Transite Pipe Waste Disposal All waste disposal rules

Transite Pipe Waste Disposal

All waste disposal rules are under the EPA NESHAP Regulation Our OSHA regulation does not regulate the waste stream beyond the work site. If asbestos waste is to be regulated, it must fall under the NESHAP. If the NESHAP waste disposal rules do not apply, the waste stream is not regulated.

NESHAP TERMS • RACM: Regulated Asbestos Containing Material; Friable or TSI >1% asbestos. • Category I Non-friable ACM: Packings, gaskets, resilient flooring, asphalt roofing; Non-regulated. • Category II Non-friable ACM: All other non-friable ACMs; Non-regulated as long as it does not become RACM; Typically the Transite products. • ACWM: Asbestos Containing Waste Material; Includes RACM and waste contaminated with RACM from demolition or renovation. • WSR: Waste Shipment Record; The waste manifest between the work site and the disposal site.

NESHAP Waste disposal rules apply by regulation to RACM OR ACWM! Not to CATEGORY I or CATEGORY II that has not become RACM or ACWM

WASTE DISPOSAL (NESHAP) WET � LEAK TIGHT CONTAINERS � PROPER LABELS � APPROVED LANDFILL � (NESHAP asbestos landfill) �

WASTE DISPOSAL (cont. ) WASTE SHIPMENT RECORD (WSR) COVERED AT LANDFILL WITH AT LEAST 6” OF NON-ASBESTOS FILL DAILY MAINTAIN WSR FOR AT LEAST 2 YEARS

WASTE VEHICLES Must be marked with the following sign during loading and unloading: DANGER ASBESTOS DUST HAZARD CANCER AND LUNG DISEASE HAZARD Authorized Personnel only

CONTAINER LABELS: DANGER OSHA CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD DOT RQ, ASBESTOS NA 2212 NAME & ADDRESS OF GENERATOR EPA Site Specific

Under the federal regulations, if removed correctly, transite pipe does not become friable, therefore is not regulated for waste disposal. This means that wetting, containing in leak-tight wrapping, labeling and disposing of in a NESHAP landfill are not required. It remains a Category II Non-friable Material. Also, breaking transite material does not make it friable. Broken pieces of transite are simply pieces of Cat. II Material. However, when transite pipe breaks, there is a certain amount of fine crumbles or friable material generated. This should be gathered with the soil that it is in and contained. If this material reaches a quantity of 35 cubic feet, the NESHAP is triggered, and all the regulations apply including notification to EPA and the ACWM is regulated for waste disposal. Do not bury transite debris in the trench (see interpretive letters in the resource package).

There a number of “best work practices” that owners may require, since they may recognize a perceived liability from negligence leading to asbestos exposure. These include spray painting broken ends, bagging or containing the broken pieces, wrapping the pipe sections, labeling the wrapped sections, and disposing of the material in an asbestos landfill. Even if the transite waste is not regulated, it should be maintained in a restricted area until disposed of at a landfill. These practices may not be required by regulation, but may be required by the owner.

Transite Pipe Abandoned pipe w/ends sealed

Transite Pipe Still on the fitting, will result in a larger waste stream! Not sealed

Transite Pipe Broken pieces Not wet Not sealed Not labeled Not managed