Attachment_3_-_Colorado_Department_of_Public_Health_and_Environmental_East_Troublesome_Wildfire_Guidance_with_Disposal_Form.pdf

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Asbestos East Troublesome Wildfire, October 2020 Public and Commercial Buildings

Ash and debris from burned structures may contain toxic substances due to the many synthetic and other materials that may be present in buildings. For example, car batteries or mercury light bulbs, lead-based paint, plastic items and other potentially toxic materials may have been present in the buildings prior to the fire. Public and commercial structures may contain larger amounts of these materials. People should take precautions when entering buildings that are partially damaged by the fire or when handling any materials from buildings completely destroyed by the fire. They should wear protective clothing and equipment to avoid skin contact with debris and inhalation of ash.

One particular concern in handling debris from structures damaged or destroyed by wildfires is the possible exposure to asbestos fibers. Asbestos is a known carcinogen and exposure to asbestos fibers can cause or contribute to the development of various diseases including asbestosis, mesothelioma and lung cancer. Asbestos fibers have been commonly used in a variety of building materials including wall and ceiling textures, drywall, insulation, sheet vinyl flooring and floor tiles. Asbestos-containing materials that are in good condition should not pose a hazard. However, materials that are damaged or disturbed can release asbestos fibers creating a potential exposure risk for people working on site or on neighboring sites.

Colorado enforces asbestos requirements under Colorado Regulation No. 8, Part B. It also has been delegated the authority and obligation to enforce the federal National Emission Standards for Hazardous Air Pollutants (NESHAP) regarding asbestos in public and commercial buildings. For residential properties, including commercial residential buildings with four or fewer dwelling units, the Colorado Department of Public Health and Environment is able to waive some of the asbestos requirements of Colorado Regulation 8, Part B. Please see the specific documents developed for residential properties affected by the East Troublesome Wildfire. Colorado cannot waive federal requirements for Public and

Commercial buildings.

I. Addressing asbestos in Public and Commercial structures completely destroyed by the fire where only ash and debris remain.

Safe Handling of Ash and Debris

The ash/debris should be handled in a manner that will minimize potential exposure to asbestos fibers and other hazardous materials in the debris.

• Ash/debris must be wetted to minimize dust; packaged inside a container (such as an end-dump roll-off or truck) lined with double 6-mil plastic sheeting with the sheeting completely closed over the material and sealed once the container is loaded.

• Soil under/surrounding the building should be scraped to ensure that all ash and building debris has been removed from the site.

• Contractors should consult with the Occupational Safety and Health Administration (OSHA) at

(303) 844-4500 (Englewood) or 303-844-5285 (Denver) to determine training and personal protective equipment that will be required for those handling this material.

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Proper Disposal of Ash and Debris

Ash and debris from buildings that were destroyed by must be disposed of at an approved landfill. The following landfills can accept ash and debris from public and commercial buildings destroyed by this fire that cannot be safely characterized for the presence of asbestos.

Tower Landfill, Inc. Denver Arapaho Disposal Site Buffalo Ridge Landfill 8480 Tower Road 3500 S. Gun Club Road 11655 WCR 59 Commerce City Aurora Keenesburg Steve Derus, 720-590-4046 Chris Anderson: 720.876.2633 Michelle Wittenbrink: 303-229-8085

Foothills Landfill Front Range Landfill 8900 Hwy 93, Golden 1830 Weld CR 5, Erie Steve Derus, 720-590-4046 Randy Tourville: 303-673-9431

No other landfills are currently approved to accept ash and debris from buildings completely destroyed by this fire. In order to get approval to accept these materials, landfills must request and receive permission from the Hazardous Materials and Waste Management Division (HMWMD) which will include agreement to implement certain best management practices designed to protect landfill workers and nearby public from potential asbestos hazards.

• Please contact the landfill before loads are taken there to confirm waste acceptance, to alert them that the material is coming and to initiate a waste profile. The landfill should be informed that the material has come from the fire area and may contain suspect asbestos-containing materials or other hazardous materials. Please take debris directly to the landfill.

• Recycling of metal and concrete foundations is permissible under the following circumstances:

Metal debris must be washed clean of ash/debris prior to recycling. If you wish to recycle a concrete foundation, the concrete must be inspected by a Colorado certified asbestos building inspector to determine that it is free of asbestos-containing materials prior to recycling.

Notification and Permitting Requirements

State demolition permitting requirements are waived. However, the building owner or contractor must submit written notification to the CDPHE Indoor Environment Program. This notification should be done using the Public and Commercial Disposal Notification Form, East Troublesome Wildfire, October 2020.

II. Addressing asbestos in damaged Public and Commercial structures where the building must be demolished and where sampling building materials for the presence of asbestos cannot be done safely.

Building owners must work with appropriate local officials overseeing the fire response to determine whether a partially damaged structure can be safely inspected. Local government ordered demolitions based on a determination that the building is structurally unsound and in danger of imminent collapse waive the requirements to inspect and remove regulated asbestos containing material provided.

However, all debris must be treated as friable asbestos waste.

• Provide written notification (10 working days in advance) to the Indoor Environment Program for all demolitions. Emergency provisions may allow notice to be made 24 hours instead of 10 working days.

• Ash/debris must be wetted to minimize dust; packaged inside a container (such as an end-dump roll-off or truck) lined with double 6-mil plastic sheeting with the sheeting completely closed over the material and sealed once the container is loaded.

• Soil under/surrounding the building should be scraped to ensure that all ash and building debris has been removed from the site.

• Ensure there is an asbestos trained supervisor on the jobsite with documentation posted.

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• In addition, Contractors should consult with the Occupational Safety and Health Administration (OSHA) at (303) 844-4500 (Englewood) or 303-844-5285 (Denver) to determine training and personal protective equipment that will be required for those handling this material.

• All debris must be treated as friable asbestos waste and can only be disposed of in a landfill that meets the Asbestos NESHAP requirements. The following are the landfills permitted to accept this waste:

Tower Landfill, Inc. Denver Arapaho Disposal Site Buffalo Ridge Landfill 8480 Tower Road 3500 S. Gun Club Road 11655 WCR 59 Commerce City Aurora Keenesburg Steve Derus, 720-590-4046 Chris Anderson: 720.876.2633 Michelle Wittenbrink: 303-229-8085

Notification and Permitting Requirements

State demolition permitting requirements are waived. However, the building owner or contractor must submit written notification to the CDPHE Indoor Environment Program. This notification should be done using the state Demolition Notification Application Form except the section for sign-off by the certified Asbestos Building Inspector and Asbestos Removal Contractor should be left blank. There is no fee required for submission. The form may be found here:

https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordHtml/1298245

III. Addressing asbestos in buildings only partially damaged by the fire and where sampling building materials for the presence of asbestos can be done safely:

Building materials must be inspected by a Colorado certified asbestos building inspector prior to renovation/demolition or debris handling activities impacting the building materials. If asbestos-containing material is present in amounts greater than the trigger levels, they must be removed in accordance with Colorado Regulation No. 8, Part B - Asbestos. Known friable asbestos-containing materials must be disposed of at a landfill that can accept friable asbestos waste.

IV. If there is known asbestos-containing material above regulatory trigger levels in a building, the owner must follow the requirements of Colorado Regulation No. 8, Part B.

For buildings that had been previously inspected and found to contain asbestos-containing materials or were previously known to contain asbestos in amounts greater that the state trigger levels, asbestos abatement permits and demolition permits are required. Known friable asbestos-containing materials must be disposed of at a landfill that can accept friable asbestos waste.

Asbestos Consulting Firms (asbestos inspectors):

https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordView/1140204 Asbestos Abatement Contractors:

https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordView/1248240 Asbestos Landfills:

https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordView/1140205

For additional asbestos information, please contact the CDPHE Indoor Environment Program at: 303-692- 3100 or cdphe.asbestos@state.co.us https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordHtml/1298245 https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordView/1140204 https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordView/1248240 https://environmentalrecords.colorado.gov/HPRMWebDrawer/RecordView/1140205 mailto:cdphe.asbestos@state.co.us

DISPOSAL NOTIFICATION FORM

East Troublesome Fire, October 2020

B u il d in g

O w n e r

Owner’s Name:

Street:

City: State: Zip Code:

Telephone #

S it e

A d d re s s

Owner’s Name:

Street:

City: County: Zip Code:

D is p o s a l

C o n tr a c to r

Company/Contractor’s Name:

Street:

City: State: Zip Code:

Telephone #

L a n d fi ll

Landfill Name:

Street:

City: State: Zip Code:

Telephone #

Submit form by mail/email (no fee is required) to:

Indoor Environment Program Permit Coordinator Colorado Dept. of Public Health and Environment

APCD-IE-B1

4300 Cherry Creek Drive South Denver, CO 80246-1530 cdphe.asbestos@state.co.us

Please call 303-692-3100 with any questions