Motel Demolition Notification
A 1962 motel with 18 units is scheduled for demolition. The owner's survey identifies 450 linear ft of friable duct insulation, 1,900 sq ft of exterior transite siding, and 600 sq ft of floor tile with mastic. The contractor submitted a demolition notification to DNREC five days ago and plans to start next Monday, which is seven working days away. The plan is to pull the building down with an excavator, then hand-remove the transite siding from the rubble. The contractor says the siding is nonfriable, so it is not regulated asbestos-containing material and can be demolished with the structure. The owner also wants to burn the wood debris on site to save disposal costs. The motel is in a residential neighborhood and the demolition permit has not yet been issued.
1. Is the notification valid? What must be corrected before demolition can begin?
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The notification is not valid on these facts. The NESHAP requires a demolition/renovation notification at least 10 working days before the start date. Five days have passed since submission, and the start is only seven working days away, so the required lead time is not met.
The contractor must either postpone the start until the 10-working-day period has run or submit a revised notification and wait for the new period to be satisfied. The notification should also be checked for accuracy:
- RACM quantities: 450 linear ft of friable duct insulation exceeds the 260-linear-foot threshold, so the project is clearly regulated.
- Start date and project type: demolition versus renovation, and the actual start date, must be correct.
- Waste disposal site: the notification must identify where the asbestos waste will go.
- Owner/operator signature and contractor information must be complete.
Starting demolition without a valid notification is a violation even if the contractor intends to remove asbestos later. The permit issue is separate but reinforces that the project is not ready to proceed.
2. Evaluate the plan to demolish the transite siding with the structure and then remove it from the rubble.
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The plan is not acceptable. Transite siding is Category II nonfriable ACM. It is not RACM while it remains intact, but demolition with an excavator will almost certainly crack, crush, and pulverize it, making it friable. Material that will be made friable is RACM and must be handled under the asbestos work-practice standards.
With 1,900 sq ft, the material far exceeds the 160-square-foot threshold. The correct sequence is to remove the siding intact before demolition, using wet methods, careful lowering, and no dropping or crushing. Hand-removing it from rubble after demolition is too late: the dust has already been created and the material has already been made friable.
The contractor's argument that 'it is nonfriable' ignores the planned demolition method. The regulatory question is not just what the material is before work begins, but what the work will do to it.
3. What should the contractor tell the owner about open burning of the wood debris?
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Open burning should not occur. Burning asbestos-containing debris or debris contaminated with asbestos can release fibers into the air and is not a legitimate disposal method. Even if the wood itself is not asbestos-containing, the fire can disturb asbestos-containing materials and spread contamination.
The owner should be told:
- Do not burn any material from the structure until it has been assessed and cleared.
- Use a permitted landfill that accepts asbestos waste and follow its packaging and appointment requirements.
- Keep asbestos waste separate from ordinary demolition debris.
- Check state and local air-quality rules for open burning; even ordinary burning may be prohibited in a residential neighborhood.
The cost-saving motive does not justify creating a public exposure risk or violating disposal rules.