WASTE DISPOSAL NESHAP 40 CFR 61 150 Asbestos

WASTE DISPOSAL NESHAP 40 CFR 61. 150

Asbestos waste is regulated by the EPA NESHAP. If the NESHAP does not regulate the waste, it is not regulated in our industry. Regulated asbestos waste is referred to in the regulation as Asbestos Containing Waste Material (ACWM). ACWM is RACM or materials contaminated with RACM from demolition or renovation activities. Two important items define ACWM from non-regulated waste: (1)RACM (2)Associated with demolition or renovation above threshold amounts.

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

The following slide lists the required work practices in handling and disposing of regulated asbestos waste (ACWM). The regulatory reference is 40 CFR 61. 150 Waste Disposal. The items in CAPITAL letters are the items, in order, from the regulation. The items in lower case in parenthesis are good work practices or OSHA compliance issues.

WASTE DISPOSAL (NESHAP) WET � LEAK TIGHT CONTAINERS � PROPER LABELS � (Lined vehicles) � (Covered / enclosed vehicles) � APPROVED LANDFILL � (Agreeable 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

The Waste Shipment Record (WSR) is required to accompany every load of ACWM shipped from the work site. It is actually a chain of custody on the ACWM which verifies that the waste went from the generating site to the appropriate landfill, and was actually received at the landfill. It is the one required recordkeeping document under the asbestos NESHAP.

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

Each individual container of ACWM must be labeled with the OSHA danger label and the NESHAP generator label which identifies the site that the waste came from and the owner of the site. If the waste is to be transported on a roadway leaving the site, it must also have the DOT label.

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