Standards Require RACM Be Kept Wet For Removal

The Asbestos NESHAP establishes the following work practice standard requiring RACM to be kept adequately wet:

Procedures for asbestos emission control. Each owner or operator of a demolition or renovation activity shall comply with the following procedures:

When RACM is stripped from a facility component while it remains in place in the facility, adequately wet the RACM during the stripping operation.

For all RACM, including material that has been removed or stripped:

Adequately wet the material and ensure that it remains wet until collected or treated in preparation for disposal in accordance with § 61.150[.]

In essence, these work practice standards require a person engaged in the removal of RACM to adequately wet the material prior to removal and then to keep the material adequately wet until it is collected for disposal.

The regulations define the term "adequately wet" to mean:

[S]ufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from asbestos-containing material, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet.

We have held that the uncontroverted testimony of Agency inspectors regarding their personal observations is sufficient to establish that RACM was not adequately wet at the time of the inspection.