 |
Acronyms and Definitions
Before we list the tips, let’s take a minute to define some asbestos terms that are applicable in demolition/renovation projects.
ACM—asbestos-containing material, i.e., any material that contains more than 1% asbestos. Sometimes it is best to leave ACM in place.
ACWM—asbestos-containing waste material, i.e., waste that contains commercial asbestos and is generated by a source covered by the Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP).
RACM—regulated asbestos-containing material, i.e., friable asbestos material (i.e., ACM that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure) or nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading or has crumbled, or has become friable in the course of demolition or renovation operations. RACM emissions are regulated under the Asbestos NESHAP.
Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get the 2015 EHS Salary Guide, absolutely free. Download Now.
Is Your ACM ‘Adequately Wet’?
The primary method used to control asbestos emissions (which is required by the Asbestos NESHAP) is to adequately wet the ACM with a wetting agent before, during, and after demolition/renovation activities.
Under the Asbestos NESHAP, “adequately wet” means to “sufficiently mix or penetrate with liquid to prevent the release of particulates.”
Adequate wetting of the ACM is typically accomplished by repeatedly spraying it with a liquid or a wetting agent, usually amended water, until it can absorb no more. (Amended water is water to which surfactant chemicals have been added.)
If visible emissions are observed coming from the ACM, that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet. Amended water is often used to wet the ACM during repair or removal operations.
Everything You Need for Environmental Compliance
Enviro.BLR.com puts everything you need at your fingertips, including practical RCRA, CAA, CWA, hazardous waste regulatory analysis and activity, news, and compliance tools. Try it at no cost or risk and get a FREE report.
7 Tips to Help Ensure Your Asbestos Is Adequately Wet
Here are seven tips concerning what asbestos inspectors look for to determine compliance with the adequately wet requirements for the RACM and ACWM.
Tip 1: Make sure there is a water supply in place for the project.
Tip 2: Spray water or a wetting agent on the RACM or ACWM both during stripping or removal and afterwards while the material awaits proper disposal.
Tip 3: Make sure the wetting application method you are using drenches the material to penetrate the ACWM throughout and doesn’t wet just the surface area.
Tip 4: If you are not using water or a wetting agent, make sure you have documentation of the reason why not (e.g., prior permission obtained from the EPA or your state agency because of a safety hazard or potential equipment damage).
Tip 5: Make sure that exposed surfaces of materials that do not readily absorb water or a wetting agent, such as premolded thermal insulation, ceiling tiles, and floor tiles, are adequately wetted.
Tip 6: Make sure there is no visible dust (airborne or settled) or dry ACWM debris in the immediate vicinity of the project.
Tip 7: Make sure that ACWM in bags or other containers is adequately wetted. Indications of adequate wetness include:
- The overall weight of the bag is heavy enough as to indicate wetting.
- There is evidence of moisture in the closed bags (e.g., water droplets, water in the bottom of the bag, a change in the color of the material due to water).
- Moisture droplets are emitted when chunks of debris in the closed bag are squeezed.