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Demolition Guidance for Structurally Unsound Buildings

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Barry R. Stephens, Director
William R. Snodgrass Tennessee Tower
312 Rosa L. Parks Avenue, 15th Floor
Nashville, TN 37243
(615) 532-0554
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The intent of the following guidance is to provide a summary of requirements pertaining to the demolition of buildings and the handling of asbestos containing material when structures have been deemed structurally unsound and in danger of imminent collapse by a state or local government agency. When a facility has been damaged by fire or by a natural disaster, for example, there may be a tendency to overlook certain hazards that are not immediately life threatening.

Given the health hazards associated with asbestos, it is reasonable that adequate measures be taken during emergency situations to minimize exposure to such material from the demolition of buildings. To the extent feasible, efforts should be made to adhere to the following guidance in order to comply with federal and state regulations.

Federal asbestos regulations are contained in 40 CFR sections 61.140 through 61.160. In addition, the OSHA regulations on asbestos are also applicable.

Applicability

This guidance applies to all nonresidential buildings (e.g., commercial and public buildings) and residential buildings with five or more dwelling units that are structurally unsound and in danger of imminent collapse.

This guidance applies to a group of residential structures that are structurally unsound and in danger of imminent collapse and are a part of a government ordered demolition. Such structures are considered an “installation” in the asbestos NESHAP, and is defined as any group of buildings or structures, which includes residential structures, at a single demolition site that are under the control of the same owner or operator (or owner or operator under common control) including a contractor hired to demolish this group of structures.

This guidance does not apply, but is recommended, to private individuals who contract directly with a demolition contractor for the demolition of a single residential structure they own having four or fewer dwelling units.

This guidance does not apply to the demolition of a damaged building that is not unsound and in danger of imminent collapse. Buildings of this classification are regulated by more stringent requirements.

If a building has been totally destroyed by fire or a natural disaster, the asbestos NESHAP does not apply to subsequent activities. If the building is only partially damaged, the asbestos NESHAP applies to the portion which remains standing.

Identifying Asbestos Containing Materials

It is unsafe to enter a structurally unsound building. A thorough inspection of a building to determine the amount, types, and location of asbestos containing building materials is not required.

A building may be known to have asbestos containing products. Such products may include: asbestos-cement corrugated sheet, asbestos-cement flat sheet, asbestos pipeline wrap, roofing felt, vinyl-asbestos floor tile, asbestos-cement shingle, millboard, asbestos-cement pipe, surfacing or spray-applied materials, and vermiculite-attic insulation.

All structures (both residential and commercial) built before 1975 may contain significant amounts of asbestos. In particular, large structures built before 1975 typically contain asbestos pipe wrap, siding, ceiling tiles, and other building materials high in asbestos content. Note that structures built after 1975 may also contain asbestos.

Notification

Persons conducting demolitions should formally notify the Air Pollution Control division as early as possible prior to the start of the demolition, but in any event, no later than the following workday after starting the demolition.

Expertise

At least one person, either a government official or private contractor, trained in the asbestos NESHAP regulations should be on site or available by cell phone during the demolition to provide assistance or guidance.

Demolition

PPE: In all instances, workers should use equipment specifically designed to protect them from asbestos exposures during demolition and handling of debris, especially respirators, as required by OSHA.

Use of water: Heavy equipment used for demolition may cause asbestos to be disturbed. It is very important to wet the structure before and during demolition to prevent the migration of asbestos fibers.

It is recommended to knock down each structure wall-by-wall, folding it in on itself to minimize the excess breakage of asbestos containing material. Debris should be handled in a way to minimize excess breakage.

Burning: Structures may not be demolished by burning unless approved by a Regional TDEC Environmental Field Office at 1-888-891-TDEC (8332). If approval is granted, there is absolutely no burning allowed unless all asbestos-containing material is removed in accordance with the asbestos NESHAP prior to burning. This also applies to residential structures containing asbestos.


Removal, Disposal and Transport of Asbestos Containing Material

If it is known that asbestos is present but cannot be safely removed or segregated, dispose of all the debris as if it is asbestos containing material.

When feasible, segregate and place asbestos containing material into leak tight wrapping. If the volume of the material precludes use of leak proof wrapping, continue to wet the material and use heavy lifting equipment to place the asbestos containing material into waiting dump trucks. Whenever possible, use a plastic liner in the bottom of the bed of the dump truck to minimize the leakage of contaminated water from the truck. If the asbestos containing material has been further broken up during the loading process, wet it down again after it is loaded into the truck.

Cover the dump truck with a tarp, sealing it so that debris and dust cannot be released during transport.

Placard (with a large sign) each dump truck as it is being loaded and unloaded with asbestos containing building materials. The placard should read:

“DANGER, ASBESTOS DUST HAZARD, CANCER AND LUNG DISEASE HAZARD,

Authorized Personnel Only”

Transport the asbestos containing material to a landfill permitted to receive asbestos. Contact the Division of Solid Waste Management at 1-888-891-TDEC for a list of approved landfills.

Waste shipment records must be maintained by the owner or operator of the demolition activity and the owner and/or operator of the landfill.

If you have any questions about this guidance, please contact the Division of Air Pollution Control, Asbestos NESHAP Program, at (615) 532-0554.