School Floor Tile and Pipe Insulation Waste Sent to a C&D Landfill
A contractor has removed 2,000 square feet of 9x9 floor tile and mastic and 40 linear feet of pipe insulation from a school. The debris is in 55 clear 3-mil bags and loose in a roll-off dumpster. The contractor plans to haul the dumpster to a county landfill that accepts construction and demolition debris; the landfill's permit does not list asbestos. The school wants the dumpster removed today because parents will tour the building tomorrow. The contractor says the tile and mastic are non-friable, so the waste is ordinary debris. The pipe insulation, however, was friable and is mixed in the same dumpster. The contractor has the DEQ notification and worker certifications on file but has not prepared a waste shipment record.
1. What is wrong with the packaging and transport plan?
Read the worked answer
Clear 3-mil bags are not acceptable. Asbestos waste must be wetted and placed in leak-tight containers - typically 6-mil or thicker poly bags, or sealed drums - and labeled with the generator's name and address and the asbestos warning. Bags must not be overfilled or ripped; if a bag tears, it should be placed inside a second bag. Loose debris in a roll-off dumpster is not leak-tight and will create visible emissions during loading and transport. The truck or dumpster must be covered during transport. The contractor should also clean the outside of containers before they leave the containment.
2. Can the waste go to the county construction and demolition landfill?
Read the worked answer
No, not unless that landfill's permit specifically authorizes asbestos waste. A landfill that accepts construction and demolition debris is not automatically authorized to accept asbestos-containing waste. The contractor must confirm in advance that the receiving landfill is permitted to accept asbestos waste and must follow the landfill's acceptance requirements. If the county landfill is not authorized, the waste must go to a permitted asbestos landfill. The school should not let the dumpster leave the site until the destination is confirmed.
3. What records and notifications should accompany the disposal?
Read the worked answer
The contractor should prepare a waste shipment record or manifest identifying the generator, the waste, the amount, the transporter, and the destination landfill. The landfill signs and returns the record; the contractor keeps copies. The project file should include the DEQ notification, the asbestos inspection, contractor and worker certifications, daily work logs, and disposal receipts. If the waste is shipped out of state, the contractor must check the receiving state's requirements. The school should retain the records for the period required by DEQ and should reconcile the number of bags or containers shipped against the manifest before closing the project.