Waste Load Out

As mentioned previously, waste load out activities generally do not cause Category I nonfriable ACM to become RACM. Top loaders are typically used to deposit demolition debris containing Category I nonfriable ACM into trucks for hauling to landfills that accept construction debris.

Recent EPA correspondence discusses the hauling and ultimate disposal of both Category I and Category II ACM as follows:

It is required that asbestos-containing waste material be kept adequately wet. Asbestos-containing waste material as applied to demolitions and renovations includes RACM waste and materials contaminated with asbestos including disposable equipment and clothing.

Category I or Category II nonfriable ACM that has been contaminated by RACM, and cannot be decontaminated (e.g., building debris in a pile contaminated with RACM) must be treated as asbestos-containing waste material. Category I or Category II ACM that does not meet the definition of RACM after a demolition or renovation, and is not contaminated with RACM, is not asbestos-containing waste material.

Category I or II nonfriable ACM would still have to be disposed of in a landfill that accepts building debris or at a facility that operates in accordance with EPA rules. This waste material would not be allowed to go to any facility that would sand, grind, cut or abrade the non-RACM waste or otherwise turn it into RACM waste (such as a cement recycling facility).

In addition, if Category I or II nonfriable ACM is sanded, ground, cut or abraded during disposal at a landfill, before it is buried, it is subject to the NESHAP.

Courtesy of The EPA