2009-07-20_INSPECTION - M1977094

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Friable asbestos waste and non-friable asbestos waste damaged to the point of being friable must be properly packaged before being sent,to the landfill. It must be tightly sealed, while wet, in at least two 6-mil, leak- tight polyethylene bags or in a wrapping or other con- tainer deemed equivalent by the Hazardous Materials and Waste Management Division. The outermost layer of the packaging must be labeled with a waste ship- ment manifest label that gives the name and address of the generator of the waste, and either of the following statements in letters at least 0.5 inches tall: CAUTION Contains Asbestos Avoid Opening Or Breaking Container Breathing Asbestos Is Hazardous To Your Health or DANGER Contains Asbestos Fibers Avoid Creating Dust Cancer and Lung Disease Hazard There are no state regulations regarding the packaging of nonfriable asbestos for disposal. The landfill should be contacted prior to disposal for any local require- ments. Non-friable vinyl-asbestos tile flooring and asphaltic roofing materials that are in good condition and not friable prior to demolition may be disposed of as con- struction and demolition materials as long as they are not rendered friable by the demolition activities. Drywall and drywall mud may contain asbestos. The percent of asbestos contained in drywall and its associ- ated materials, including mud and, tape, may be deter- mined based on a representative composite sampling program. Drywall finishing mud and joint compound, referred to simply as "mud", frequently has been found to contain a significant amount of asbestos (i.e. greater than 1%), while the substrate it is applied over may or may not contain any asbestos. The question; then, is how to handle this composite material in the event of a renovation or demolition project that will impact these materials. Two distinct situations may occur: first, the demoli- tion/renovation project may impact the mud alone, such as could be the case during a sanding operation, or second, the demolition/renovation project may im- pact the composite material (the mud .grand, the substrate drywall it is applied over), such as would be the case in the demolition of the drywall. EXHIBIT A MORGAN COUNTY COMMISSIONERS COMPLAINT MORGAN SAND AND GRAVEL In the first case; if the mud contains greater than 1% asbestos, the project must be handled as an asbestos abatement project, subject to all the applicable re- quirements of the Air Pollution Control Division. In the second case, the project is considered to be an asbestos abatement project if the percent of asbestos in the combined mud/drywall composite material is greater than 1%. If, on the other hand, the mud contains 1% or less of asbestos, the material is not considered to be asbestos- containing material for purposes of the Air regulations and is not subject to the asbestos abatement require- ments. Similarly, if the composite analysis indicates an asbestos content of 1% or less, even though the mud itself may be greater than 1%, the material is not con- sidered to be asbestos-containing material and does not fall under the asbestos abatement requirements of the Air regulations. In both of these cases, the removed materials, may be disposed of as construction and demolition debris - i.e., non-asbestos waste. Adequate documentation must be kept to demonstrate the deter- mination regarding the concentration of asbestos in the materials being disposed. If construction or demolition debris is commingled with any friable asbestos material, it all must be dis- posed of as asbestos-contaminated debris. Proper mate- rials characterization and planning should occur early in the project to minimize the amount of asbestos- containing waste. For more information: Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 For abatement, renovation, demolition, training or certification questions, contact: Air Pollution Control Division Asbestos Unit Telephone: 303-692-3100 Email: asbestosCastate.co.us For disposal questions, contact: Hazardous Materials and Waste Management Division Solid Waste Unit Telephone: 303-692-3300 Email: comments.hmwmd(i4state.co.us sw-ooi This Compliance Bulletin is intended to provide guidance on the appropriate management of wastes based on Colorado solid and hazardous waste statutes and regulations only. The wastes described in this guidance may be regulated under other statutes and regulations. 3 of 3