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Pipebursting AC Pipe Problematic, Says EPA
Facing the prospect of replacing hundreds of thousands of feet of old AC pipe, project owners and contractors are faced with what they must do to comply with environmental regulations to properly dispose of old AC pipe removed from the ground, pieces of broken pipe removed in slurry during pipe reaming operations, and whether it is permissible to leave broken AC pipe segments in the ground after pipebursting procedures.
The U.S. Environmental Protection Agency (EPA) is responsible for protecting the public from asbestos hazards, and Von Aspern believes confusion over how EPA regulations apply to AC pipe continues to cause problems for utility providers and contractors who serve them.
"One area of confusion," said Von Aspern, "is whether public agencies are required to replace AC pipe. Studies have indicated that in normal use, AC pipe does not pose a threat to public health. However, if AC pipe is tapped, cut, crushed and removed from the ground for disposal, National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations apply."
Another point of confusion is whether contractors need special licensing to work with AC pipe.
"Contrary to common belief," Von Aspern said, "in most cases special licensed contractors are not required to work with AC pipe (New Jersey is one exception). Many states have developed programs to train individual employees in safe practices involving the regulated AC pipe practices. These training programs provide employer exemptions for hiring licensed contractors. In addition, guidelines have been established for licensing of course providers to extend available training resources while maintaining consistency in content and message."
In 1991, the EPA took the position that "crushing" AC pipe with mechanical equipment would cause the crushed material to become regulated asbestos containing material and that pipe crushed and left in place would cause the location to be considered an active waste disposal site. Without using the term pipebursting, this appears pipebursting and pipe reaming cause remnants of AC pipe to be in the category of regulated waste.
"Because pipebursting was not specifically identified in the EPA letter, interpretation of EPA's intent has been inconsistent in the industry. Some entities are issuing clarifying documents," said Von Aspern.
For example, in California, the Bay Area Air Quality Management District issued a Compliance Advisory addressing the pipebursting and pipe reaming construction methods, as well as EPA's interpretation of NESHAP requirements concerning these specific techniques.