Waste Management Program fact sheet
Division of Environmental Quality Director: Ed Galbraith
PUB2374

Project Checklist

Disclaimer: The checklist is intended to help those planning a demolition project in Missouri to comply with various laws and regulations intended to protect human health and the environment. This checklist is not intended, nor can it be relied on, to create any rights enforceable by any party in litigation. It is recommended you contact the county or city of jurisdiction to determine if additional local requirements apply to your situation. Contact information for the Missouri Department of Natural Resources and specific programs referenced in the checklist is found at the end of this document.

Pre-Planning

  • All public, commercial, and in some cases residential structures, must be inspected by a Missouri certified asbestos inspector prior to beginning any demolition or renovation project. A listing of currently certified asbestos inspectors is available on the department’s asbestos webpage or by calling the Air Pollution Control Program at 573-751-4817.
  • Determine if there are hazardous materials in the building such as lead pipes, lead paint, thermostats, fluorescent bulbs, batteries, pesticides, cleaners and other chemicals that would become hazardous wastes if intended for discard. If so, additional regulations may apply. Refer to the guidance document, Handbook for Small Quantity Generators - PUB2174 for information on hazardous waste management in Missouri.
  • Hazardous fluorescent bulbs, thermostats, pesticides and batteries in good condition may be managed as universal waste. If not managed as universal waste, these materials would need to be characterized to determine if they are hazardous waste for proper on-site management and disposal. For more information review the department's The Universal Waste Rule in Missouri - PUB2058 fact sheet.
  • Are there abandoned cisterns or wells? If so, additional regulations may apply. For more information, review the department’s Abandoned Wells: Locating, Plugging and Reporting - PUB2900 fact sheet.
  • Are there above- or underground petroleum storage tanks? If so, additional regulations may apply. For more information about underground storage tanks, visit Underground Storage Tank Requirements. For information about above-ground storage tanks, please contact the Missouri Department of Agriculture by telephone at 573-751-5636.
  • Are there air conditioning units or refrigeration units with refrigerants such as chlorofluorocarbons, or CFCs? If so, contact the CFC Stratospheric Ozone Hotline at 800-296-1996 about managing CFCs.
  • Are there light ballasts that may contain Polychlorinated Biphenyls, or PCBs? If so, visit EPA's Disposal of Fluorescent Light Ballasts webpage.
  • Contact the recycling or waste disposal facility where the recovered materials or demolition waste will be received to ensure the facility can receive the waste and to check for any restrictions or special requirement the facility may have for the waste.

Notifications

  • Submit a Closure Notice for Underground Storage Tanks MO 780-2121 form 30-days before beginning an underground storage tank closure and notify the department's Underground Storage Tanks Section three days before beginning closure activities.
  • Register with the department as a hazardous waste generator if generating or accumulating 220 pounds or more of hazardous waste per month. Refer to the department’s Handbook for Small Quantity Generators - PUB2174 guidance document for more information, including how to register as a hazardous waste generator.
  • Submit an Asbestos NESHAP Notification of Demolition and Renovation MO 780-1923 form to the department's Air Pollution Control Program at least 10 business days before demolition start date of any regulated structure (public, commercial and in some cases residential). Include a copy of the asbestos inspection report by a Missouri certified asbestos inspector. Submission is required for regulated structures, regardless of whether asbestos is found. Note that local health departments may have stricter requirements.
  • If removal or disturbance of greater than 160 square feet, 260 linear feet, or 35 cubic feet of regulated asbestos-containing materials will occur during the demolition project, submit an Asbestos Project Notification MO 780-1226 form to the department's Air Pollution Control Program at least 10 business days before the start of the abatement project. Note that local health departments may have stricter requirements.
  • Submit an Water Well/ Heat Pump Plugging Registration Report MO 780-1603 to the department’s Wellhead Protection Section for plugging an abandoned well. 

Demolition and Post Demolition Activities

  • Recovered materials that can be reused or be made into new products must be used in some way to remain exempt from regulation as solid waste. Potentially recoverable materials include clean fill, metals, plastics, glass, electrical wire, asphalt shingles and wood.
  • If light ballasts were manufactured before 1979, or manufactured after 1979 and do not have labels stating they do not contain PCBs, assume they contain PCBs. Carefully remove light ballasts to prevent PCB leaks and remove and contain leaking ballasts in a manner that minimizes contamination. Use a licensed hazardous waste transporter to transport PCB waste to a disposal facility.
  • Universal wastes must be transported to a universal waste handler or destination facility. For more information, review the department's The Universal Waste Rule in Missouri - PUB2058 fact sheet.
  • Hazardous wastes must be appropriately packaged, marked and labeled and transported to a treatment, storage and disposal facility or certified resource recovery facility. The transporter must have a valid EPA generator identification number and active Missouri hazardous waste transporter license. An EPA identification number can be obtained after submitting a completed Notice of Regulated Waste Activity MO 780-1164 form. To apply for a hazardous waste transporter license visit the Missouri Department of Transportation’s Motor Carrier Services webpage. 
  • Properly close petroleum storage tanks in-place or by removal.
  • Asbestos-containing materials must be removed by a Missouri registered asbestos contractor prior to demolition if the amount of regulated asbestos containing material is greater than 160 square feet, 260 linear feet or 35 cubic feet.
  • Manage remaining asbestos-containing material in the structure in a manner that will keep it from being broken-up, made friable or becoming regulated asbestos containing material.
  • Minimize dust during demolition and prevent dust from leaving property boundaries.
  • Intentional burning and other training activities for the purpose of training and instructing fire protection, law enforcement or emergency personnel are exempt from Missouri open burning regulations as long as the exercise conforms to the limitation described in the regulation, doesn’t cause hazards to air or vehicular traffic and doesn’t cause a violation of any other regulation. This exemption is intended only for fire training exercises and is not for allowing the intentional burning of a structure as a method of disposal. If a structure is already knocked down, it does not meet the conditions for the exemption and the option to be burned as a part of a fire training exercise. The knocked-down structure must instead be taken to a permitted solid waste facility for disposal. Also, structures used for training exercises are still subject to state and federal asbestos regulations.
  • All regulated asbestos-containing material and all petroleum-based products (in the case of fire training) such as asphalt shingles and vinyl tile must be removed before beginning the training exercise.
  • Properly plug abandoned wells and cisterns.
  • Clean fill is uncontaminated soil, rock, sand, gravel, concrete, asphaltic concrete, cinderblock and brick with very small amounts of wood and metal, and other inert solids approved by the department. These materials may be used as fill on-site, with the permission of the property owner. If clean fill will come in contact with surface water or subsurface water, contact the department's Water Protection Program at 573-751-1300 for guidance.
  • Major appliances except for microwaves cannot be disposed of in landfills and must be salvaged.
  • Demolition debris deemed non-hazardous must be transported to a permitted solid waste landfill or processing facility.
  • All asbestos-containing materials must be disposed of in a permitted landfill. Contact the landfill before transporting the materials to obtain special handling requirements.

Additional Resources

Additional fact sheets and publications are available at Publications and Fact Sheets


Nothing in this document may be used to implement any enforcement action or levy any penalty unless promulgated by rule under chapter 536 or authorized by statute.


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