Anyone who has projects in construction, renovation, or demolition should be aware of regulations published in September 2004 (the first such regulations for some time) by the US EPA. The document is not especially lengthy for a government document and there are a few pages of “Contacts and Resources” that could prove most helpful to people wondering if they are in compliance at a particular site. One Web site we find useful is the Construction Industry Compliance Assistance Center at www.cicacenter.org.Most construction debris is not hazardous, so forget any grumpy growling about the EPA interfering in everything. That’s why most construction and demolition (C&D) debris comes under state regulations rather than the EPA’s federal mandates. Debris is the result of work with buildings (commercial, residential, and institutional) when the contractor is building, demolishing, or renovating, and debris is also generated as a result of road and bridge work. Most states have similar descriptions of C&D debris. They include asphalt, concrete, wood, roofing materials, gypsum wallboards, rubble, glass, and paper; and also include debris from land clearance, such as tree stumps, rocks, and dirt. That debris is seldom hazardous. The most likely hazardous debris is asbestos insulation removed from buildings. It pays to know if your debris includes asbestos products, and you should be told of that condition before you get the contract or do the work.
Disposal Options
Some states do not permit C&D debris to be placed in their municipal landfills and some states (California is one) require that you recycle a minimum percentage of the C&D debris you have generated at your site. That’s a tough regulation. Many of those with whom we spoke are truly concerned about reusing materials, about recycling materials like asphalt and concrete—but not everyone. We spoke to three contractors in Cincinnati, OH. The first two said they recycle nothing. They go to the site, tear down the structure and haul it all away. One of the contractors does site clearance and, “Most of that goes straight to the landfill. There’s not much that’s wanted by anybody.” The strongest reason given by both contractors was that they could not afford to store materials for recycling and the demand was poor, anyway. In the same region, we heard another opinion. “We recycle everything that can be recycled,” observes Charles St. John of Demolition Inc. His company works mostly in the Cincinnati area but has been asked to do demolition work in places as distant from his home base as Minneapolis, MN; Richmond, VA; and the far corner of Ohio in Toledo. “We recycle everything we can, immediately. We work mostly on houses, small buildings, and barns. We take the responsibility of reusing materials very seriously, and sometimes there’s plenty of usable debris.”
In Charlotte, NC, The Linda Construction Co. Inc. is also serious about recycling as much as possible. “We take out the concrete and asphalt,” notes assistant operations manager Mark Kerley. “We also recycle metals like stainless steel, and even working equipment. In some of the structures we demolish, there are pieces of equipment that can be of use to somebody and don’t deserve to go straight to a landfill.” The Linda Construction Co. has between 60 and 70 employees. Some of their projects are quite large—larger than a single residence. When factories are closed, it is not uncommon for machinery and equipment to be abandoned with the structure itself. Abandoned may be the wrong word. A demolition contractor may have a general contractor that tells him to remove everything and to take ownership of everything at the site. If the demolition contractor earns several thousand dollars for unwanted machinery, that helps to make the project worthwhile. Some of the biggest and most successful demolition contractors (for example, Brandenburg Industrial Service Co. of Chicago, IL) are experienced enough—and have the right staff—to know beforehand how much the contents of the building to be demolished will be worth. It is not unheard of for the contents to pay for the work. (That can be possible for smaller projects, too, so it’s advisable to see what is the most beneficial contract for you.)
There may not be tons of material suitable for recycling at your site. “If our demolition involves concrete or drywall,” comments Kelly Vasquez of Holes Inc., based in Houston, TX, “we can expect recycling. But much of our debris is hauled to the landfill for handling there.”
If there is one commodity that seems to have lost its recycling appeal in many parts of the country, it’s the lumber from houses. Several contractors asserted that nobody wanted it, either because of its age and condition, or because people building new structures wanted newer, different woods and, “They don’t make houses the way they used to” in some communities, explains Lisa Goldish of DeConstruction Services in Minneapolis, MN. “We demolish buildings by hand. We salvage kitchen cabinets, windows, doors, and even appliances. We have found there is little demand for the basic lumber. If we have redwood or cedar, they are usually marketable and used again.”
State Regulations
Many states have similar regulations for the disposal of C&D debris. You will come across exceptions, like some of the strict rules for California. If anything, those kinds of rules will increase, think many contractors, but very few were upset by the thought. To show you the regulations you may encounter, we stuck a pin in the map and came up with Nebraska. Whatever your state’s regulations, you should know them. As you will see, many of the negative items may never apply to your business—or only rarely. The regulations are provided to assist the public and regulated community; they do not apply only to large contractors. Whatever the regulations for C&D debris are in your state, they apply to you—whether you do demolition work every week or only once a year. (You may do it more frequently than you imagine. Demolition isn’t just the tearing down of complete buildings. When you change the kitchen cabinets or remodel the front porch, there’s demolition involved.)
Like most people in our country, the state of Nebraska recommends that everyone try to recycle or reuse building materials in other structures. If the C&D debris must be disposed of in another fashion, it should be taken to a permitted C&D waste landfill or to a municipal solid waste landfill. When a community provides a well-planned and safe disposal site for your waste, it expects you to use it. That’s understandable because the concern is for everybody in the community—especially for their water supply and good health.
It is acceptable in our sample state, Nebraska, to separate brick and concrete from demolition waste and use them in stabilization or land improvement projects, and to then take the unused materials to a permitted landfill. If there is a natural disaster, the Department of Environmental Quality can give permission for waste materials to be disposed of at another area, on a temporary basis only. In Nebraska it is permissible to bury farm buildings (bins, barns, and sheds, for example) on the farm property where it is standing. In other states, there may be regulations that say that nothing should be buried at the site of a demolition project. Burying the unwanted debris underground reminds one of sweeping the dust under the carpet; it does not solve the problem. In Nebraska, the acceptability of burying anything is for farm structures only. It is forbidden to demolish a house in an incorporated area (town, city, or village) and bury it onsite. It was done in former times and called “dropping it in the basement.” What you can do if you demolish a house and have a basement hole to fill is use debris that is considered “beneficial fill” to fill the pit; that would be a justifiable form of land improvement or landscaping. For the more devious demolition person, Nebraska reminds us that you cannot demolish a building or house in an incorporated area and then haul it out to bury on a farm.
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PHOTO: CATERPILLAR |
| Metal is separated from concrete and rubble; the rubble is used to fill to a dangerous out-of-town pit. |
You should not put demolition waste into a river, stream, or creek. Even if your fill is considered beneficial, it cannot be deposited in a river, stream, or creek in a way that would impact the flow of the water or the capacity of the flood plain. To do that you have to get permission from the US Army Corps of Engineers, one of whose responsibilities is to look after our water for us. Sometimes a building’s demolition is caused by fire. You cannot toss the ash wherever you like; you should dispose of it at a permitted landfill. Included in the regulations about C&D debris is the ban on burning buildings and waste without proper state and local permits. You can see that air and water quality are concerns, sensibly, behind many regulations.
Definitions
Because there are so many lawyers in our country and too many people trying to break the rules, the terms used in regulations about C&D debris must be clearly defined. Beneficial fill was mentioned above. To a state or other local public authority, it means something like this: uncontaminated gravel, sand, stone, rock, soil, concrete rubble, asphalt rubble, brick, or similar material, or some combination thereof, for the purpose of erosion control, erosion repair, channel stabilization, landscaping, road bed preparation, or other land improvement.
State regulations are probably more specific about definitions because they are closer to real, everyday situations than the federal agencies. In defining construction and demolition waste, Nebraska says it means waste that results from land clearing, the demolition of buildings, roads, or other structures, including—but not limited to—beneficial fill materials, wood (including painted and treated wood), land clearing debris other than yard waste, wall coverings (including wall paper, paneling, and tile), drywall, plaster, non-asbestos insulation, roofing shingles and other roof coverings, plumbing fixtures, glass, plastic, carpeting, electrical wiring, pipe, and metals. Such waste shall also include the above-listed types of waste that result from construction projects. Construction and demolition waste shall not include friable asbestos waste, special waste, liquid waste, hazardous waste and waste that contains polychlorinated biphenyl, putrescible waste, household, industrial solid waste, corrugated cardboard, appliances, tires, drums, and fuel tanks. A construction and demolition waste disposal area shall mean any area used for the sole purpose of disposal of construction and demolition waste. There’s more, but we get the gist. And, to tell the truth, we understand what is being advised and mandated.
As we mentioned before, most of us will rarely come across hazardous or unusual waste. If there is some friction or testiness, it is caused by the feeling that government would like us to reuse and recycle everything at the site, but the truth is that most of the debris is not wanted by anybody and the costs would be prohibitive to store debris that might be useful one day. “It costs us $50 an hour in labor to take things out,” comments Vince Miller of Site Recovery Services Inc. in Bellwood, IL. Most of their demolition involves smaller structures, buildings of three stories or less. “The only materials that are suitable for reuse or recycling are those that can be reused or recycled in an economically feasible manner. There is no sensible or practical way that we can store debris.” His opinions are echoed by Dean Ramos, founder of Platinum Excavating Inc. in Naples, FL. “Of course the concrete is processed and reused,” notes Ramos. “But most of the debris we generate is just that—debris. It’s mostly useless for any further use. It is hauled away and disposed of in the right places.” At TGL Environmental Inc. in Pompano Beach, FL, most of the debris goes to recycling. “We provide containers for the owners of the properties and charge them accordingly,” observes Gina Devine, owner of TGL. “We demolish houses, many of them older buildings that are coming down to be replaced by newer models. There is some debris that is reusable as it is but most is sent by us to a recycling center where it is dealt with correctly.” Last year’s hurricanes caused many tons of C&D debris and it seems to have been handled wisely and efficiently. Many of the companies involved in the post-hurricane work were (and are) grading and excavation contractors.
One person we spoke with has a business in demolition that intrigues us, because his goal is to save as much as possible of everything in the structure to be demolished. Willie White owns Architectural Demolition Inc., in New Orleans, LA. That city probably has more Victorian-era buildings than any other city in the US, and people constantly want to move them or renovate them without damage. “Ninety percent of what we do concerns historical buildings,” explains White. “A good example would be a 12,000-square-foot wood frame school building that was moved twelve blocks. All the windows and doors were reused—and the bricks. In fact the only materials that were not reused were the plaster and lath.” Most of the customers are private individuals who wish to take down or change something, for whatever reason; and then preservationists come in and try to save as much of historical value as possible.
Although most of us are used to wooden houses, some parts of the country have many brick buildings, both residential and industrial. “We find that most of the materials are not suitable for reuse or recycling,” says Kevin Simms, owner of KMS Excavating in Shelton, CT. “We don’t do much demolition but we have noticed that, when we do, the bricks of old houses are more likely to be wanted than anything else. People use them for landscaping or pulverize them for attractive driveways. Sometimes doors and windows can be used again. It all depends on their condition, their age, and their attractiveness.” That brings us to the statement we hear so often—that debris is reusable when somebody wants it, and can pay for it.
Asbestos and Lead-Based Paint
As older houses come down, two materials that used to be common are involved. It’s almost 30 years since lead-based paint was banned but you may still find it in older houses. The biggest danger may be to workers during demolition or renovation—when they are sanding, cutting, scraping, heating, or blasting the paint from buildings (or from tanks and metal bridges). Lead poisoning is a serious health threat to adults and even more dangerous for young children. It can cause anemia, as well as damage to the kidneys, liver, and brain. It can also cause reproductive disorders. C&D debris from commercial and industrial sites contaminated with lead-based paint must be managed as hazardous waste if a sample meets the toxicity characteristic. But—and this is a big but—contractors who are remodeling, renovating, or abating lead-based paint in homes are allowed to dispose of lead-based paint as household garbage. Contractors who generate the waste in that way generally do not need to determine the toxicity characteristics under the Resource Conservation and Recovery Act. It would be a good idea to contact your state agency to confirm local requirements. This easy-to-deal-with waste usually comprises window frames, doors, painted woodwork, and the inevitable paint chips. Let’s repeat that lead poisoning is a deadly enemy—so much so that you should not eat, drink, or smoke around lead-based-paint work. Wash your hands and face before eating, drinking, or smoking. When it’s time to go home, change; do not wear any clothes that have been covered in lead-based paint dust.
Asbestos has been used in many, many projects because of its fire resistance and insulation qualities. You can find it in siding shingles, cement products, resilient floor coverings, insulation, and roofing products. Asbestos-containing materials (ACMs) are now considered a major health hazard because they cause scarring of lung tissue and certain types of cancer. Asbestos is strictly regulated by both OSHA and the EPA. If the ACMs can be crumbled under hand pressure or are in spray-applied fireproofing or insulation, they are strictly regulated when they are found in reconstruction or demolition. Few of the contractors with whom we spoke mentioned lead-based paint or asbestos materials as major problems for them, which is excellent news.
Equipment for C&D Debris
Most grading and excavation contractors seem to have the same experiences as Dominic Fantozzi at Fantozzi Demolition & Excavation in Island Park, NY. “We may have 10% demolition in our schedule,” comments Fantozzi (the last of the great Romans, he assures me). “Ninety percent of our work is excavation. Our demolition is usually for small buildings, like houses, and there is very little worth saving in the debris. We do take out some metals and sell them but the debris is generally not suitable for reuse or recycling.”
You are essentially in grading and excavation, but a demolition job may be offered to you because of your good reputation in everything else. How do you get the right equipment? For occasional applications, renting seems to be the most practical answer. With the wonderful array of attachments now available, there are certainly the tools you need for demolishing, breaking, and even sweeping up. Most of your demolition work can be done with your existing equipment and the right attachments (purchased or rented). Demolition Inc.’s Charles St. John gave us this advice to pass along to other contractors. “Tell anybody who has never done demolition that the right equipment is available and not difficult to run. But demolition is dangerous, and never think that it won’t be.” Those are words of wisdom, indeed, and remind us that demolition is a nicer way of saying smashing, crushing, breaking, destroying, and tearing apart. It is dangerous, but it can help you expand your business and bring good profits. Just as you do for grading, dozing, and excavation, make sure that you do everything right.