Reduction of Demolition Debris
Reduction activities are of the greatest concern to EPA, since they are most likely to cause both Category I and Category II nonfriable ACM to become RACM.
Category I Reduction
The use of bulldozers to reduce the volume of Category I materials causes them to become RACM. Reduction by the use of sledgehammers does not normally cause Category I nonfriable ACM to become RACM.
The use of pneumatic hammers, however, whether hand-operated or attached to heavy machinery, does cause these materials to become RACM.
The use of cranes with clamshells or other heavy machinery with rakes or buckets to partially reduce Category I nonfriable ACM is permissible if the material is left recognizable in its original form.
Extensively damaged Category I ACM (that which has been sanded, ground, cut, or abraded) becomes RACM. Consolidating waste materials containing Category I nonfriable ACM in the hole (basement) of a building and subsequently grinding or crushing it via bulldozer subjects the operation to the asbestos NESHAP.
For wood/tile debris, demolition crews sometimes use tree chippers to grind the material up. Any Category I nonfriable ACM subjected to this treatment becomes RACM.
Courtesy of The EPA

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