Asbestos
Demolition Practices Under the Asbestos NESHAP

Demolition Practices Under the Asbestos NESHAP

EPA - 340/1-92-013

U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington, D.C. 20460

September 1992

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

SECTION 1

DEMOLITION PRACTICES AND NONFRIABLE MATERIALS

INTRODUCTION

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

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

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

PURPOSE

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

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

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

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

DEFINITIONS

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

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

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

Category I nonfriable asbestos-containing material (ACM) means asbestos-containing packings, gaskets, resilient floor
covering, and asphalt roofing products containing more than one percent asbestos as determined using the method specified in appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy.

Category II nonfriable ACM means any material, excluding Category I nonfriable ACM, containing more than one percent
asbestos as determined using the methods specified in appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

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

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

Facility means any institutional, commercial, public, industrial, or residential structure, installation, or building (including any structure, installation, or building containing condominiums or individual dwelling units operated as a residential cooperative, but excluding residential buildings having four or fewer dwelling units); any ship; and any active or inactive waste disposal site. For purposes of this definition, any building, structure, or installation that contains a loft used as a dwelling is not considered a residential structure, installation, or building. Any structure, installation or building that was previously subject to this subpart is not excluded, regardless of its current use or function.

Facility component means any part of a facility including equipment.

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

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

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

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

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

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

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

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

Regulated asbestos-containing material (RACM) means (a) Friable asbestos material, (b) Category I nonfriable ACM that
has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart. Remove means to take out RACM or facility components that contain or are covered with RACM from any facility.

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

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

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

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

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

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

SECTION 2

PRE-DEMOLITION BUILDING STATUS

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

STATE AND LOCAL REGULATIONS

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

UNSAFE BUILDING DECLARATIONS

Several contractors surveyed utilized state or local mechanisms to have buildings declared unsafe as a means to avoid NESHAP requirements during and after demolition activities. However, a State or local agency should not issue a demolition order unless the facility is structurally unsound and in danger of imminent collapse. These conditions should be confirmed independently, and a demolition order should not be based solely on the representation of the contractor or the contractor's agent.

Although issuance of a demolition order may have an effect on notification requirements under the asbestos NESHAP (see 61.145(a)(3)), it has no effect on requirements for disposal procedures for RACM after demolition activities. Also, waste segregation/reduction activities, addressed in Section 5 of this manual, are subject to the asbestos NESHAP provisions whether or not a building has been declared unsafe.

ABATEMENT PRIOR TO DEMOLITION

Demolition contractors typically require that a building owner/operator accept responsibility for the removal of all
asbestos-containing materials found during the building inspection prior to the start of demolition activities. Several contractors indicated that if suspect ACM became exposed during demolition activities, and there was no prior knowledge of its existence at the start of demolition activities, that potential asbestos NESHAP requirements would be disregarded unless a change order was immediately processed by the owner/operator requesting the time and materials necessary to achieve compliance with the asbestos NESHAP. Such practices are in direct violation of the asbestos NESHAP.

INTENTIONAL BURNING

As stated in the November 1990 asbestos NESHAP revision (see 61.145(c)(10)): "If a facility is demolished by intentional burning, all RACM, including Category I and Category II nonfriable ACM, must be removed in accordance with the NESHAP before burning." Abandoned buildings utilized by fire departments for practice exercises involving partial burning are subject to this requirement.

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

SECTION 3

DEMOLITION PRACTICES BY TYPE OF ACM

INTRODUCTION

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

Category I materials are considered RACM only when they "will be or have been subjected to sanding, grinding, cutting, or abrading", they are in "poor condition" and "friable", or the structure in which they are located will be demolished by burning. (Definitions for these terms and additional information concerning Category I nonfriable ACM can be found in the preamble to the November 1990 revised asbestos NESHAP (SUPPLEMENTARY INFORMATION, Section IV - Significant Comments..., Demolition and Renovation, Nonfriable ACM and Broken ACM).

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

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

RESILIENT FLOOR COVERING (TILES)

Depending on the types of activities occurring at a demolition site, floor tiles (and mastic) may or may not become subject to the provisions of the asbestos NESHAP.

Pre-demolition Floor Tile Removal

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

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

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

Water/Amended Water/Solvents

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

However, where breakage is extensive, the tiles are RACM and are subject to the provisions of the asbestos NESHAP.

Dry Ice

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

Infrared Machines

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

Shot-blasters

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

Demolition with Floor Tiles in Place

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

ASPHALT ROOFING PRODUCTS

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

Pre-demolition Roof Removal

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

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

Demolition with Roofing Materials in Place

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

ASBESTOS-CEMENT PRODUCTS

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

Whether asbestos-cement products are subject to the asbestos NESHAP should be determined by the owner or operator on a case-by-case basis based on the demolition techniques to be used. In general, if contractors carefully remove asbestos-cement materials using tools that do not cause significant damage, the materials are not considered RACM and can be disposed of with other construction debris.

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

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

SECTION 4

DEMOLITION PRACTICES BY METHOD

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

HEAVY MACHINERY RAZING OPERATIONS

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

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

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

Bulldozers and Similar Machinery

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

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

977's or D-9s may be used to undermine a building, but hydraulic excavators (discussed later in this section) are usually used for this purpose. Backhoes and top loaders are mainly used for moving debris and tearing off sections of walls and other building components.

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

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

Hydraulic Excavators

Hydraulic excavators, such as EL-300s, 225s or 215s, resemble a combination bulldozer/backhoe and operate on tracks. They are easier to use and provide greater control during demolition than the bulldozers described above. However, since they too raze buildings by ramming and tearing, like bulldozers, their use in congested areas is limited. Nearby buildings must be protected from the falling debris; plywood may be applied over the windows and rubber tires may be used to cushion and prevent damage to walls of adjacent structures.

On rare occasions, hydraulic excavators may be used to topple one-or two-story buildings by means of an undermining
process. The strategy is to undermine the building while controlling the manner and direction in which it falls. The demolition project manager (who in many jurisdictions must be licensed by the city or state) must determine where undermining is necessary so that a building falls in the desired manner and direction. The walls are typically undermined at a building's base, but this is not always the case as building designs may dictate otherwise. Safety and cleanup considerations are also taken into account in determining the methods to be used.

Since the toppling of a building constitutes a safety hazard and generates enormous quantities of dust, many cities and towns will not approve of this method of demolition. Where the practice is allowed, the contractor may be required to keep the structure wet during demolition. Hydrant permits may be required and, because of the wetting restrictions, such demolitions may be impossible to accomplish during the winter.

Hydraulic excavators are also used to conduct cleanup activities such as excavation, fill burial, material reduction, and material load-out. The use of hydraulic excavators during the razing process causes Category II nonfriable ACM, but not Category I nonfriable ACM to become RACM.

Cranes (Wrecking Ball, Clamshell, Bucket)

Although often employed in the past, particularly during demolitions of high-rise structures, cranes are now rarely used. They are expensive to operate and usually not necessary, since renovation has displaced demolition as the method of choice in dealing with many out-of-date structures. Cranes are currently used only in situations where other equipment cannot be employed.

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

Buckets and clamshells allow a greater degree of control than wrecking balls. Buckets may be raised to the level where internal demolition of the building is taking place and be used merely to transport and segregate hand-loaded demolition materials collected from within. Clamshells can take big bites out of the structure and facilitate the segregation of demolition debris. When demolition is accomplished by crane, the process can begin at the roof and progress continually downward, or alternate up and down. Materials are segregated to the greatest degree possible as the demolition progresses so that the need for post-demolition handling is minimized. In the case of high-rise structures, the interiors are usually gutted by hand prior to razing.

Effect on Category I Materials

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

Effect on Category II Materials

The use of wrecking balls on asbestos-cement (A/C) siding (a Category II nonfriable ACM) on buildings is specifically
addressed in the November 1990 asbestos NESHAP revision (see SUPPLEMENTARY INFORMATION, Section IV -
Significant Comments..., Demolition and Renovation, Nonfriable ACM):

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

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

EXPLOSIONS/IMPLOSIONS

Building implosions utilizing explosive devices constitute a rarely-used demolition technique. In simplest form, this method is accomplished through the use of explosive charges placed strategically throughout a building so that the building collapses in on itself and debris does not radiate outward to any appreciable distance. Relatively large quantities of dust are created, however, and the direction and magnitude of transport are matters of concern.

Effect on Category I Materials

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

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

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

Effect on Category II Materials

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

HAND METHODS OF DEMOLITION

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

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

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

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

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

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

Floor Removal and Disposition

The techniques used in removing flooring depend upon its ultimate fate. Where it is in poor condition and incapable of being reused or recycled, the flooring is typically ripped out using pry bars and sledge hammers and sent offsite for disposal. Sometimes wood flooring and other debris is burned to reduce the volume of waste. In this case, the asbestos must be removed prior to burning the wood debris. Since demolition debris disposal costs are so high ($100 - $500 per 60-100 cubic yard load) as much salvage/recycling of materials is done as possible.

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

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

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

Roof Removal and Disposition

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

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

Roofs are often taken out by hand, typically by using pry bars, sledge hammers, axes, adzes, bolt cutters, ice chippers, shovels and roof-cutting saws. If the roof contains asbestos materials (felt, cork, etc.), an asbestos removal contractor may be employed to remove it. Some abatement contractors wet the roof with plain or amended water and then use shrouded power saws whose exhaust is HEPA-filtered to cut the roofing into manageable (often 2' x 3') pieces. After the pieces are lifted, the edges may be encapsulated. Other abatement contractors may build a full containment and establish a reduced pressure environment prior to removing the roofing materials.

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

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

Work Progression

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

Sawing/Cutting Operations

In order to raze a building by hand, load-bearing members must be cut. Based upon the composition, thickness, and condition of the structural member being cut, saws selected range from hand saws to Sawz-alls and gas-driven carbide blade hand saws. Large bolt cutters are also used to cut steel members. Category I materials subjected to sawing or cutting are subject to the provisions of the asbestos NESHAP; however, typical demolition sawing/cutting operations rarely involve such materials.

Grinding Operations

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

Pulverizing Operations

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

Summary

On rare occasions Category I nonfriable ACM may be subjected to hand methods involving the uncontrolled drilling, cutting, sawing, grinding or abrading of such materials; under these circumstances Category I materials are considered RACM.

ONSITE WASTE HANDLING PROCEDURES

INTRODUCTION

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

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

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

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

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

WASTE CONSOLIDATION

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

Segregation of Demolition Debris

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

Segregation may involve cutting and grinding operations, the breaking and tearing apart of materials to separate them by material type, and the transport of materials within the demolition site boundaries.

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

Segregation by Hand

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

Material Transport

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

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

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

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

Vehicular Traffic Impact

Rubber-tired Vehicles

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

Tracked Vehicles

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

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

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

Reduction of Demolition Debris

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

Category I Reduction

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

"If, after a demolition, material left in the facility... is intentionally ground up (such as repeatedly running over the debris with a bulldozer to compact the material), then 61.150(a)(3) applies. The material must be adequately wetted and kept adequately wet during collection and transport to a site or facility operated in accordance with 61.154 or 61.155." (See Appendix I).

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

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

Category II Reduction

Reduction of Category II materials such as asbestos-cement pipe and concrete following demolition is also a matter of concern.

Asbestos-Cement Pipe

EPA considers asbestos-cement pipe to be a "facility component" (as defined in 40 CFR 61.141) of the facility which owns or utilizes the pipe. In addition, EPA considers asbestos- cement pipe to be Category II nonfriable asbestos containing material. This material becomes "regulated asbestos containing material" (RACM), as defined in 40 CFR 61.141, when it becomes "friable asbestos material" or when it "has a high probability of becoming or has become crumbled, pulverized or reduced to powder by the forces expected to act on the material during the course of demolition or renovation operations regulated by [40 CFR Part 61 Subpart M]." Consequently, the crushing of asbestos-cement pipe with mechanical equipment will cause this material to become RACM. The demolition and renovation provisions in 40 CFR 61.145 and the waste disposal provisions in 40 CFR 61.150 apply to asbestos-cement pipe where the pipe is considered RACM, and the amount of pipe being removed and crushed is at least 260 linear feet for a single renovation project or during a calendar year for individual nonscheduled operations.

Concrete

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

Onsite Waste Disposal

As mentioned in other sections of this manual, using heavy machinery to crush demolition debris containing Category I or II nonfriable ACM in place prior to or during burial, can cause the ACM to become RACM subject to the provisions of sections 61.150 (waste disposal) and 61.151 (inactive waste disposal sites) or 61.154 (active waste disposal sites). If Category I or II materials are not rendered friable, they are not subject to the asbestos NESHAP.

EPA has recently responded to a question regarding the onsite disposal of crushed asbestos- cement pipe, a Category II material. The response is applicable as well to the burying of Category I material which has been sanded, ground, cut or abraded. In its correspondence EPA stated that the practice of backfilling and burying crushed asbestos-cement pipe in place causes these locations to become active waste disposal sites subject to the requirements of 61.154. Furthermore, if no additional asbestos-containing waste material is buried at that location for a year, the site becomes an inactive waste disposal site subject to the requirements of 61.151(e) and 61.154(h). Consequently, the owner of the land would be required to comply with the requirements for active and inactive waste disposal sites.

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

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

Waste Load Out

As mentioned previously, waste load out activities generally do not cause Category I nonfriable ACM to become RACM. Top loaders are typically used to deposit demolition debris containing Category I nonfriable ACM into trucks for hauling to landfills that accept construction debris.

Recent EPA correspondence discusses the hauling and ultimate disposal of both Category I and Category II ACM as follows:

It is required under 61.150(a)(3) that asbestos-containing waste material be kept adequately wet. Asbestos-containing waste material as applied to demolitions and renovations includes RACM waste and materials contaminated with asbestos including disposable equipment and clothing. Category I or Category II nonfriable ACM that has been contaminated by RACM, and cannot be decontaminated (e.g., building debris in a pile contaminated with RACM) must be treated as asbestos-containing waste material. Category I or Category II ACM that does not meet the definition of RACM after a demolition or renovation, and is not contaminated with RACM, is not asbestos-containing waste material and is not subject to the wetting requirement of 61.150(a)(3).

Category I or II nonfriable ACM that is not subject to 61.150(a)(3) would still have to be disposed of in a landfill that accepts building debris, in a landfill that operates in accordance with 61.154, or at a facility that operates in accordance with 61.155. This waste material would not be allowed to go to any facility that would sand, grind, cut or abrade the non-RACM waste or otherwise turn it into RACM waste (such as a cement recycling facility). In addition, if Category I or II nonfriable ACM is sanded, ground, cut or abraded during disposal at a landfill, before it is buried, it is subject to the NESHAP. (See Appendix I).

SECTION 6

OFFSITE WASTE HANDLING PROCEDURES

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

Landfills

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

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

Recycling Centers

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

Conversion Facilities

Conversion facilities are addressed in Section 61.155 of the November 1990 revised asbestos NESHAP. Owners/operators of such facilities must handle ACWM according to the provisions of the asbestos NESHAP.

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This Information Last Modified On: 03/17/2005 03:43 PM