Order Code RL34576
Managing Disaster Debris:
Overview of Regulatory Requirements,
Agency Roles, and Selected Challenges
July 15, 2008
Linda Luther
Analyst in Environmental Policy
Resources, Science, and Industry Division

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Managing Disaster Debris: Overview of Regulatory
Requirements, Agency Roles, and Selected Challenges
Summary
After a disaster, when a region turns its attention to rebuilding, one of the
greatest challenges to moving forward may involve how to properly manage debris
generated by the event. Options include typical methods of waste management —
landfilling, recycling, or burning. The challenge after a major disaster (e.g., a
building or bridge collapse, or a flood, hurricane, or earthquake) is in managing
significantly greater amounts of debris often left in the wake of such an event.
Debris after a disaster may include waste soils and sediments, vegetation (trees,
limbs, shrubs), municipal solid waste (common household garbage, personal
belongings), construction and demolition debris (in some instances, entire residential
structures and all their contents), vehicles (cars, trucks, boats), food waste, so-called
white goods (refrigerators, freezers, air conditioners), and household hazardous waste
(cleaning agents, pesticides, pool chemicals). Each type of waste may contain or be
contaminated with certain toxic or hazardous constituents. In the short term, removal
of debris is necessary to facilitate the recovery of a geographic area. In the long term,
the methods by which these wastes are to be managed require proper consideration
to ensure that their management (by landfilling, for example) will not pose future
threats to human health or the environment.
After a presidentially declared disaster, federal funding or direct assistance in
response to the disaster may be available to a state or local government. The Federal
Emergency Management Agency (FEMA) may provide funding through its Public
Assistance (PA) Grant Program for debris removal operations that eliminate
immediate threats to lives, public health, and safety, or eliminate immediate threats
of significant damage to improved public or private property. The federal share of
funding to the affected area will be stated in the disaster declaration, but will be no
less than 75%. The funding will be available for response activities in a designated
geographic area for a specific period of time.
In addition to funding, if the state or local government does not have the
capability to respond to the disaster, it may request direct federal assistance from
FEMA. Federal agencies most likely to assist with debris removal operations are the
Army Corps of Engineers (the Corps) and the U.S. Environmental Protection Agency
(EPA). Activities they may perform include right-of-way clearance, curbside waste
pickup, private property debris removal, property demolition, assistance with
contaminated debris management, and collection of household hazardous waste.
This report provides background to help readers understand why debris removal
can be such a costly and lengthy operation. (The debris removal process may involve
several activities, such as waste separation, hauling, landfill disposal, burning, and
recycling.) To illustrate these points, this report provides an overview of the types
and amounts of debris often generated after a disaster, and discusses selected
regulatory requirements potentially applicable to debris removal. The report also
outlines federal, state, and local agency roles in the debris removal process, and
includes a discussion of the activities that are eligible for federal funding.

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Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Types and Amount of Debris . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Federal and State Waste Management Requirements . . . . . . . . . . . . . . . . . . . . . . 3
Federal and State Agency Roles in Debris Removal . . . . . . . . . . . . . . . . . . . . . . . 5
Federal Agency Roles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
FEMA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
The Corps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
EPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
State and Local Agency Roles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Selected Challenges to Managing Disaster Debris . . . . . . . . . . . . . . . . . . . . . . . . 9
Managing Large Volumes of Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Ensuring the Ability of Residents to Return to a Disaster Area . . . . . . . . . 10
Separating Hazardous and Nonhazardous Wastes . . . . . . . . . . . . . . . . . . . . 10
Managing Asbestos-Containing Materials . . . . . . . . . . . . . . . . . . . . . . . . . . 10
For Additional Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

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Managing Disaster Debris:
Overview of Regulatory Requirements,
Agency Roles and Selected Challenges
Introduction
In the aftermath of a major natural disaster, a potential threat to safety and
obstacle to recovery and rebuilding is the presence of significant amounts of disaster
debris. Depending on the type of disaster, debris may include waste soils and
sediments, vegetation (trees and shrubs), man-made structures (collapsed homes,
buildings, or bridges), and personal property. The ability of residents to return to the
area and live in a safe and healthy environment may depend on how quickly and
effectively a community manages its debris.
There are many factors that influence the proper and timely management of
disaster debris. For one, the sheer volume of debris can overwhelm a community. As
an illustration, what follows are disaster debris amounts generated during three major
disasters:
! Hurricane Katrina, 2005 — more than 118 million cubic yards (CY)1
over a 93,000-square-mile area.
! Hurricane Andrew, 1992 — 43 million CY over a 500-square-mile
area.
! The Northridge Earthquake, 1994 — 7 million CY.
A large volume of waste can quickly overburden existing landfill space. The likely
best choice for most regions will involve diverting as much debris as possible from
area landfills (through recycling, burning, composting, or another method of volume
reduction) the logistics of which, however, can prove complicated without proper
pre-disaster planning.
Also, the desire to manage disaster debris as quickly as possible can have
detrimental long-term repercussions if debris is managed improperly. During a
disaster, some amount of hazardous waste will likely be commingled with
nonhazardous wastes (for instance, under flooding conditions, household hazardous
waste or sewage may contaminate nonhazardous personal property). Afterward,
improper disposal of hazardous waste may lead to future environmental, health, or
safety problems, such as the contamination of local groundwater.
1 By way of comparison, a cubic yard is approximately the size of a conventional
dishwasher.

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This report addresses debris resulting from a “major disaster” or “emergency”
declared by the President. First, it discusses the types of debris commonly generated
during and after a disaster and selected factors that can make “debris removal”2 such
a costly, complex operation. Second, it discusses the roles of federal, state, and local
agencies after a disaster has been declared — with regard to both funding debris
removal and the actual physical process of removal.
Types and Amount of Debris
Generally, “disaster debris” includes waste materials created after a natural
disaster such as an earthquake, tornado, fire, flood, hurricane, or winter snow or ice
storm. Before a community can move forward with debris recovery, it must have
some understanding of the types of debris involved and the volume it must handle.
The type of debris generated is largely dependent upon the nature of the
disaster.3 For example, debris caused by flooding differs somewhat from debris
resulting from an earthquake or tornado. Each category of debris poses individual
challenges to disposal, particularly when generated in significant amounts or when
forms of waste become mixed with one another to the point that separation is
difficult. Typical disaster debris includes
! municipal solid waste (MSW) — personal belongings and general
household trash;
! soil and sediment;
! putrescibles — animal carcasses (pets or farm animals), rotten or
spoiled fruits, vegetables, seafood, or meats;
! white goods — refrigerators, freezers, air conditioners, washers,
dryers, stoves, water heaters, and dishwashers;
! household hazardous waste — oil, pesticides, paints, cleaning
agents;
! construction and demolition (C&D) debris — road, bridge, or
building materials such as metals, asphalt, drywall, plaster, brick,
concrete, roofing materials, and treated or untreated lumber;
! vegetative debris — trees, branches, shrubs, and logs;
! vehicles and vessels — cars, trucks, and boats, fuel, motor oil,
batteries, and tires; and
! electronic waste — computers, televisions, printers, stereos, DVD
players, and telephones.
2 In this report, the term “debris removal” is used broadly. Where necessary, actions such
as disposal or recycling are referred to specifically.
3 For more information, see the Environmental Protection Agency’s report Planning for
Natural Disaster Debris, March 2008, pp. 6-7, available online at [http://www.epa.gov/
CDmaterials/pubs/pndd.pdf] and the Federal Emergency Management Agency’s FEMA-325,
Public Assistance: Debris Management Guide, July 2007, pp. 54-57, available online at
[http://www.fema.gov/government/grant/pa/demagde.shtm].

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To appropriately manage these different waste streams, it is also necessary to
estimate the total volume of debris. This is important for various reasons, including
the identification of appropriate staging grounds to separate wastes, determination of
necessary landfill space, determination of necessary contract services, and
anticipation of special handling requirements applicable to hazardous debris.
There are various methods of estimating debris totals. The Army Corps of
Engineers (the Corps) uses mathematical modeling forecasts that take into account
such factors as the number of households affected, the amount of vegetative cover
in a given area, commercial density, and a storm’s intensity.4
To effectively manage disaster debris, the U.S. Environmental Protection
Agency (EPA) and the Federal Emergency Management Agency (FEMA)
recommend that states develop a disaster debris management plan before a disaster
strikes. Such plans delineate the types of disaster debris that will be handled under
particular emergency conditions and existing laws that apply to the handling and
disposal of different types of waste (i.e., hazardous waste, nonhazardous waste,
asbestos-containing materials). State plans may also specify requirements regarding
a selection of debris storage and staging sites and waste-handling methods (e.g.,
chipping/grinding, burning, or landfilling) for certain types of waste, provide an
inventory of debris capacity at local debris management facilities — including
recycling, waste to energy, and disposal options — and evaluate equipment and
administrative needs such as pre-negotiated waste management contracts and pre-
qualified contractors.5
Federal and State Waste Management
Requirements
Generally, disaster debris will be sent to a landfill or it may be managed in some
way that reduces its volume (such as open burning/incineration,6 recycling, or
chipping and grinding). Each choice involves activities that may require compliance
with certain local, state, or federal regulations. For example, states are required to
manage solid and hazardous waste in accordance with provisions of the Resource
Conservation and Recovery Act (RCRA).7 (In addition to RCRA, depending on how
4 FEMA-325, Public Assistance: Debris Management Guide, pp. 53-62 and Appendix B.
5 EPA, Planning for Natural Disaster Debris, pp. 3-31.
6 Open burning includes both burning debris in an open pit and burning debris in an air
curtain incinerator (ACI). The air curtain method incorporates a pit constructed by digging
below grade or building above grade (if there is a shallow groundwater table) and a blower.
The blower and pit make up an engineered system which must be precisely configured to
properly function. The blower must have adequate air velocity to provide a “curtain effect”
to hold smoke in and to feed air to the fire below. See EPA’s, “Planning for Natural Disaster
Debris, pp. 30.
7 Solid waste is defined broadly under the law as “any garbage, refuse ... and other discarded
material” (42 U.S.C. § 6903). Hazardous waste, a subset of solid waste, is defined as a solid
(continued...)

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waste is managed, provisions of other environmental laws such as the Clean Air Act
or Clean Water Act may also apply.)
Under RCRA, businesses that generate hazardous waste above certain
thresholds must transport, treat, store, and dispose of their hazardous waste in
accordance with certain regulatory requirements. However, households and certain
small businesses are essentially exempt from RCRA. This means that hazardous
waste generated by these entities can be disposed of in common household or
municipal garbage. After a disaster, this can be a particular concern when hazardous
waste is generated in significant amounts by these unregulated entities.
Although any waste management choice may involve certain environmental
concerns, landfilling and burning generally cause the most concern among a region’s
residents. With regard to landfilling, municipal solid waste landfills are
predominantly regulated by state and local governments. EPA has, however,
established minimum criteria that these landfills must meet. States are then
authorized to implement their own criteria, provided they are at least as stringent as
federal requirements.
Often, a sizable proportion of disaster debris is managed as construction and
demolition (C&D) waste. Under federal law, C&D waste is classified neither as
hazardous waste nor as municipal solid waste. Therefore, C&D landfills are not
subject to federal design and operational criteria (i.e., C&D landfills are not required
under federal law to have protective liners that a municipal solid waste landfill,
which is expected to receive a certain amount of hazardous waste from households,
would have).
The disposal of C&D waste is primarily a state-regulated issue. This means that
states have the authority to determine what criteria a C&D landfill must meet and
what materials constitute C&D waste. In the event of an emergency, a state may
change the regulatory definition of C&D debris to more broadly characterize larger
volumes of debris that have been generated in the wake of a particular disaster. One
issue of concern with this approach is that C&D waste commingled with more
hazardous materials could be disposed of at landfills that are not designed to accept
such wastes. Therefore, it is suggested that hazardous materials such as asbestos,
lead-based paint, PCBs, and any other contaminated materials should be separated
from C&D waste before landfill disposal.8 Further, to lessen the burden on disposal
facilities and potentially reduce costs, it is recommended that C&D waste be reused
and recycled.
Like C&D waste, vegetative debris often represents a significant proportion of
disaster debris. Vegetative debris can be chipped or ground up for re-use. It is
estimated that the volume of vegetative debris can be reduced by as much as 75%
7 (...continued)
waste that is either specifically listed in the regulations (40 C.F.R. §§ 261.31-261.33) or
meets specific criteria that make it toxic, ignitable (i.e., burns readily), corrosive, or reactive
(e.g., explosive) (40 C.F.R. § 261.3).
8 EPA, Planning for Natural Disaster Debris, p. 22-24.

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using this method of waste reduction. Because of the potentially huge volume of
vegetative debris following a disaster, burning may be a preferred method of waste-
handling (which reduces the waste by as much as 95%). If that is the case, local,
state, or federal regulations that control emissions of air pollutants will likely apply.
Further, when mixed or contaminated with other wastes (such as sewage), burning
may not be an option. Also, if residents have begun to return to a disaster area, there
may be significant opposition to burning by community members who would be
affected by the smoke.9
Following are other common categories of waste and special handling
requirements, pursuant to local, state, or federal regulations or recommendations, that
apply to each:
! White goods must be separated from other waste and delivered to
certified recyclers permitted to drain refrigerants and other regulated
chemicals and oils.
! Household hazardous waste (HHW) should be collected separately
and disposed of in specially designed landfills.
! Putrescible wastes rot or decay quickly, and must be managed
quickly to avoid disease vectors (rodents, flies, mosquitoes). Some
putrescibles can be composted and rendered.
! Electronic wastes, which contain lead, mercury, and other heavy
metals, should be separated from other waste recycled or disposed
of as HHW.
! Automobiles and boats generally can be recycled, but gas tanks,
mercury switches, batteries, and tires should be removed and
managed separately.
! Soils and sediments can be reused. However, in agricultural areas,
soil may be too contaminated with fertilizers or other chemicals to
be used on residential or agricultural lands.
Federal and State Agency Roles in Debris Removal
Federal agency response to debris removal after a disaster is generally done in
accordance with provisions of the Robert T. Stafford Disaster Relief and Emergency
Assistance Act (The Stafford Act, 42 U.S.C. §§ 5121-5206) and the National
Response Plan.10 The Stafford Act authorizes the President to issue a “major disaster”
or “emergency” declaration in response to catastrophes that overwhelm state and
local governments. The declaration may also authorize all federal agencies, as
necessary, to provide assistance to respond to a disaster, including the “demolition
of unsafe structures which endanger the public” (§ 5170b) and debris removal
9 The impact to the community depends on the burning method used. For example, air
curtain pit incinerators have fewer environmental impacts than uncontrolled open-air
burning.
10 For more information on provisions of the Stafford Act and the National Response Plan,
see CRS Report RL33053, Federal Stafford Act Disaster Assistance: Presidential
Declarations, Eligible Activities, and Funding, by Keith Bea.

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activities (§ 5173).11 The declaration will also specify geographic areas over which
the declaration is made.
The National Response Plan (NRP) was developed by the Department of
Homeland Security (DHS) to structure the way responders work together and to
provide supporting mechanisms for disasters so serious that the Secretary of DHS
declares them to be “Incidents of National Significance.”12 The NRP applies to
situations in which the resources of state and local authorities are overwhelmed and
authorities have requested federal assistance. Various federal statutory authorities and
policies provide the basis for federal actions and activities in the context of domestic
incident management under the NRP. The NRP does not confer new authorities upon
the Secretary of DHS or any other federal official. Rather, the NRP establishes the
coordinating structures, processes, and protocols required to integrate the specific
statutory and policy authorities of various federal departments and agencies. As with
the Stafford Act, the President has designated DHS as the implementing agency for
the NRP.
Under the NRP, DHS identifies and groups the capabilities of federal
departments and agencies into 15 Emergency Support Functions (ESFs) to provide
the planning, support, resources, program implementation, and emergency services
most likely to be needed.13 Two ESFs include debris removal missions:
! ESF #3, Public Works and Engineering — this includes
infrastructure protection and emergency repair, infrastructure
restoration, engineering services, construction management, and
critical infrastructure liaison. The Corps is the lead agency to
complete this ESF.14
! ESF #10, Oil and Hazardous Materials Response — this includes oil
and hazardous materials response and environmental safety and
short- and long-term cleanup. EPA is the lead agency to complete
this ESF; the Corps provides support.15
11 The Stafford Act and implementing regulations use the term “debris removal” in a broad
sense to encompass the entire process of removing, handling, recycling, and disposing of
debris (44 C.F.R. 206.224).
12 In accordance with provisions of the NRP, all presidentially declared disasters and
emergencies under the Stafford Act are considered Incidents of National Significance (see
“Section II. Planning Assumptions and Consideration” of the NRP, available at
[https://www.fema.gov/pdf/emergency/nrf/nrf-core.pdf]).
13 See FEMA’s National Response Framework, available online at [https://www.fema.gov/
emergency/nrf/].
14 See FEMA’s the National Response Framework, “Emergency Support Function #3 —
Public Works and Engineering Annex,” available online at [https://www.fema.gov/pdf/
emergency/nrf/nrf-esf-03.pdf].
15 See FEMA’s the National Response Framework, “Emergency Support Function #10 —
Oil and Hazardous Materials Response Annex,” available online at [https://www.fema.gov/
pdf/emergency/nrf/nrf-esf-10.pdf].

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Federal Agency Roles
FEMA. FEMA serves two primary roles in debris removal operations. First, it
provides funding to eligible applicants. Second, it may provide direct federal
assistance to an applicant (state or local government) that does not have the capability
to respond to a presidentially declared disaster.16
Funding debris removal. With regard to funding, FEMA provides grant
assistance to reimburse state, tribal, and local governments, and certain types of
private nonprofit organizations for their response and recovery efforts. This is done
through FEMA’s Public Assistance (PA) Grant Program. To be eligible for PA
funding, the debris removal work must
! be a direct result of a presidentially declared disaster,
! occur within the designated disaster area, and
! be the legal responsibility of the applicant at the time of the
disaster.17
Eligible activities must also be in the public interest, which is defined as activities
that will
! eliminate an immediate threat to lives, public health, and safety;
! eliminate immediate threats of significant damage to improved
public or private property;
! ensure the economic recovery of the affected community to the
benefit of the community-at-large; or
! mitigate the risk to life and property by removing substantially
damaged structures and associated appurtenances as needed to
convert property acquired through a FEMA hazard mitigation
program to uses compatible with open space, recreation, or wetlands
management practices.18
The disaster declaration will state whether debris removal operations will be
funded. The federal share will also be specified. That share will be no less than 75%,
but may be more if requested by the state and approved by the President.
Providing direct assistance. When an affected state or local government
does not have the capability required to respond to a presidentially declared disaster,
it may a request direct federal assistance from FEMA.19 The approved request is
called a “mission assignment.” A mission assignment is a work order issued by
FEMA to another federal agency directing completion of a specific assignment in
16 42 U.S.C. § 5172.
17 44 C.F.R. 206.223(a).
18 44 C.F.R. 206.224(a).
19 42 U.S.C. §5173.

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response to a presidential declaration of a major disaster or emergency.20 To have
debris removal activities mission assigned,
! the state must specifically request it from FEMA,
! the community must demonstrate that the required disaster-related
efforts exceed state and local resources, and
! the scope of work must include specific quantifiable, measurable
tasks.
Eligible debris-related activities include
! removing debris from critical roadways and facilities;
! removing debris from curbsides or from eligible facilities and
hauling it to either temporary or permanent disposal sites;
! identifying, designing, operating, and closing debris management
sites;
! monitoring debris removal operations; and
! demolishing and/or removing disaster-damaged structures and
facilities in accordance with FEMA regulations and policies.
Depending on the nature and location of debris (e.g., on farmland, highways, in
the coastal zone), many federal agencies may provide assistance in fulfilling
requirements of the applicable ESF. However, the Corps and EPA are the two lead
agencies responsible for completing debris-related ESFs.
The Corps. The Corps acts as the coordinator for ESF #3 (Public Works and
Engineering). The Corps’s mission includes right-of-way clearance, curbside pickup,
private property debris removal, and property demolition. Included within its ESF #3
mission is providing personnel for the debris removal team, obtaining a contractor
to execute the mission, and coordinating landfill and burn sites and the final disposal
of debris. The management of contaminated debris is coordinated with EPA under
ESF #10.
EPA. Under ESF #3, EPA assists local agencies in locating disposal sites for
debris clearance activities and assists with contaminated debris management
activities by coordinating and/or providing resources, assessments, data, expertise,
technical assistance, monitoring, and other appropriate support.
EPA is the lead federal agency under ESF #10 (Oil and Hazardous Materials
Response). Under the mission, FEMA funds EPA’s retrieval and disposal of orphan
tanks and drums and the collection of household hazardous waste; the collection of
liquid and semi-liquid waste has also been tasked to ESF #10.
EPA generally works with other federal agencies (particularly the Corps), state
agencies, and local governments to facilitate the collection, segregation, and
management of waste. EPA may also provide guidance on such issues as burning
20 FEMA-325, Public Assistance: Debris Management Guide, p. 141.

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debris, proper disposal of equipment that may contain PCBs, and proper handling and
disposal of asbestos-containing debris.
State and Local Agency Roles
The states help coordinate local government requests for federal assistance and
work with FEMA to define the mission. The Corps coordinates with state
representatives regarding operational issues. Alternatively, state or local governments
may choose to accept the debris removal mission themselves and apply to FEMA for
reimbursement.
Local agencies are responsible for providing Rights-of-Entry permits to allow
the Corps or its contractors to enter private property for debris removal activities
(within the Corps’s authority), establishing criteria and procedures for classifying
different types of debris, selecting disposal methods and approving disposal
operations, condemning properties, providing demolition plans, and designating the
appropriate type of landfill.
State environmental protection agencies or departments of environmental
quality are the environmental regulatory arms of state governments. A state
environmental agency may issue a declaration of emergency after a disaster. Such a
declaration would specify how debris removal operations should be carried out for
the particular disaster. For example, after Hurricane Katrina, the Louisiana
Department of Environmental Quality expanded the definition of C&D waste to
essentially allow the entire contents of flooded homes in New Orleans to be disposed
of in C&D landfills. Each state is authorized to implement its own solid and
hazardous waste management programs, including siting and permitting debris
disposal sites.
Selected Challenges to Managing Disaster Debris
There are many challenges to managing disaster debris, particularly if a region
does not have a debris management plan in place. Some of these challenges include
issues associated with managing large volumes of waste, ensuring the ability of
property owners to return to an area and assist with cleanup, separating hazardous
and nonhazardous waste, and managing asbestos-contaminated wastes.
Managing Large Volumes of Waste
The logistics of managing tens of thousands or millions of cubic yards of waste
form a daunting task, even when a community is prepared. When not prepared, a
region must coordinate the physical removal of debris, and likely designate a
temporary staging area to sort and separate the waste before determining the
appropriate management method. If debris removal contractors have not already been
identified, it may be time-consuming to find a sufficient number of waste haulers
able or qualified to do the work.

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CRS-10
Further, as discussed previously, it is generally recommended that communities
conserve landfill space as much as possible by reusing and recycling their disaster
debris. However, this is an option only in so far as there are available markets for
those materials.
Ensuring the Ability of Residents to Return to a Disaster Area
In the event of widespread devastation to a region, the speed with which cleanup
and rebuilding occurs may depend on how quickly debris on private property can be
removed. Generally, debris removal from private property does not qualify for federal
funding because it is considered a responsibility of individual property owners that
may be covered by private insurance. However, if residents move disaster-generated
debris to a public right-of-way (e.g., curbside), federal funding of debris removal may
be available. Therefore, to a certain degree, the speed with which debris from private
property is removed will depend upon the speed with which residents are able to
return to the area and assist in the cleanup.
Separating Hazardous and Nonhazardous Wastes
As discussed above, the separation of waste is also necessary to comply with
existing local, state, and federal waste management regulations. To ensure that
disaster debris is managed appropriately, returning residents are generally asked to
separate debris as much as possible. If residents do not or are unable to separate their
waste, waste management contractors or landfill operators may have to do so.
Separating debris is a time-consuming, costly, and potentially dangerous process.
Further, disaster debris may be mixed to the point that separation is either very
difficult or essentially impossible (i.e., in flooding situations). This may mean that
hazardous waste is mixed with nonhazardous waste and disposed of in a landfill not
intended to hold such waste.
Managing Asbestos-Containing Materials
If a disaster involves the destruction of homes and buildings built before the late
1970s, the presence of asbestos-containing materials (ACM) will likely be a concern.
The need to segregate that material before demolition and disposal will add to the
time it takes to demolish individual structures. Both federal and state laws specify
criteria that must be met when demolishing a structure with asbestos-containing
materials.21 Further, after a disaster, states will likely develop their own protocols for
complying with asbestos requirements as they apply to the destruction and cleanup.22
21 The Clean Air Act (§ 112) establishes national emissions standards for hazardous air
pollutants (NESHAP), including asbestos. Individual states, in coordination with EPA, must
manage ACM in compliance with the asbestos NESHAP, with regard to asbestos removal
and disposal during building destruction and renovation (40 C.F.R. §§ 61.140-61.160).
22 For example, see the Louisiana Department of Environmental Quality’s “LDEQ Protocol
to Comply with the LESHAP Regulations,” March 16, 2006, available at [http://www.deq.
louisiana.gov/portal/Default.aspx?tabid=2251]; and the February 24, 2006, letter from
Granta Nakayama, EPA Assistant Administrator, Office of Enforcement and Compliance,
(continued...)

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EPA will generally work closely with affected states and provide debris management
guidance specific to their disaster conditions. For example, after Hurricane Katrina,
EPA advised states to make efforts to segregate asbestos and certain other types of
waste for proper disposal in landfills prior to burning the debris.23
For Additional Information
Following are selected guidance and fact sheets produced by FEMA, EPA, and
the Corps to assist applicants with the federal funding process, disaster debris
planning, and debris removal operations:
! FEMA report FEMA-325, Public Assistance: Debris Management
Guide, July 2007, available online at [http://www.fema.gov/
government/grant/pa/demagde.shtm].
! EPA Web page “Dealing with Debris and Damaged Buildings,”
available at [http://www.epa.gov/naturalevents/returnhomeadvisory.
htm]. This Web page includes EPA’s “emergency hurricane debris
burning guidance.”
! EPA Report Planning for Natural Disaster Debris, March 2008,
available online at [http://www.epa.gov/CDmaterials/pubs/pndd.
pdf].
! The Corps “Debris Management” fact sheet, available online at
[http://www.swg.usace.army.mil/CorpsHurricaneResponse/].
22 (...continued)
to Mike McDaniel, Secretary, LDEQ, specifying EPA’s agreement with LDEQ regarding
asbestos issues in hurricane-affected areas, available at [http://www.deq.louisiana.gov/
portal/tabid/2223/Default.aspx].
23 EPA website, Hurricane Katrina Response, Frequent Questions, “Asbestos,” available at
[http://www.epa.gov/katrina/faqs.htm].

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