Record Keeping

As required by 40 CFR Part 61 Subpart M, a federal regulation administered by the U.S. Environmental Protection Agency (EPA) as part of the National Emission Standards for Hazardous Air Pollutants (NESHAP), all commercially generated asbestos waste material destined for disposal must be accompanied by a Waste Shipment Record (WSR) (see attached). The WSR must include the name, address and signature of the generator; the address where the waste was generated; the estimated quantity of asbestos being transported; the type of disposal container selected for use; and the disposal site location. Once delivered to the disposal site, the form is to be signed by the facility operator indicating receipt of the waste, and a copy returned to the waste generator as evidence of receipt at the disposal site. The only exception to this requirement is asbestos containing waste material generated at the residence of, and handled by, an individual homeowner. Copies of signed WSRs must be kept at the permitted disposal site for at least two years from the date of disposal.

Attempts to reconcile any discrepancies between the waste generator and the disposal site regarding the quantity of waste disposed, must occur within 15 days after receipt of the asbestos containing waste material. If no resolution occurs, the disparity must be reported to the NH Department of Environmental Services (DES) at (603)271-2925.

Disposal

Disposal of asbestos waste is regulated under 40 CFR Part 61 Subpart M, under N.H. RSA Chapter 149-M and under the NH Solid Waste Rules. The following procedures apply:

1. The first step in disposing of asbestos is for the generator/contractor to contact the chosen permitted landfill and initiate the required paperwork (WSR, etc.). New Hampshire landfills require a minimum notice of 24 hours before the asbestos waste is brought in, allowing the landfill time to prepare for receipt of the shipment. In some cases, this notification period may extend to several weeks while all the paperwork is completed and delivery arrangements are finalized.

2. Landfill personnel are to prepare a separate trench to receive asbestos waste. The size of the trench will depend on the quantity and frequency of asbestos waste delivered to the disposal site. The trenching technique must allow application of soil cover without disturbing the asbestos waste containers. The trench must be ramped as necessary to allow the transport vehicle to back into it, and must be as narrow as possible to reduce the amount of cover required. If possible, the trench should be aligned perpendicular to prevailing winds.

3. Personnel off-loading the asbestos must wear proper protective equipment which includes head, body and foot protection. Also, minimum respiratory requirements include the use of half-face, air-purifying, dual cartridge respirators equipped with high efficiency filters.

4. Hand place or slide the asbestos waste containers into the trench carefully to avoid breaking them. Be particularly careful with plastic bags because if they break under pressure, asbestos fibers may be emitted.

5. Once in place, the asbestos must be immediately covered with at least three feet of solid waste or 18 inches of unspecified soil, prior to compacting. During compaction, asbestos waste must not be exposed. DO NOT RUN MACHINERY OVER UNCOVERED/EXPOSED ASBESTOS.

6. Any improperly packaged or uncovered asbestos waste, or any asbestos containing waste material not sealed in leak-tight containers that is received at a landfill, must be reported to DES at (603)271-2925. The landfill supervisor, possibly in conjunction with DES personnel, may have to decide whether the asbestos waste can be accepted or must be rejected. Rejected loads must be properly packaged at the landfill and cannot be approved for transportation until repackaging is complete.

The limited service area landfills (for the most part publicly owned) generally accept only small amounts of asbestos (1-2 cubic yards) provided the waste was generated within the area serviced by the landfill. Most of these landfills will not accept asbestos from contractors. Because of the volumes they handle, it is generally preferred that contractors do business at landfills with unlimited service areas.

The unlimited service area landfills (generally thought of as "commercial" facilities) will generally accept any amount of asbestos, usually containerized, sometimes in bulk. One should contact the facility directly for information regarding cost and disposal requirements.

For further information, please contact the N.H. Department of Environmental Services, Waste Management Division, 29 Hazen Drive, P O Box 95, Concord, NH, 03301, Telephone: (603) 271-2900, TDD Access: Relay NH 1-800-735-2964.
 
 

Waste Shipment Record & Instructions
Attachment

Limited Service Area Landfills That Accept Small Quantities of Asbestos Generated Within the Service Area
Unlimited Service Area Landfills Permitted to Accept Asbestos
Attachment

Further Information

For additional information, contact: