A Split Bag, an Open Trailer, and the Wrong Landfill
A crew finishes removing 2,800 square feet of sprayed-on ceiling texture in a Missouri school. The waste includes about 55 filled 6-mil poly bags - many loaded to 60 to 70 pounds - plus used respirator cartridges, spent HEPA filters, and disposable suits. The foreman plans to stack the bags on an open flatbed trailer, tie a tarp over them, and drive 45 miles to the county's construction-and-demolition landfill, which holds a solid waste permit but does not advertise asbestos acceptance. While loading, a bag splits and about 8 pounds of wet, friable debris drops onto the trailer bed and the driveway; the foreman plans to put the split bag inside a new bag, sweep the driveway with a broom, and leave. He also intends to pour the decontamination shower water into the parking-lot storm drain and to put the used HEPA filters in the school dumpster.
1. Which federal requirements govern this waste, and is the C&D landfill acceptable?
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40 CFR 61.150 governs. The generator must ensure the waste is adequately wet, contained in leak-tight containers, produces no visible emissions to the outside air during collection, processing, transport, and disposal, and contains no free liquids. Disposal must be at a landfill approved to accept asbestos waste.
- The landfill: a solid waste permit is not the same as approval to take asbestos. Most C&D landfills are not approved, and if this one is not, the load is a NESHAP violation plus CERCLA liability that follows the generator. Call the landfill and the state solid waste program before the truck leaves; if it is not approved, redirect to one that is.
- The load: 6-mil bags loaded to 60 to 70 pounds are overfilled and will tear. Repackage to a weight the bag holds (roughly 40 to 50 pounds), double-bag, gooseneck and tape, and label each container with the asbestos warning.
- The vehicle: a tarped flatbed is acceptable only if no visible emissions occur, and many receiving facilities and state rules require an enclosed, leak-tight vehicle. Use the enclosed truck.
- Cartridges, HEPA filters, and suits are asbestos waste; they do not go in the school dumpster.
- Complete the waste shipment record, get the facility's signed copy back, and keep the file; chase and report a missing copy as the rule requires.
2. What is the correct response to the split bag and the spilled debris?
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The spill is the priority; the schedule is not.
- Stop loading. Put on the appropriate respirator and disposable suit - the foreman's street clothes are not PPE.
- Wet the 8 pounds of debris down. Never dry-sweep it. HEPA-vacuum the solids, then wet-wipe the trailer bed and the driveway.
- Overbag the split bag inside a second (preferably third) 6-mil bag, gooseneck it, tape it, label it. A split bag taped shut is not a repaired container.
- Inspect the cleaned surfaces visually. If the spill was windy or the debris had dried, take air samples downwind and around the truck and keep people out of the area until results are in.
- Document: photos, time, who cleaned up, what was bagged, and the entry on the waste shipment record.
- Fix the cause. The overfilled bags are why it split; re-weigh and re-bag the rest of the load before the truck moves. Overfilled bags also fail at the landfill tipping face, where a release is much harder to control.
3. What should be done with the decontamination shower water and the spent HEPA filters?
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Decontamination water: not the storm drain, and not the ground. Shower and decon water from an asbestos project is normally filtered (5 micron) and discharged to the sanitary sewer only with the local publicly owned treatment works' permission; the filter sludge is asbestos waste. Get the POTW's answer in writing, or hold the water in the tank and have it hauled as waste. A parking-lot storm drain discharges to surface water and is the worst available option.
HEPA filters and respirator cartridges: used negative-air machine filters and cartridges are asbestos waste. Bag them, label them, and ship them with the rest of the load to the approved landfill. The school dumpster goes to a C&D or municipal site that is not approved and will not know what it received.
Also check the negative-air machine's final filter and the HEPA vacuum's exhaust filter before the equipment leaves the site. Both are changed at project close-out and both are waste, and the machine cannot be released until its interior has been cleaned and verified.