Warehouse Demolition with Buried Pipe Insulation and Non-Friable Ceiling Tile
A 1958 warehouse, 18,000 square feet, is scheduled for demolition in 12 working days. The owner's property condition survey - not an asbestos inspection - noted 600 square feet of 2x4 ceiling tiles and 150 linear feet of pipe insulation. Lab results later confirmed 12% chrysotile in the tile and 35% amosite in the pipe insulation. The demolition contractor proposes to wet the structure with fire hoses and knock it down, arguing the tile is non-friable and the pipe insulation will be buried in the rubble. The owner has not filed a DEQ notification. The landfill that accepted the owner's construction and demolition debris says it can take the rubble, but its permit does not mention asbestos. The project schedule has no time for a full asbestos survey.
1. What must be removed before demolition, and why is the contractor's wetting plan inadequate?
Read the worked answer
The 150 linear feet of amosite pipe insulation is regulated asbestos-containing material and must be removed before demolition; it cannot be buried in rubble. The 600 square feet of ceiling tile is Category I non-friable, but demolition by heavy equipment will crumble, pulverize, or reduce it to powder, so it becomes regulated asbestos-containing material and must also be removed before demolition. Wetting with fire hoses is not a substitute for removal, containment, and proper disposal; it does not prevent the asbestos from being pulverized and released. The owner also needs a thorough asbestos inspection by a DEQ-certified inspector before renovation or demolition, not a property condition survey. The inspection must identify all ACM, including hidden materials, before the scope is finalized.
2. What notification is required and can the 12-working-day schedule be met?
Read the worked answer
A demolition notification must be received by DEQ at least 10 working days before demolition begins. The owner has not filed, so the clock has not started. If the notification is filed today and is complete, the earliest lawful start is 10 working days later; a 12-working-day demolition start could still be possible, but only if the notification is filed immediately and the removal is completed first. The notification must include the owner or operator, facility description, scheduled start and completion dates, amount and type of asbestos, and the abatement contractor. Starting demolition before the 10-working-day period expires would violate OAR 340-248 and the federal NESHAP. The owner should also confirm the landfill will accept the waste before scheduling.
3. What else must the owner do to keep the project lawful?
Read the worked answer
Use a DEQ-licensed abatement contractor and DEQ-certified workers and supervisor for the removal. Keep the removed material wet and package it in leak-tight, labeled containers; arrange transport to a landfill permitted to accept asbestos waste and use the required waste shipment record. Notify DEQ of any change in start date or scope. Keep the inspection report, notification, contractor credentials, and disposal records. Because the building is a 1958 warehouse, the inspector should look for additional materials - floor tile, mastic, roofing, transite, duct sealant - before demolition; if new ACM is found, the notification and scope must be amended. Demolition cannot proceed until all regulated ACM is removed.