Asbestos in Concrete
Under section 61.145 of the asbestos NESHAP, operators and/or owners of facilities are required to conduct a thorough inspection prior to any demolition or renovation operation. A thorough inspection includes all suspect materials, including concrete, that are part of the structure to determine whether it’s an asbestos-containing material. Because the US EPA considers bridges to be structures that fit the definition of “facility,” in recent years, the Kansas Department of Transportation (KDOT)’s request to grant a waiver from asbestos testing requirements for bare concrete deck bridges that don’t involve an asphalt bridge deck weather surface (waterproof membrane) was denied. The US EPA states that concrete as well as any other suspect material associated with a bridge that will be subject to a demolition operation must be thoroughly inspected to determine whether or not it is ACM. In another recent case brought to the US EPA’s attention by the Missouri Department of Natural Resources, airport taxiways, which are considered a facility component, are potentially subject to the asbestos NESHAP; repair operations on a runway/taxiway could be considered a renovation operation, and therefore be subject to a thorough inspection. The issue at hand is that people are forgetting that testing concrete for the presence of asbestos during demolition and renovation is required.