January 13, 2014

Hazardous Material Assessments for Demolition Projects

Before beginning a demolition project, the building/structure owner/operator should develop a work plan. This plan guides personnel through the various steps of assessing and demolishing the building/structure. One of the main components in the demolition work plan will be a hazardous materials assessment. This assessment identifies all hazardous materials in the building/structure that will be generated during cleaning and demolition. The items to be covered in the pre-demolition hazardous materials assessment and recommended pre-demolition material removal activities are as follows.

  1. Building/structure itself:
    • Assessment of any containers: 1) if product, remove for use; 2) if waste (e.g., used rags, used oil, used aerosol cans, unused but unusable product, drums of unknown material/waste), make a hazardous waste determination and manage accordingly; 3) if RCRA-empty, manage as nonhazardous waste or scrap metal.
    • Assessment of any noncontainerized debris (e.g., pallets, cardboard, tires, trash); make a hazardous waste determination and manage accordingly.
    • Assessment for lead-based paint (LBP) on building/structure components. If found, management options include 1) removing LBP layers from building/structure surfaces prior to demolition, 2) removing building/structure components that contain elevated levels of LBP prior to demolition, and 3) using sampling and analysis or other evaluation to determine if the debris generated during demolition is hazardous or nonhazardous for lead.
    • Assessment for mercury-containing lamps, thermostats, switches, and other types of equipment that contain mercury. Once identified, these items should all be removed from the building/structure prior to demolition and either 1) reused as products for their intended purpose, or 2) managed as universal waste or D009 hazardous waste.
    • Assessment for chlorofluorocarbons (CFCs) in air conditioning, heat pump, or other refrigeration equipment. CAA-regulated refrigerants may not be released during salvaging or dismantling activities; they must be properly recovered, using approved equipment operated by qualified technicians.
    • Assessment for PCBs in transformers, capacitors, light ballasts, paint, caulking, roofing materials, and other building/structure materials. Once identified, these PCB-containing materials should be removed from the building/structure prior to demolition and managed per the applicable TSCA regulations.
    • Assessment for asbestos in vinyl floor tiles, roofing felt, ceiling texture, cement stucco and gypsum plaster, roofing and siding shingles, insulation/fire-proofing, and other building/structure materials. Once identified, asbestos-containing materials should be removed from the building/structure prior to demolition and managed per the applicable TSCA/OSHA regulations.
  2. Process equipment within building/structure—The regulatory status of residues remaining within this equipment is subject to §261.4(c). This section notes these residues are exempt from RCRA regulation until one of two things occurs: 1) the residues are removed from the process unit in which they were generated, or 2) the residues remain in the unit for more than 90 days after the unit is temporarily or permanently removed from service. Once these residues potentially become subject to RCRA for one of the two reasons noted above, a hazardous waste determination must be made and the equipment and/or the removed residues must be managed appropriately. Once decontaminated, the process equipment should be removed from the building/structure and 1) reused somewhere else as nonwaste equipment, 2) sent for scrap metal recycling if metallic, or 3) disposed.
  3. Utilities within building/structure—These systems may present RCRA issues. Utility systems that should be evaluated for removal before demolition include 1) hydraulic systems (paying particular attention to the possibility of PCBs in old hydraulic oil), 2) drain lines and traps, 3) sumps and other floor drains/trenches, 4) tritium exit signs, 5) uninterruptible power supplies, and 6) fire extinguishers/fire suppression systems.
  4. Hazardous waste tanks/container accumulation areas within building/structure—These units need to be closed per the RCRA regs. Some units, such as 180-day container accumulation areas and satellite accumulation areas, are not subject to any closure requirements in the federal RCRA regulations. If no state provisions are applicable, they should be closed using best professional judgment.
  5. Spills/stains on walls, concrete—It is of particular importance to decontaminate buildings/structures before demolition so hazardous demolition debris is not generated. Residues generated from cleaning such spills/stains need a hazardous waste determination.
  6. Assessment of soil/ground water contamination (either before or after demolition)—If soil and/or ground water contamination adjacent to or underlying the building/structure is discovered before, during, or after demolition, the site owner/operator will need to decide if remediation is required once demolition is complete. This determination is usually based on site-specific health risk-based action levels. You may need to get your state environmental agency involved with this decision. If a decision is made to remediate contaminated soil and/or ground water, a hazardous waste determination will be required at the point of generation of the remediation wastes.


©2014-2021 McCoy and Associates, Inc. All rights reserved.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.



Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.