NYS DOL Memorandum Regarding Concrete Disposal

Below is an email from the NES Asbestos Control Engineering Services Unit regarding their memorandum on Concrete Disposal...

Dear Asbestos Project Designers:
 
Effective immediately, ESU will no longer grant variances which seek to dispose of ACM contaminated concrete debris pile as C&D without prior approval from the EPA.  All concrete debris in a controlled demolition with friable ACM, regardless of the size, porosity, and types of treatment, shall be disposed as regulated asbestos-containing material (RACM). As such, they can no longer be treated as conventional construction and demolition (C&D) waste even if they have been cleaned and cleared by the Project Monitor.
 
There are no approved alternative demolition work practices under Asbestos NESHAP and as a result, contaminated concrete from the demolition debris pile cannot simply be cleaned and reused as standard C&D waste. The only exception is concrete that was segregated prior to the demolition and has never been part of the contaminated debris pile. Project Designers must indicate this in the variance petition to be granted that relief.
 
Contractors and property owners who wish to dispose of the concrete debris pile as C&D can contact EPA for their approval and attach the approval letter to the petition to be considered by ESU.
 
Controlled demolition with Category I non-friable ACM is not affected by this change.
 
ESU’s variance conditions will be altered accordingly to reflect this change, which will also include additional instructions for the handling of concrete masonry units (CMUs) and poured concrete foundations.
 
Thank you,
 
 
 
Melissa Dippel
Administrative Assistant 2
Division of Safety and Health
Direct Supervisor for Engineering Services Unit
Chek Beng Ng Professonial Engineer 2
 
 
New York State Department of Labor | Engineering Services
Harriman State Office Campus
Building 12, Room 154, Albany NY 12226
P: (518) 457-1536
www.labor.ny.gov | [email protected]
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