments are present,
a graduated filtration system may be used to process the collected demolition wastewater.
Wastewater passes through a coarse filter, followed by a secondary finer filter, and lastly
through a finest filter. Coarse filters, which are also less expensive, are changed frequently.
Secondary filters, which are more costly, are changed less frequently. All wastewater filters are
changed in this EMP before they are full, and any spillage that may occur during filter change
out is collected in a tray and is also filtered. All filters are doubly bagged with the asbestos-
contaminated debris for proper disposal.
The use of settling tanks can also be used to remove coarser sediments so that a graduated
system is not needed.
6.2.2 EMP: Post-demolition Wastewater Testing
Demolition water should be tested after filtration for the presence of asbestos, and the analysis
results should be retained in the work plan records. Filtered water may be disposed of in
accordance with the local POTW requirements.
16 For more details, see 40 CFR 61.150(a)-(b).
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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We recommend testing the catch basin sediments to indicate whether or not a release of
asbestos is indicated. If asbestos is present in the catch basin sediments, this may indicate that
asbestos was released to the environment as a result of the demolition activity and that some
cleanup may be needed as a result (see soil protection and remediation). Further, when this
requirement is part of the work plan and is communicated to all parties in advance of the
demolition work, we believe it is likely that the work will be conducted using EMPs that are
effective and would more likely prevent asbestos from reaching areas where it could be
released into the environment.
An EMP is to require testing of all soils receiving abatement water, remaining soils and
surrounding soils to show asbestos levels at or below background.
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6.3 EMP: Remediate Soils at the Demolition Site and Surrounding
Areas
If the work plan was well developed, contingency plans were followed, and the waste water
from the demolition site was properly managed, controlled and contained, there may be no
remediation of the site needed. However, when violations of the standard or unexpected and
unforeseen circumstances arise that cause or contribute to asbestos contamination of a site,
post-demolition remediation of the site may be required.
^^^^^^^M^^^^^^^M
We recommend
maintaining
documentation to show
that the site is not
contaminated. One way
to document this is to
sample the soils below
the removal level (using
a grid) to verify that the
asbestos content is at or
less than background.
Clearance sampling may
be conducted to show
that soils below the
removal level either did
not contain asbestos or
Figure 15. Micro-vac sampling is one method that may be used to indicate that non-porous
surfaces, such as this asphalt parking lot, have not been contaminated by asbestos after the
ordered demolition of the hotel featured in Figure 4. Photo courtesy of
that asbestos was
present at or below
background levels.
After visual inspection
and clearance, representative sampling and analysis may be conducted to indicate that the
work performed was successful in avoiding asbestos contamination of nearby areas. Figure 15
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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shows one micro-vac sample being taken at a site to indicate that a nearby asphalt parking lot
was not impacted by the ordered demolition of a hotel.
If asbestos has contaminated the demolition site, we recommend the controlled excavation and
removal of soils:
• beneath debris piles that received water,
• for which sampling and analysis confirms are contaminated by asbestos, and
• which are suspected of being impacted by asbestos in the demolition debris.
All asbestos-containing materials, including soils, should be kept adequately wet during
excavation, packaging, loading for transport, and while awaiting disposal (which is required
under the Asbestos NESHAP to be done as soon as practical).
In 2008, the EPA Office of Solid Waste and Emergency Response (OSWER), now the Office of
Land and Emergency Management (OLEM), released the Framework for Investigating Asbestos-
Contaminated Superfund Sites (http://www.epa.gov/superfund/superfund-asbestos-technical-
resourcesffframework). The framework (which is currently in revision) is part of many recent
efforts to make sure that new developments regarding asbestos are used to better assess
exposure and risk (e.g., EPA efforts to update cancer and non-cancer assessments for asbestos).
The framework provides a process that supplements other EPA guidance concerning exposure
and risk assessment (e.g., EPA's 1989 Risk Assessment Guidance for Superfund) and is specific
to assessment of sites contaminated with asbestos. Because there are unique scientific and
technical issues associated with the investigation of human exposure and risk from asbestos, it
is important for risk assessors and risk managers to understand these issues when assessing
asbestos sites. This framework discusses specific strategies based on the best available science
and recommends common industrial hygiene methods for characterizing exposure and risk
from asbestos, as well as discusses the various sampling and analysis methods for
contaminated air, soil and dust. While the entire framework document may not be applicable
to issues specifically related to NESHAP regulation, many sections, including sections related to
sampling and analysis, may prove useful for site managers dealing with issues of risk
assessment and sampling and analysis. It should be noted that the current framework
document references two laboratory testing methods for determining asbestos concentrations
in soil in Section 4 (NIOSH 9002 and California Resources Board, or CARB Method
435.). However, currently OLEM is recommending CARB 435 as the method of choice for the
direct detection of asbestos in soil media. OLEM is in the process of evaluating an ASTM
method and an internal EPA method for analysis of asbestos in soils, but a final decision on the
applicability of these methods has not yet been made. Asbestos fibers in outdoor soil, indoor
dust or other source materials typically are not inherently hazardous unless the asbestos is
released from the source material into air where it can be inhaled.
These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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6.4 Cross Reference to Selected Relevant Federal Regulations
Requirement
Permitting water discharges
Stormwater Discharge
Reportable quantity of
released pollutant
Asbestos NESHAP
Asbestos Worker Protection
Asbestos Worker Protection
for State & Local
Government Employers
Asbestos in Schools
Labelling and Transportation
of Asbestos-Contaminated
waste
Government
Authority
Federal
Federal NPDES
Federal CERCLA
Federal
Federal /State
Federal
Federal
Federal /State
Law
NPDES
NPDES
CERCLA
CAA
OSHA
TSCA
AHERA
DOT
CFR Citation
40 C.F.R. Section 450
Section 103(a)
40 C.F.R. part 61, subpart M
29 CFR Part 1926.110129 C.F.R.
section 1926.1101; 29 U.S.C.
section 654; see also 29 C.F.R.
sections 1910.1001 and
1915.1001
40 C.F.R. part 763, subpart G49
40 C.F.R. part 763, subpart E
C.F.R. part 100 - 185
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These guidelines do not impose legally binding requirements, do not confer legal rights or impose legal obligations
on anyone, or implement any statutory or regulatory provisions.
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Appendices
Appendix 1: Applicable Regulations
Appendix 2: Guidance Documents
Appendix 3: Example Workplans
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United States Office of Air Quality Planning and Standards Publication No. EPA-453/B-16-002a
Environmental Protection Sector Policies and Programs Division July 2016
Agency Research Triangle Park, NC
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