The Strip Mall Threshold Argument
A developer plans to demolish a 1974 strip mall in Mississippi next month. A pre-demolition survey by an accredited inspector identifies 120 linear feet of friable pipe insulation on heating lines; 200 square feet of asphalt roof flashing; 140 square feet of vinyl floor tile and mastic; and 60 square feet of transite panels in the electrical room. The developer's project manager calculates that the pipe insulation is under the 260-linear-foot threshold and the floor tile is under the 160-square-foot threshold, so he concludes that no NESHAP notification is required and that the material can be demolished with the structure. The general contractor plans to knock down the building with an excavator, then sort debris. The project is not an emergency.
1. Assess the manager's conclusion that no notification is required because the pipe and floor tile are below threshold.
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The conclusion is wrong for a demolition. Under the asbestos NESHAP, demolition notification is generally required even when the asbestos amount is below the renovation threshold, subject to limited regulatory exceptions. The 260-linear-foot and 160-square-foot thresholds are used to determine regulated asbestos-containing material quantities and whether renovation notification is triggered; they do not eliminate the demolition notification. In addition, 120 linear feet of friable pipe insulation is RACM and must be removed before demolition. The 200 square feet of asphalt roof flashing is Category I nonfriable material; if it will be cut, ground, or abraded during demolition, it becomes RACM. The 60 square feet of transite is Category II nonfriable material and can also become RACM if broken. The contractor should file the required notification at least 10 working days before demolition.
2. What changes should be made to the demolition plan before the excavator arrives?
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The plan should remove all RACM before demolition rather than knocking down the building and sorting debris. The friable pipe insulation must be removed by an accredited abatement contractor using wet methods, HEPA vacuuming, containment as needed, and proper bagging. Category I and Category II nonfriable materials that will be broken or abraded should be removed intact before demolition or handled so they do not become friable. The contractor should seal and label waste, use covered transport, and dispose at an approved landfill with manifests. The notification should identify the facility, scheduled start, amount and type of asbestos, and removal methods. If the schedule changes, the contractor should amend the notification. Demolishing first and sorting later would likely spread fibers and violate work-practice requirements.
3. How should the contractor handle the transite panels if they are removed intact?
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Intact transite panels are Category II nonfriable material. They can be removed before demolition without being classified as RACM if they remain intact and are not sanded, cut, ground, or abraded. The contractor should avoid breaking the panels, wet them as needed to control dust, lower rather than drop them, and package them for disposal according to the landfill's acceptance requirements. If a panel breaks or must be cut, the resulting material may be regulated and should be handled with abatement work practices. The contractor should document the condition, quantity, and removal method, and ensure the disposal facility is authorized to accept the waste. Even intact removal should be coordinated with the required demolition notification and the overall asbestos removal plan.