Hazardous Substances & Hazardous Building Materials
When a brownfield includes buildings, hazardous building materials (HBM) surveys are often necessary so demolition or rehab can proceed safely and legally. DEC’s Brownfields Program offers Brownfield Assessment and Cleanup (DBAC) services, which can include Phase I/II environmental site assessments, hazardous building materials (HBM) surveys, cleanup planning, and in some cases abatement of HBM, to reduce environmental uncertainties that block reuse.
HBMs in Alaska sit within a layered framework:
- DEC Solid Waste (18 AAC 60) governs landfill acceptance, disposal, and special rules for asbestos (RACM and non RACM), “polluted soil,” and construction & demolition (C&D) waste.
- DEC guidance requires a hazard building materials survey before demolition/renovation to identify risks; NESHAP notice to EPA Region 10 is required ≥10 days before demolition for covered structures.
- OSHA standards apply to worker protection (e.g., asbestos standard 29 CFR 1926.1101).
- EPA TSCA governs PCBs in building materials (e.g., management of PCB containing caulk and adjacent contaminated substrates).
Asbestos
Buildings constructed before 1980 are especially likely to contain asbestos materials. Asbestos was extensively used in building construction throughout Alaska, especially in:
- Pipe insulation and boiler wrap
- Floor tiles and mastics
- Drywall joint compound
- Roofing and siding materials
- Cement board and panels
- Sprayed on fireproofing
- Acoustic ceiling materials
When asbestos-containing materials (ACMs) are disturbed, tiny fibers can become airborne and pose significant health risks. Because disturbance is common during demolition or renovation, HBMs surveys are required before this work begins.
- Materials with more than 1% asbestos are subject to disposal regulations.
- Renovation and demolition projects must include an asbestos survey conducted by a certified inspector.
- Certain demolition activities require notification under EPA’s NESHAP rules (10-day notice).
- Disposal must follow DEC solid waste regulations (18 AAC 60), which include packaging, labeling, transport, and use of approved landfills.
- Alaska requires RACM to go to approved RACM landfills with leak proof packaging, labeling, shipment records, and daily cover; non RACM may go to permitted municipal landfills with specific handling.
- ADEC Solid Waste Asbestos Disposal
Asbestos surveys are often funded or coordinated through DEC Brownfields DBAC services when asbestos could complicate reuse, redevelopment, or site cleanup.
Lead and Lead-Based Paint (LBP)
Peeling or disturbed paint is the most common exposure pathway. Lead-based paint was used in many buildings before 1978 and remains common in:
- Siding and exterior trim
- Interior walls, doors, and window frames
- Painted metal surfaces
- Industrial structures and older public buildings
Lead is toxic to humans and animals. It is harmful if inhaled or swallowed and can pose serious health risks. When painted surfaces are not maintained, paint can deteriorate, peel, chip or crack and become a hazard. Old or worn lead-based paint, especially on surfaces subject to constant friction like doors or window sills, can produce chips and dust that become a hazard when inhaled or ingested. Any renovation or demolition in a pre-1978 home or building that has lead-based paint can easily create dangerous lead dust.
Lead-containing materials require special handling during demolition or renovation:
- Waste is commonly screened using the TCLP test to determine if it is hazardous waste.
- Alaska distinguishes between residential and non-residential lead paint waste for disposal. Non residential LBP debris must meet TCLP (<5 mg/L) and “polluted soil” thresholds (≥400 mg/kg lead) to determine disposal options and cell type.
- Some soils or construction debris may meet the definition of “polluted material,” requiring disposal at a lined landfill or special handling.
- ADEC Solid Waste Non Residential Lead Disposal
LBP assessments are routinely included as part of Phase II ESA or HBM surveys. Management and disposal planning often integrate with cleanup activities and redevelopment planning.
Polychlorinated Biphenyls (PCBs)
PCBs were widely used in building materials between the 1950s and 1970s. Common sources include:
- Old electrical transformers and capacitors
- Fluorescent light ballasts
- Caulks, sealants, and mastics
- Certain paints and industrial coatings
- Adhesives and rubberized materials
PCBs in caulk were especially widespread in schools, public buildings, and commercial structures built before 1979.
PCBs PCBs are persistent, bioaccumulative, and regulated under the Toxic Substances Control Act (TSCA). Even when present in small amounts, PCBs in building materials may trigger strict cleanup and disposal requirements.
- Regulated PCBs, >50ppm cannot be disposed of in the state of Alaska and must be shipped to a facility that accepts this material.
- Adjacent materials (brick, concrete, wood, soil, etc) may also become contaminated and require removal.
- Only TSCA-authorized disposal options may be used, sometimes including out-of-state facilities.
PCB issues often complicate redevelopment of schools, industrial buildings, military structures, and older commercial properties. Identifying PCBs early helps avoid large unexpected abatement costs.
Other Hazardous Building Materials
In addition to asbestos, lead, and PCBs, Alaska brownfields often contain other materials of concern:
Commonly present in thermmostats, fluorescent lamps, gym floor finishing materials, and older medical or laboratory equipment. Mercury spills require specialized cleanup and vapor monitoring.
While not regulated as hazardous waste, mold can pose health risks and must be managed during demolition or rehab. Brownfield funding cannot be used for mold assessment or abatement.
Many building cleanouts generate universal wastes, such as batteries, lamps, pesticides, and aerosol cans. These materials require proper accumulation, labeling, and disposal.
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