Asbestos Concrete Pipe Replacement Using Pipe-Bursting
Purpose
The purpose of this publication is to summarize guidance documents made by the U.S. Environmental Protection Agency (USEPA) regarding renovation projects on asbestos concrete (AC) pipe, also known as Transite pipe, (hereinafter “AC pipe”), using pipe bursting technologies.
Background
AC pipe, commonly used for potable watermains during the 1940s through 1980s, is typically characterized as "non-friable” when in good condition and actively used as part of a water distribution system that accounts for approximately 15 percent (~600,000 miles) of watermain pipe material in North America. The typical life span of AC pipe is 50 years, and the majority is past or nearing the end of its useful life. Over time, the cementitious bonds of the AC pipe will erode, causing leaks and the continued degradation of the pipe.
USEPA has determined that during the pipe bursting process, the AC pipe becomes friable by being crushed, crumbled, or pulverized, thus making it a Regulated Asbestos Containing Material (RACM) subject to the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation at 40 C.F.R. Part 61 and the demolition provisions of 40 CFR 61.145 would apply.[1]. USEPA has determined that a public water system is a “facility” and AC pipe that is part of a public water system is a “facility component” subject to NESHAP. As such, the backfilling and burial of the bursted AC pipe would cause these locations to be considered active waste disposal sites and subject to the NESHAP requirements in 40 CFR 61.154. If the AC pipe is abandoned in place without crushing it would not be subject to the NESHAP requirements.
There are available conventional methods for the replacement of the AC pipes, including open trenching and abandonment in place. On May 30, 2019, USEPA approved a request for an Alternate Work Practice (AWP) for AC pipe known as “close tolerance pipe slurification” (CTPS). This work practice provides for a trenchless method of removing and replacing AC pipe and is protective of human health and the environment as the Asbestos NESHAP.
The USEPA has made clear: “Where a potential work practice would depart from any part of the existing rule for a regulated activity, 40 CFR 61.12(d) explains how the USEPA may approve an AWP, and such approval would be required in advance of using the potential AWP.”[1] EPA has not approved AC pipe bursting/breaking as an AWP.
Conclusion
In the April 13, 2022, AC Pipe Replacement memorandum, USEPA emphasized that approved AC pipe replacement methods only include abandonment in place, open trench and CTPS pipe removal. USEPA further stated that the pipe bursting and pipe breaking are not approved technologies because they “render the existing pipe friable and do not comply with the requirements of the Asbestos NESHAP.”
Due to the federal regulatory requirements with pipe bursting of AC pipe, the Department of Environment, Great Lakes, and Energy (EGLE) will generally not permit the use of pipe bursting as an acceptable method for rehabilitation of AC pipe. If new industry research and/or site testing changes the federal position, EGLE will update stakeholders and inform our state permitting engineers.
[1] July 1991 Determination by EPA to John B. Rasnic
[1] National Emission Standards for Hazardous Air Pollutants for Asbestos: Notice of Final Approval for an Alternative Work Practice Standard for Asbestos Cement Pipe Replacement, 84 Fed. Reg. 26852, 26858 (June 10, 2019).
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