Are wet methods being used during RACM removal and disposal?

When removing RACM, your facility is required to control visible emissions of asbestos to the outside air because no safe concentration of airborne asbestos has ever been established.

Remember that the asbestos NESHAP relating to demolitions, including ship scrapping, is a work practice standard. This means that it does not place specific numerical emission limitations for asbestos fibers on asbestos removals and demolitions. Instead, it requires your facility to implement specific work practices to control asbestos emissions.

The primary method used to control asbestos emissions is to "adequately wet" RACM with a liquid or wetting agent "prior to, during and after" removal activities. To "adequately wet" RACM means to sufficiently mix or penetrate the material with liquid to prevent the release of asbestos particulates. If you or your workers see visible emissions coming from RACM, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet.

To meet the NESHAP wetting provisions, your workers must wet RACM and keep it wet until it is collected and contained for disposal. Adequate wetting is typically accomplished by repeated spraying of the RACM with a liquid or a wetting agent, until it cannot absorb any more. Wetting agents may be applied with garden sprayers or hoses.

An inspector may determine whether RACM has been adequately wetted based on observations made during an inspection. These observations may include, but are not limited to, the following:

Is there a water supply in place?

Is there visible dust (airborne or settled) or dry ACM debris in the immediate vicinity of the operation? An inspector may collect samples of such materials for analyses of their possible asbestos content.

Does the RACM inside the bag (if transparent) appear wet? Remember: ACM must be adequately wet when it is placed in the bags or containers. It is a violation of the asbestos NESHAP standards to put water in the bottom of a bag, then strip the asbestos material dry and let it fall into the water.

Courtesy of The EPA

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