Demolition of a 1900s Mill Building

The owner cannot demolish first and sort asbestos afterward. The survey identifies regulated asbestos-containing material, including 800 sq ft of friable spray-on insulation and 1,500 linear feet of pipe insulation. NESHAP requires the RACM to be removed before demolition when it will be disturbed; wetting during demolition is not a substitute for removal. Transite siding is category I non-friable, but it becomes regulated if it is broken, crushed, or pulverized during demolition, so it must be handled carefully and either removed before demolition or kept intact under a plan that prevents it from becoming regulated. The owner also must file the required notification with NH DES and the NESHAP-authorized agency at least 10 working days before the abatement or demolition begins. A local demolition permit does not satisfy the asbestos notification or removal requirements. Abatement must be performed by a licensed contractor before the excavator starts.

The owner or operator should prepare a complete asbestos abatement and demolition notification and submit it at least 10 working days before the start date. The notification should identify the owner, the abatement contractor, the demolition contractor, the site address, the start and completion dates, the amount and type of asbestos-containing material, the locations, the removal methods, and the waste disposal site. It should distinguish the abatement phase from the demolition phase and include the 800 sq ft of friable spray-on insulation, the 1,500 linear feet of pipe insulation, and the transite siding and floor tile. The notification should go to NH DES and to the NESHAP-authorized agency for the project; if the schedule changes, the owner should submit a revised notification. The owner should not rely on the demolition permit as notification. A copy should be kept on site and made available to inspectors.

Transite siding should be kept intact as much as possible, wetted, lowered rather than dropped, and wrapped or containerized so it does not break and release fibers. If it breaks or is crushed during demolition, it should be managed as regulated asbestos waste. The friable spray-on insulation and pipe insulation must be removed under containment with wet methods and HEPA vacuuming, then packaged in leak-tight containers and labeled. The waste hauler should use a licensed landfill that accepts asbestos waste, and the owner should retain waste shipment records, landfill receipts, and disposal manifests. The contractor should prevent visible emissions during loading and transport and should not use dry sweeping or compressed air. The owner should also keep the survey, notification, daily pressure logs, clearance reports, and waste records for the required retention period. These records are the evidence that the removal and disposal were done before demolition, not afterward.