Hazardous Waste Program fact sheet

Environmental Regulations for Demolition

Project Checklist3/2012

PUB2374

Disclaimer: The checklist is intended to help those planning a demolition project in Missouri tocomply with various laws and regulations intended to protect human health and the environment.

This checklist is not intended, nor can it be relied on, to create any rights enforceable by anyparty in litigation. It is recommended you contact the county or city of jurisdiction to determine ifadditional local requirements apply to your situation.

Contact information for the Missouri Department of Natural Resources and specific programsreferenced in the checklist is found at the end of this document.

Pre-Planning

Complete N/AAll public, commercial and, in some cases residential structures must beinspected by a Missouri certified asbestos inspector prior to beginning anydemolition or renovation project. A listing of currently certified asbestosinspectors is available on the department’s website at www.dnr.mo.gov/env/apcp/ asbestos.htm or by calling the Air Pollution Control Program.

Determine if there are hazardous materials in the building such as lead pipes,lead paint, thermostats, fluorescent bulbs, batteries, pesticides, cleaners andother chemicals that would become hazardous wastes if intended for discard.If so, additional regulations may apply. Contact the Hazardous Waste Programfor guidance. For more information about recommended management ofmercury-containing devices, see EPA’s fact sheet Before You Tear it Down,Get the Mercury Out, available online atwww.epa.gov/mercury/pdfs/EPA-905-F-11-008.pdf.

Hazardous fluorescent bulbs, thermostats, pesticides and batteries in goodcondition may be managed as universal waste. If not managed as universalwaste, these materials would need to be characterized to determine if it ishazardous waste for proper on-site management and disposal. For moreinformation see the fact sheet The Universal Waste Rule in Missouri (PUB2058)available on the department’s website at www.dnr.mo.gov/pubs/pub2058.pdf.

Hazardous and non-hazardous fluorescent bulbs may be taken to a recycler.A list of recyclers is available in the fact sheet Fluorescent Bulb Recyclers(PUB0451). More information about managing fluorescent bulbs is in thedepartment’s Fluorescent Lamps (PUB0024) fact sheet.

Are there abandoned cisterns or wells? If so, additional regulations may apply.Contact the Wellhead Protection Section for guidance.

2

Are there above- or below-ground petroleum storage tanks? If so, additionalregulations may apply. Contact the Hazardous Waste Program for guidanceabout underground storage tanks and the Missouri Department of Agriculturefor above-ground and propane tanks.

Are there air conditioning units or refrigeration units with refrigerants such aschlorofluorocarbons, or CFCs? If so, contact the CFC Stratospheric OzoneHotline at 800-296-1996 about management of CFCs.

Are there light ballasts that may contain Polychlorinated Biphenyls, or PCBs? Ifso, additional regulations may apply. Contact the Hazardous Waste Program forguidance.

Identify the recycling or disposal facility receiving the demolition waste toensure it can receive it or for any restriction or special requirement they mayhave for the waste.

Submit a Closure Notice form (780-2121) 30-days prior to underground storagetank closure and notify the Hazardous Waste Program’s Tanks Section threedays before beginning closure activities. This form is available online atwww.dnr.mo.gov/forms/780-2121-f.pdf.

Register with the Hazardous Waste Program as a hazardous waste generator ifgenerating or accumulating 220 pounds or more of hazardous waste per month.Most construction and demolition and renovation contractors are consideredconditionally exempt small quantity generators. Note: Acutely hazardous wastesbecome regulated at 2.2 pounds.

Submit an Asbestos National Emissions Standards for Hazardous Air Pollutants,or NESHAP, Notification of Demolition and Renovation form (780-1923) to theAir Pollution Control Program at least 10 business days prior to demolition startdate of any regulated structure (public, commercial and in some casesresidential). Include a copy of the asbestos inspection report by a Missouricertified asbestos inspector. This form is available online atwww.dnr.mo.gov/forms/780-1923-f.pdf.

Submit Asbestos Project Notification form (780-1226) to the Air Pollution ControlProgram at least 10 business days prior to the project start date. This isrequired if removal or disturbance of greater than 160 square feet, 260 linearfeet or 35 cubic feet of regulated asbestos-containing materials will occur duringthe demolition project. This form is available online at www.dnr.mo.gov/forms/7801226-f.pdf.

Submit an Abandonment Registration Record form (780-1603) to thedepartment’s Wellhead Protection Section for the plugging of an abandoned well.This form is available online at www.dnr.mo.gov/forms/780-1603-f.pdf.

Complete N/A

Notifications

Complete N/A

3

Recovered materials that can be reused or be made into new products must beused in some way to remain exempt from regulation as solid waste. Potentiallyrecoverable materials include clean fill, metals, plastics, glass, electrical wire,asphalt shingles and wood.

If light ballasts were manufactured before 1979 or manufactured after 1979 and donot have labels stating they do not contain PCBs, assume they contain PCBs.Carefully remove light ballasts to prevent PCB leaks and remove and containleaking ballasts in a manner that minimizes contamination. Use a licensedtransporter to transport PCB waste for disposal.

Universal wastes must be properly removed and transported to a universal wastehandler or destination facility.

Hazardous wastes must be appropriately packaged, marked and labeled andtransported to a treatment, storage and disposal facility or certified resource-recovery facility. The transporter must have a valid EPA generator identificationnumber and active Missouri hazardous waste transporter license.

Properly close petroleum storage tanks in place or by removal.

Regulated asbestos-containing materials must be removed by a Missouriregistered asbestos contractor prior to demolition if the amount of asbestos-containing material is greater than 160 square feet, 260 linear feet or 35 cubic feet.

Manage remaining asbestos-containing materials in the structure in a manner thatwill keep it from being broken-up, made friable or becoming regulated asbestos-containing material.

Minimize fugitive dust during demolition and prevent dust from leaving propertyboundaries.

Intentional burning and other training activities for the purpose of training andinstructing fire protection, law enforcement or emergency personnel are exemptfrom Missouri open burning regulations as long as the exercise conforms to thelimitation described in the regulation, does not cause or constitute hazards to air orvehicular traffic and does not cause a violation of any other regulation. However,structures used for training exercises remain subject to 10 CSR 106.080,subsection (3)(M) - National Emission Standards for Asbestos (inspection,abatement and notification requirements). All regulated asbestos-containingmaterial and all petroleum-based products (in the case of fire training) such asasphalt shingles and vinyl tile must be removed prior to the training exercise.

Note: The intentional burning of a structure as a method of demolition or disposal isprohibited. Demolition debris from a previously demolished structure cannot beburned under the exemption.

Properly plug abandoned wells and cisterns.

Clean fill, which is uncontaminated soil, rock, sand, gravel, concrete, asphalticconcrete, cinderblock and brick with minimal amounts of wood, metal or other inertsolids approved by the department, may be used as fill on-site, with the permissionof the property owner.

Demolition and Post Demolition Activities

Complete N/A

4

Additional InformationMissouri Department of Natural ResourcesAir Pollution Control Program 573-751-4817 cleanair@dnr.mo.govHazardous Waste Program 573-751-3176 hazwaste@dnr.mo.govSolid Waste Management Program 573-751-5401 swmp@dnr.mo.govWater Protection Program 573-751-1300 cleanwater@dnr.mo.govWellhead Protection Section 573-368-2165 gspgeol@dnr.mo.gov

Regional OfficesKansas City Regional Office 816-622-7000Northeast Regional Office 660-385-8000St. Louis Regional Office 314-416-2960Southeast Regional Office 573-840-9750Southwest Regional Office 417-891-4300

Missouri Department of AgricultureAboveground Petroleum Tanks and Propane Tanks 573-751-4278

On the Web• Code of State Regulations: www.sos.mo.gov/adrules/csr/current/10csr/10csr.asp.

• Lead abatement in Missouri: www.dhss.mo.gov/Lead/FAQs.html.

The following fact sheets and publications are available on the Web atwww.dnr.mo.gov/pubs/index.html or by contacting the Department of Natural Resources:

• Asbestos Requirements for Demolition and Renovation Projects (PUB2157),www.dnr.mo.gov/pubs/pub2157.pdf.

• Asbestos: Inspection Report Requirements (PUB2349), www.dnr.mo.gov/pubs/pub2349.pdf.

• Construction and Demolition Waste Guidance (PUB2242), http://dnr.mo.gov/pubs/pub2242.pdf.

• Disposal of Demolition Wastes Contaminated with Lead or Other Heavy Metals (PUB2002),www.dnr.mo.gov/pubs/pub2002.pdf.

• Eliminating an Unnecessary Risk: Abandoned Wells and Cisterns (PUB0682),www.dnr.mo.gov/pubs/pub682.pdf.

• Fluorescent Lamp Ballasts (PUB2081), www.dnr.mo.gov/pubs/pub2081.pdf.

• Fluorescent Lamps (PUB024), www.dnr.mo.gov/pubs/pub24.pdf.

If clean fill will come in contact with surface water or subsurface water, contactthe Water Protection Program for guidance.

Major appliances except for microwaves cannot be disposed of in landfills andshould be salvaged.

Demolition debris must be transported to a permitted landfill or transfer station.

All asbestos-containing materials must be disposed of in a permitted landfill.Contact the landfill prior to transporting the materials to obtain special handlingrequirements.

Complete N/A

5

• Managing Construction and Demolition Waste (PUB2045), www.dnr.mo.gov/pubs/pub2045.pdf

• Managing Recovered Materials (PUB2049), www.dnr.mo.gov/pubs/pub2049.pdf

• Prohibition of Major Appliance Disposal in Landfills (PUB0929), www.dnr.mo.gov/pubs/pub929.pdf

• Requirements for Fire Training Exercises Involving Structures (PUB2029), www.dnr.mo.gov/pubs/pub2029.pdf

• Tank Closure Checklist (PUB2218), www.dnr.mo.gov/pubs/pub2218.pdf

• The Universal Waste Rule in Missouri (PUB2058), www.dnr.mo.gov/pubs/pub2058.pdf

The following forms are available on the Web at www.dnr.mo.gov/forms/index.html or bycontacting the Department of Natural Resources:

• Asbestos Project Notification form (780-1226), www.dnr.mo.gov/forms/780-1226-f.pdf

• Asbestos NESHAP Notification of Demolition and Renovation form (780-1923),www.dnr.mo.gov/forms/780-1923-f.pdf

• Notification of Regulated Waste Activity (780-1164), www.dnr.mo.gov/forms/780-1164-f.pdf

• Underground Storage Tank Closure Notice 1 and 2, www.dnr.mo.gov/env/hwp/docs/closureforms605.xls

• Abandonment Registration Record (780-1603), www.dnr.mo.gov/forms/780-1603-f.pdf

For More InformationMissouri Department of Natural ResourcesHazardous Waste ProgramP.O. Box 176,Jefferson City, M0 65102800-361-4827 or 573-751-3176www.dnr.mo.gov/env/hwp