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<br />This is an except from a very long article concerning asbestos containing materials. The website <br />contains the full manual. <br /> <br />http://www.epa.qovJReqion4JairJasbestosJdemolish.htm <br /> <br />Terms: RACM is Related Asbestos Containing Material <br /> <br />ACM is Asbestos Containing Material <br /> <br />Onsite Waste Disposal <br /> <br />As mentioned in other sections of this manual, using heavy machinery to crush demolition debris <br />containing Category I or II nonfriable ACM in place prior to or during burial, can cause the ACM to <br />become RACM subject to the provisions of sections 61.150 (waste disposal) and 61.151 (inactive <br />waste disposal sites) or 61.154 (active waste disposal sites). If Category I or II materials are not <br />rendered friable, they are not subject to the asbestos NESHAP. <br /> <br />EPA has recently responded to a question regarding the onsite disposal of crushed asbestos- <br />cement pipe, a Category II material. The response is applicable as well to the burying of Category <br />I material which has been sanded, ground, cut or abraded. In its correspondence EPA stated that <br />the practice of backfilling and burying crushed asbestos-cement pipe in place causes these <br />locations to become active waste disposal sites subject to the requirements of 61.154. <br />Furthermore, if no additional asbestos-containing waste material is buried at that location for a <br />year, the site becomes an inactive waste disposal site subject to the requirements of 61.151 (e) <br />and 61.154(h). Consequently, the owner of the land would be required to comply with the <br />requirements for active and inactive waste disposal sites. <br /> <br />In order to avoid the creation of a waste disposal site which is subject to the Asbestos NESHAP, <br />it was suggested that the owners or operators of the pipe consider other options for dealing with <br />it. If the pipe is left in place or removed in such a way that it is not crumbled, pulverized or <br />reduced to power, it would not be subject to the NESHAP. If the pipe must be crushed, the <br />creation of an active waste disposal site can be avoided by removing the pipe from the site and <br />transporting it to a landfill which accepts asbestos waste material. <br /> <br />An alternative method suggested involved the pumping of grout into the buried lines which are no <br />longer in service. <br /> <br />Waste Load Out <br /> <br />As mentioned previously, waste load out activities generally do not cause Category I nonfriable <br />ACM to become RACM. Top loaders are typically used to deposit demolition debris containing <br />Category I nonfriable ACM into trucks for hauling to landfills that accept construction debris. <br /> <br />Recent EPA correspondence discusses the hauling and ultimate disposal of both Category I and <br />Category II ACM as follows: <br /> <br />It is required under 61.150(a)(3) that asbestos-containing waste material be kept adequately wet. <br />Asbestos-containing waste material as applied to demolitions and renovations includes RACM <br />waste and materials contaminated with asbestos including disposable equipment and clothing. <br />